Medicare Program; Advancing Care Coordination Through Episode Payment Models (EPMs); Cardiac Rehabilitation Incentive Payment Model; and Changes to the Comprehensive Care for Joint Replacement Model (CJR), 180-651 [2016-30746]
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Federal Register / Vol. 82, No. 1 / Tuesday, January 3, 2017 / Rules and Regulations
SUPPLEMENTARY INFORMATION:
DEPARTMENT OF HEALTH AND
HUMAN SERVICES
Electronic Access
This Federal Register document is
also available from the Federal Register
online database through Federal Digital
System (FDsys), a service of the U.S.
Government Printing Office. This
database can be accessed via the
internet at https://www.gpo.gov/fdsys/.
Centers for Medicare & Medicaid
Services
42 CFR Parts 510 and 512
[CMS–5519–F]
RIN 0938–AS90
Alphabetical List of Acronyms
Because of the many terms to which
we refer by acronym, abbreviation, or
short form in this final rule, we are
listing the acronyms, abbreviations and
short forms used and their
corresponding terms in alphabetical
order.
Medicare Program; Advancing Care
Coordination Through Episode
Payment Models (EPMs); Cardiac
Rehabilitation Incentive Payment
Model; and Changes to the
Comprehensive Care for Joint
Replacement Model (CJR)
Centers for Medicare &
Medicaid Services (CMS), HHS.
ACTION: Final rule.
AGENCY:
This final rule implements
three new Medicare Parts A and B
episode payment models, a Cardiac
Rehabilitation (CR) Incentive Payment
model and modifications to the existing
Comprehensive Care for Joint
Replacement model under section
1115A of the Social Security Act. Acute
care hospitals in certain selected
geographic areas will participate in
retrospective episode payment models
targeting care for Medicare fee-forservice beneficiaries receiving services
during acute myocardial infarction,
coronary artery bypass graft, and
surgical hip/femur fracture treatment
episodes. All related care within 90
days of hospital discharge will be
included in the episode of care. We
believe these models will further our
goals of improving the efficiency and
quality of care for Medicare
beneficiaries receiving care for these
common clinical conditions and
procedures.
DATES: Effective dates: This rule is
effective February 18, 2017, except for
the following amendatory instructions:
number 3 amending 42 CFR 510.2;
number 4 adding 42 CFR 510.110;
number 6 amending 42 CFR 510.120;
number 14 amending 42 CFR 510.405;
number 15 42 CFR 510.410; number 16
revising 42 CFR 510.500; number 17
revising 42 CFR 510.505; number 18
adding 42 CFR 510.506; and number 19
amending 42 CFR 510.515, which are
effective July 1, 2017.
Applicability date: The regulations at
42 CFR part 512 are applicable July 1,
2017.
FOR FURTHER INFORMATION CONTACT: For
questions related to the EPMs:
EPMRULE@cms.hhs.gov.
For questions related to the CJR
model: CJR@cms.hhs.gov.
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SUMMARY:
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ACE Acute-care episode
ACO Accountable Care Organization
ALOS Average length of stay
AMA American Medical Association
AMI Acute Myocardial Infarction
APM Alternative Payment Model
APRN Advanced Practice Registered Nurse
ASC QRP Ambulatory Surgical Center
Quality Reporting Program
ASC Ambulatory Surgical Center
ASPE Assistant Secretary for Planning and
Evaluation
BAA Business Associate Agreement
BPCI Bundled Payments for Care
Improvement
CABG Coronary Artery Bypass Graft
CAD Coronary artery disease
CAH Critical access hospital
CBSA Core-Based Statistical Area
CC Complication or comorbidity
CCDA Consolidated clinical document
architecture
CCDE Core clinical data elements
CCN CMS Certification Number
CEC Comprehensive ESRD Care Initiative
CEHRT Certified Electronic Health Record
Technology
CEP Clinical Episode Payment
CFR Code of Federal Regulations
CHIP Children’s Health Insurance Program
CJR Comprehensive Care for Joint
Replacement
CMHC Community Mental Health Center
CMI Case Mix Index
CMP Civil monetary penalty
CQMC Core Quality Measure Collaborative
CMS Centers for Medicare & Medicaid
Services
CoP Condition of Participation
CORF Comprehensive Outpatient
Rehabilitation Facility
CPC Comprehensive Primary Care Initiative
CPT Current Procedural Terminology
CR Cardiac rehabilitation
CRNA Certified Registered Nurse
Anesthetists
CSA Combined Statistical Area
CVICU Cardiovascular intensive care units
CY Calendar year
DES Drug-eluting stents
DME Durable medical equipment
DMEPOS Durable medical equipment,
prosthetics, orthotics, and supplies
DR Downside Risk
DSH Disproportionate Share Hospital
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DUA Data Use Agreement
ED Emergency Department
ECMO Extracorporeal membrane
circulation
ECQM Electronic Clinical Quality Measures
EFT Electronic funds transfer
EGM Episode Grouper for Medicare
EHR Electronic health record
E/M Evaluation and management
EPM Episode payment model
ESCO ESRD Seamless Care Organization
ESRD End-Stage Renal Disease
FFS Fee-for-service
FFR Fractional Flow Reserve
GAAP Generally-Accepted Accounting
Principles
GEM General Equivalence Mapping
GPCI Geographic Practice Cost Index
HAC Hospital-Acquired Condition
HACRP Hospital-Acquired Condition
Reduction Program
HCAHPS Hospital Consumer Assessment of
Healthcare Providers and Systems
HCC Hierarchical Condition Category
HCPCS Healthcare Common Procedure
Coding System
HHA Home health agency
HHPPS Home Health Prospective Payment
System
HHRG Home Health Resource Group
HHS U.S. Department of Health and Human
Services
HH QRP Home Health Quality Reporting
Program
HICN Health Insurance Claim Number
HIPAA Health Insurance Portability and
Accountability Act
HIQR Hospital Inpatient Quality Reporting
HIV Human Immunodeficiency Virus
Health IT Health Information Technology
HLM Hierarchical Logistic Regression
model
HLMR HCAHPS Linear Mean Roll Up
HOOS Hip Dysfunction and Osteoarthritis
Outcome Score
HOPD Hospital outpatient department
HRRP Hospital Readmissions Reductions
Program
HRR Hospital Referral Region
HVBP Hospital Value-Based Purchasing
Program
ICD–9–CM International Classification of
Diseases, 9th Revision, Clinical
Modification
ICHOM International Consortium for Health
Outcomes Measurement
IRFQR Inpatient Rehabilitation Facilities
Quality Reporting
ICD Implantable Cardioverter Defibrillator
ICD–10–CM International Classification of
Diseases, 10th Revision, Clinical
Modification
ICR Intensive Cardiac Rehabilitation
I–I Inpatient to inpatient transfer
IME Indirect medical education
IP Inpatient
IPF Inpatient psychiatric facility
IPF QRP Inpatient Psychiatric Facility
Quality Reporting Program
IPPS Inpatient Prospective Payment System
IRF Inpatient rehabilitation facility
IRF QRP Inpatient Rehabilitation Facility
Quality Reporting Program
IVR Active Interactive Voice Recognition
KOOS Knee Injury and Osteoarthritis
Outcome Score
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LAN Healthcare Payment Learning and
Action Network
LBBB Left bundled branch block
LEJR Lower-extremity joint replacement
LEP limited English proficiency
LIP Low-income percentage
LOS Length-of-stay
LTCH QRP Long-Term Care Hospital
Quality Reporting Program
LTCH Long-term care hospital
LUPA Low-utilization payment adjustment
MA Medicare Advantage
MAC Medicare Administrative Contractor
MACRA Medicare Access and CHIP
Reauthorization Act of 2015
MAP Measure Application Partnership
MAPCP Multi-Payer Advanced Primary
Care Practice
MAT Measure Authoring Tool
MCC Major complications or comorbidities
MCCM Medicare Care Choices Model
MDC Major diagnostic category
MDH Medicare-Dependent Hospital
MDM Master Database Management
MedPAC Medicare Payment Advisory
Commission
MIPS Merit-based Incentive Payment
System
MP Malpractice
MSA Metropolitan Statistical Area
MS–DRG Medical Severity DiagnosisRelated Group
MSPB Medicare Spending Per Beneficiary
NHDS National Hospital Discharge Survey
NCDR National Cardiovascular Data
Registry
NDR No Downside Risk
NPI National Provider Identifier
NPPGP Non-Physician Practitioner Group
Practice
NPRA Net Payment Reconciliation Amount
NQF National Quality Forum
NSTEMI Non ST-elevation myocardial
infarction
OCM Oncology Care Model
OIG Department of Health and Human
Services’ Office of the Inspector General
O–I Outpatient-to-inpatient transfer
OPPS Outpatient Prospective Payment
System
OPT Outpatient Physical Therapist
OQR Outpatient Quality Reporting
PACE Program of All-Inclusive Care for the
Elderly
PBPM Per-beneficiary per-month
PCI Percutaneous Coronary Intervention
PCMH Primary Care Medical Homes
PE Practice Expense
PEP Partial Episode Payment
PFS Physician Fee Schedule
PGP Physician group practice
PHA Partial hip arthroplasty
PQRS Physician Quality Reporting System
PPS Prospective Payment System
PRO Patient-Reported Outcome
PROMIS Patient-Reported Outcomes
Measurement Information Systems
PROM Patient-Reported Outcome
Performance Measure
PTAC Focused Payment Model Technical
Advisory Committee
PTCA Percutaneous transluminal coronary
angioplasty
PY Performance year
QCDR Qualified clinical data registries
QE Qualified Entity
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QIO Quality Improvement Organization
QP Qualifying APM Participant
QPP Quality Payment Program
QRDA Quality Reporting Document
Architecture
QRUR Quality and Resource Use Reports
RAC Recovery Audit Contractor
RRC Rural Referral Center
RSCR Risk-Standardized Complication Rate
RSRR Risk-Standardized Readmission Rate
RSMR Risk-Standardized Mortality Rate
RVU Relative Value Unit
SCH Sole Community Hospital
SDS Socio-demographic Status
SFT Secure File Transfer
SHFFT Surgical hip/femur fracture
treatment
SHIP State Health Insurance Assistance
Programs
SILS2 Single Item Health Literacy
Screening
SLA Service level agreement
SNF Skilled nursing facility
SNF–QRP QRP Skilled Nursing Facility
Quality Reporting Program
SSDMF Social Security Death Master file
STEMI ST-elevation myocardial infarction
STS Society of Thoracic Surgeons
ST–T ST-segment-T wave
TEP Technical Expert Panel
TGP Therapy Group Practice
THA Total hip arthroplasty
TIN Taxpayer identification number
TJA Total joint arthroplasty
TKA Total knee arthroplasty
TP Target price
UHDDS Uniform Hospital Discharge Data
Set
VAD Ventricular Assist Device
VBP Value Based Purchasing
VR–12 Veterans Rand 12 Item Health
Survey
Table of Contents
I. Executive Summary
A. Purpose
B. Summary of the Major Provisions
1. Model Overview—EPM Episodes of Care
2. Model Scope
3. Payment
4. Similar, Previous, and Concurrent
Models
5. Overlap With Ongoing CMS Efforts
6. Quality Measures and Reporting
Requirements
7. Beneficiary Protections
8. Financial Arrangements
9. Data Sharing
10. Program Waivers
C. Summary of Economic Effects
II. Background
III. Episode Payment Models
A. Selection of Episodes, Advanced
Alternative Payment Model
Considerations, and Future Directions
1. Selection of Episodes for Episode
Payment Models in This Rulemaking
a. Overview
b. SHFFT Model
c. AMI and CABG Models
2. Advanced Alternative Payment Model
Considerations
a. Overview for the EPMs
b. EPM Participant Tracks
c. Clinician Financial Arrangements Lists
Under the EPMs
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d. Documentation Requirements
3. Future Directions for Episode Payment
Models
a. Refinements to the BPCI Initiative
Models
b. Potential Future Condition-Specific
Episode Payment Models
c. Potential Future Event-Based Episode
Payment Models for Procedures and
Medical Conditions
d. Health Information Technology
Readiness for Potential Future Episode
Payment Models
B. Definition of the Episode Initiator and
Selected Geographic Areas
1. Background
2. Definition of Episode Initiator
3. Financial Responsibility for Episode of
Care
4. Geographic Unit of Selection and
Exclusion of Selected Hospitals
5. Overview and Options for Geographic
Area Selection for AMI and CABG
Episodes
a. Exclusion of Certain MSAs
b. Selection Approach
(1) Factors Considered but Not Used
(2) Sample Size Calculations and the
Number of Selected MSAs
(3) Method of Selecting MSAs
C. Episode Definition for EPMs
1. Background
2. Overview of Three New Episode
Payment Models
3. Clinical Dimensions of AMI, CABG, and
SHFFT Model Episodes
a. Definition of the Clinical Conditions
Included in AMI, CABG, and SHFFT
Model Episodes
(1) AMI (Medical Management and PCI)
Model
(2) CABG Model
(3) SHFFT (Excludes Lower Extremity Joint
Replacement) Model
b. Definition of the Related Services
Included in EPM Episodes
4. EPM Episodes
a. Beneficiary Care Inclusion Criteria and
Beginning of EPM Episodes
(1) General Beneficiary Care Inclusion
Criteria
(2) Beginning AMI Episodes
(3) Beginning CABG Episodes
(4) Beginning SHFFT Episodes
(5) Special Policies for Hospital Transfers
of Beneficiaries With AMI
b. Middle of EPM Episodes
c. End of EPM Episodes
(1) AMI and CABG Models
(2) SHFFT Model
D. Methodology for Setting EPM Episode
Prices and Paying EPM Participants in
the AMI, CABG, and SHFFT Models
1. Background
a. Overview
b. Key Terms for EPM Episode Pricing and
Payment
2. Performance Years, Retrospective
Episode Payments, and Two-Sided Risk
EPMs
a. Performance Period
b. Retrospective Payment Methodology
c. Two-Sided Risk EPMs
3. Adjustments to Actual EPM Episode
Payments and to Historical Episode
Payments Used To Set Episode Prices
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a. Overview
b. Special Payment Provisions
c. Services That Straddle Episodes
d. High-Payment EPM Episodes
e. Treatment of Reconciliation Payments
and Medicare Repayments When
Calculating Historical EPM-Episode
Payments To Update EPM-Episode
Benchmark and Quality-Adjusted Target
Prices
4. EPM-Episode Price-Setting
Methodologies
a. Overview
(1) AMI Model DRGs
(2) CABG Model DRGs
(3) SHFFT Model DRGs
b. EPM-Episode Benchmark and QualityAdjusted Target Price Features
(1) Risk-Stratifying EPM-Episode
Benchmark Prices Based on MS–DRG
and Diagnosis
(2) Adjustments To Account for EPMEpisode Price Variation
(a) Adjustments for Certain AMI Model
Episodes With Chained Anchor
Hospitalizations
(b) Adjustments for CABG Model Episodes
(c) Adjustments for Certain AMI Model
Episodes With CABG Readmissions
(d) Potential Future Approaches To Setting
Target Prices for AMI and Hip Fracture
Episodes
(e) Summary of Pricing Methodologies for
AMI, CABG, and SHFFT Model Episode
Scenarios
(3) 3 Years of Historical Data
(4) Trending Historical Data to the Most
Recent Year
(5) Update Historical EPM-Episode
Payments for Ongoing Payment System
Updates
(6) Blend Hospital-Specific and Regional
Historical Data
(7) Define Regions as U.S. Census Divisions
(8) Normalize for Provider-Specific Wage
Adjustment Variations
(9) Combining Episodes To Set Stable
Benchmark and Quality-Adjusted Target
Prices
(10) Effective Discount Factor
c. Approach To Combine Pricing Features
for all SHFFT Model Episodes and AMI
Model Episodes Without CABG
Readmissions
d. Approach To Combine Pricing Features
for CABG Model Episodes
(1) Anchor Hospitalization Portion of
CABG Model Episodes
(2) Approach To Combine Pricing Features
for Post-Anchor Hospitalization Portion
of CABG Model Episodes
(3) Combine CABG Anchor Hospitalization
Benchmark Price and CABG Post-Anchor
Hospitalization Benchmark Price
e. Approach To Combine Pricing Features
for AMI Model Episodes With CABG
Readmissions
5. Process for Reconciliation
a. Net Payment Reconciliation Amount
(NPRA)
b. Payment Reconciliation
c. Reconciliation Report
6. Adjustments for Overlaps With Other
Innovation Center Models and CMS
Programs
a. Overview
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b. Provider Overlap
(1) BPCI Participant Hospitals in
Geographic Areas Selected for EPMs
(2) BPCI Physician Group Practice (PGP)
Episode Initiators in Hospitals
Participating in EPMs
c. Beneficiary Overlap
(1) Beneficiary Overlap With BPCI
(2) Beneficiary Overlap With the CJR
Model and Other EPMs
(3) Beneficiary Overlap With Shared
Savings Models and Programs
d. Payment Reconciliation of Overlap With
Non-ACO CMS Models and Programs
7. Limits or Adjustments to EPM
Participants’ Financial Responsibility
a. Overview
b. Limit on Actual EPM-Episode Payment
Contribution to Repayment Amounts and
Reconciliation Payments
(1) Limit on Actual EPM-Episode Payment
Contribution to Repayment Amounts
(2) Limitation on Reconciliation Payments
c. Additional Protections for Certain EPM
Participants
(1) Policies for Certain EPM Participants to
Further Limit Repayment Responsibility
(2) Considerations for Hospitals Serving a
High Percentage of Potentially
Vulnerable Populations
d. Application of Stop-Gain and Stop-Loss
Limits
e. EPM Participant Responsibility for
Increased Post-Episode Payments
8. Appeals Process
a. Overview
b. Notice of Calculation Error (First Level
Appeal)
c. Dispute Resolution Process (Second
Level of Appeal)
d. Exception to the Notice of Calculation
Error Process and Notice of Termination
e. Limitations on Review
E. EPM Quality Measures, Public Display,
and Use of Quality Measures in the EPM
Payment Methodology
1. Background
2. Selection of Quality Measures for the
EPMs
a. Overview of Quality Measure Selection
b. AMI Model Quality Measures
c. CABG Model Quality Measures
d. SHFFT Model Quality Measures
3. Use of Quality Measures in the EPM
Payment Methodologies
a. Overview of EPM Composite Quality
Score Methodology
b. Determining Quality Measure
Performance
c. Determining Quality Measure
Improvement
d. Determining Successful Submission of
Voluntary Data for AMI and SHFFT
Models
(1) Hybrid AMI Mortality (NQF #2473)
Voluntary Data
(2) Patient-Reported Outcomes and Limited
Risk Variable Voluntary Data Following
Elective Primary THA/TKA
e. Calculation of the EPM-Specific
Composite Quality Score
(1) AMI Model Composite Quality Score
(2) CABG Model Composite Quality Score
(3) SHFFT Model Composite Quality Score
f. EPM Pay-for-Performance Methodologies
To Link Quality and Payment
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(1) Overview of Pay-for-Performance
Proposals Applicable to the EPMs
(2) AMI and CABG Model Pay-forPerformance Methodology
(a) AMI Model Pay-for-Performance
Methodology
(b) CABG Model Pay-for-Performance
Methodology
(c) Alignment Between the AMI and CABG
Model Methodologies
(3) SHFFT Model Pay-for-Performance
Methodology
4. Details on Quality Measures for the
EPMs
a. AMI Model-Specific Measures
(1) Hospital 30-Day, All-Cause, RiskStandardized Mortality Rate Following
Acute Myocardial Infarction (AMI)
Hospitalization (NQF #0230) (MORT–
30–AMI)
(a) Background
(b) Data Sources
(c) Cohort
(d) Inclusion and Exclusion Criteria
(e) Risk-Adjustment
(f) Calculating the Risk-Standardized
Mortality Ratio (RSMR) and Performance
Period
(2) Excess Days in Acute Care After
Hospitalization for Acute Myocardial
Infarction (AMI Excess Days)
(a) Background
(b) Data Sources
(c) Cohort
(d) Inclusion and Exclusion Criteria
(e) Risk-Adjustment
(f) Calculating the Rate and Performance
Period
(3) Hybrid Hospital 30-Day, All-Cause,
Risk-Standardized Mortality Rate
Following Acute Myocardial Infarction
(AMI) Hospitalization (NQF #2473)
(Hybrid AMI Mortality)
(a) Background
(b) Data Sources
(c) Cohort
(d) Inclusion and Exclusion Criteria
(e) Risk-Adjustment
(f) Calculating the Risk-Standardized
Mortality Ratio (RSMR) and Performance
Period
(g) Requirements for Successful
Submission of AMI Voluntary Data
b. CABG Model-Specific Measure
(1) Hospital 30-Day, All-Cause, RiskStandardized Mortality Rate (RSMR)
Following Coronary Artery Bypass Graft
(CABG) Surgery (NQF #2558) (MORT–
30–CABG)
(a) Background
(b) Data Source
(c) Cohort
(d) Inclusion and Exclusion Criteria
(e) Risk-Adjustment
(f) Calculating the Risk-Standardized
Mortality Ratio (RSMR) and Performance
Period
c. SHFFT Model-Specific Measures
(1) Hospital Level Risk Standardized
Complication Rate (RSCR) Following
Elective Primary Total Hip Arthroplasty
(THA) and/or Total Knee Arthroplasty
(TKA) (NQF #1550) (Hip/Knee
Complications)
(a) Background
(b) Data Sources
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(c) Cohort
(d) Inclusion and Exclusion Criteria
(e) Risk Adjustment
(f) Calculating the Risk Standardized
Complication Rate and Performance
Period
(2) Hospital-Level Performance Measure(s)
of Patient-Reported Outcomes Following
Elective Primary Total Hip and/or Total
Knee Arthroplasty
(a) Background
(b) Data Sources
(c) Cohort
(d) Inclusion and Exclusion Criteria
(e) Outcome
(f) Risk Adjustment (If Applicable)
(g) Calculating the Risk Standardized Rate
(h) Performance Period for Successful
Submission of THA/TKA PatientReported Outcome-Based Voluntary Data
(i) Requirements for Successful Submission
of THA/TKA Patient-Reported-OutcomeBased Voluntary Data
d. Measure Used for All EPMs
(1) Hospital Consumer Assessment of
Healthcare Providers and Systems
(HCAHPS) Survey (NQF #0166)
(a) Background
(b) Data Sources
(c) Cohort
(d) Inclusion and Exclusion Criteria
(e) Case-Mix Adjustment
(f) HCAHPS Scoring
(g) Calculating the Rate and Performance
Period
e. Potential Future Measures
5. Form, Manner, and Timing of Quality
Measure Data Submission
6. Display of Quality Measures and
Availability of Information for the Public
From the AMI, CABG, and SHFFT
Models
F. Compliance Enforcement and
Termination of an Episode Payment
Model
1. Overview and Background
2. Compliance Enforcement for EPMs
3. Termination of an Episode Payment
Model
G. Monitoring and Beneficiary Protection
1. Introduction and Summary
2. Beneficiary Choice
3. Beneficiary Notification
4. Monitoring for Access To Care
5. Monitoring for Quality of Care
6. Monitoring for Delayed Care
H. Access to Records and Record Retention
I. Financial Arrangements Under EPM
1. Background
2. Overview of the EPM Financial
Arrangements
3. EPM Collaborators
4. Sharing Arrangements Under EPM
a. General
b. Requirements
c. Gainsharing Payment, Alignment
Payment, and Internal Cost Savings
Conditions and Restrictions
d. Documentation Requirements
5. Distribution Arrangements Under the
EPM
a. General
b. Requirements
6. Downstream Distribution Arrangements
Under the EPM
a. General
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b. Requirements
7. Summary of Proposals for Sharing,
Distribution, and Downstream
Distribution Arrangements Under the
EPM
8. Enforcement Authority
9. Beneficiary Engagement Incentives
Under the EPM
a. General
b. Technology Provided to an EPM
Beneficiary
c. Clinical Goals of the EPM
d. Documentation of Beneficiary Incentives
10. Compliance With Fraud and Abuse
Laws
J. Waivers of Medicare Program
Requirements
1. Overview
2. Summary of Waivers Adopted Under the
CJR Model
3. Analysis of Current Model Data
a. Analysis of Waiver Usage
b. Analysis of Discharge Destination—PostAcute Care Usage
c. Analysis of Hospital Mean Length of
Stay Data
4. Post-Discharge Home Visits
a. AMI Model
b. CABG Model
c. SHFFT Model
5. Billing and Payment for Telehealth
Services
6. SNF 3-Day Rule
a. Waiver of SNF 3-Day Rule
b. Additional Beneficiary Protections
Under the SNF 3-Day Stay Rule Waiver
7. Waivers of Medicare Program Rules To
Allow Reconciliation Payment or
Repayment Actions Resulting From the
Net Payment Reconciliation Amount
8. New Waiver for Providers and Suppliers
of Cardiac Rehabilitation and Intensive
Cardiac Rehabilitation Services
Furnished to EPM Beneficiaries During
an AMI or CABG Episode
K. Data Sharing
1. Overview
2. Beneficiary Claims Data
3. Aggregate Regional Data
4. Timing and Period of Baseline Data
5. Frequency and Period of Claims Data
Updates for Sharing BeneficiaryIdentifiable Claims Data During the
Performance Period
6. Legal Permission To Share BeneficiaryIdentifiable Data
7. Data Considerations With Respect to
EPM and CJR Collaborators
L. Coordination With Other Agencies
IV. Evaluation Approach
A. Background
B. Design and Evaluation Methods
C. Data Collection Methods
D. Key Evaluation Research Questions
E. Evaluation Period and Anticipated
Reports
V. Comprehensive Care for Joint Replacement
Model
A. Participant Hospitals in the CJR Model
B. Inclusion of Reconciliation and
Repayment Amounts When Updating
Data for Quality-Adjusted Target Prices
C. Quality-Adjusted Target Price
D. Reconciliation
1. Hospital Responsibility for Increased
Post-Episode Payments
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183
2. ACO Overlap and Subsequent
Reconciliation Calculation
3. Stop-Loss and Stop-Gain Limits
4. Modifications to Reconciliation Process
E. Use of Quality Measures and the
Composite Quality Score
1. Hospitals Included in Quality
Performance Distribution
2. Quality Improvement Points
3. Relationship of Composite Quality Score
to Quality Categories
4. Maximum Composite Quality Score
5. Acknowledgement of Voluntary Data
Submission
6. Calculation of the HCAHPS Linear Mean
Roll-Up (HLMR) Score
F. Accounting for Overlap With CMS ACO
Models and the Medicare Shared Savings
Program
G. Appeals Process
H. Beneficiary Notification
I. Compliance Enforcement
1. Failure To Comply
J. Financial Arrangements Under the CJR
Model
1. Definitions Related to Financial
Arrangements
a. Addition to the Definition of CJR
Collaborators
b. Deleting the Term Collaborator
Agreements
c. Addition of CJR Activities
2. Sharing Arrangements
a. General
b. Requirements
c. Gainsharing Payment, Alignment
Payment, and Internal Cost Savings
Conditions and Restrictions
d. Documentation
3. Distribution Arrangements
a. General
b. Requirements
4. Downstream Distribution Arrangements
Under the CJR Model
a. General
b. Requirements
5. Summary of Proposals for Sharing,
Distribution, and Downstream
Distribution Arrangements Under the
CJR Model
K. Beneficiary Incentives Under the CJR
Model
L. Access to Records and Record Retention
M. Waivers of Medicare Program Rules To
Allow Reconciliation Payment or
Repayment Actions Resulting From the
Net Payment Reconciliation Amount
N. SNF 3-Day Waiver Beneficiary
Protections
O. Advanced Alternative Payment Model
Considerations
1. Overview for CJR
2. CJR Participant Hospital Track
3. Clinician Financial Arrangements Lists
Under the CJR Model
4. Documentation Requirements
VI. Cardiac Rehabilitation Incentive Payment
Model
A. Background
B. Overview of the CR Incentive Payment
Model
1. Rationale for the CR Incentive Payment
Model
2. General Design of the CR Incentive
Payment Model
C. CR Incentive Payment Model
Participants
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D. CR/ICR Services That Count Towards
CR Incentive Payments
E. Determination of CR Incentive Payments
1. Determination of CR Amounts That Sum
To Determine a CR Incentive Payment
2. Relation of CR Incentive Payments to
EPM Pricing and Payment Policies and
Sharing Arrangements for EPM–CR
Participants
3. CR Incentive Payment Report
4. Timing for Making CR Incentive
Payments
F. Provisions for FFS–CR Participants
1. Access to Records and Retention for
FFS–CR Participants
2. Appeals Process for FFS–CR Participants
a. Overview
b. Notice of Calculation Error (First Level
Appeal)
c. Dispute Resolution Process (Second
Level of Appeal)
d. Exception to the Notice of Calculation
Error Process and Notice of Termination
e. Limitations on Review
3. Data Sharing for FFS–CR Participants
a. Overview
b. Data Sharing With CR Participants
4. Compliance Enforcement for FFS–CR
Participants and Termination of the CR
Incentive Payment Model
5. Enforcement Authority for FFS–CR
Participants
6. Beneficiary Engagement Incentives for
FFS–CR Participants
7. Waiver of Physician Definition for FFS–
CR Participants Furnishing CR and ICR
Services
a. Overview of Program Rule Waivers
Under an EPM
b. General Physician Requirements for
Furnishing CR/ICR Services
c. Waiver of Physician Definition For
EPM–CR Participants Furnishing CR and
ICR Services
d. Waiver of Physician Definition For FFS–
CR Participants Furnishing CR and ICR
Services
G. Considerations Regarding Financial
Arrangements Under the CR Incentive
Payment Model
VII. Collection of Information Requirements
VIII. Regulatory Impact Analysis
A. Statement of Need
1. Need for EPM Final Rule
2. Need for CJR Modifications
3. Need for CR Incentive Payment Model
4. Aggregate Impact of EPMs, CJR, and CR
Incentive Payment Model
B. Overall Impact
C. Anticipated Effects
1. Overall Magnitude of the Model and Its
Effects on the Market
a. EPMs
b. CJR
c. CR Incentive Payment Model
d. Aggregate Effects on the Market
2. Effects on the Medicare Program
a. EPMs
(1) Assumptions and Uncertainties
(2) Analyses
(3) Uncertainties
b. CJR
(1) Assumptions and Uncertainties
(2) Analyses
c. CR Incentive Payment Model
(1) Assumptions and Uncertainties
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(2) Analysis
d. Further Consideration
3. Effects on Beneficiaries
4. Effects on Small Rural Hospitals
5. Effects on Small Entities
6. Effects on Collection of Information
7. Unfunded Mandates
D. Alternatives Considered
E. Accounting Statement and Table
F. Conclusion
Regulations Text
I. Executive Summary
A. Purpose
The purpose of this final rule—
Advancing Care Coordination through
Episode Payment Models is to
implement the creation and testing of
three new episode payment models
(EPMs) and a Cardiac Rehabilitation
(CR) incentive payment model under
the authority of the Center for Medicare
and Medicaid Innovation (‘‘the
Innovation Center’’), as well as to
implement several modifications to the
Comprehensive Care for Joint
Replacement model. Section 1115A of
the Social Security Act (‘‘the Act’’)
authorizes the Innovation Center to test
innovative payment and servicedelivery models to reduce Medicare,
Medicaid, and Children’s Health
Insurance Program (CHIP) expenditures
while preserving or enhancing the
quality of care furnished to such
programs’ beneficiaries. Under the feefor-service (FFS) program, Medicare
makes separate payments to providers
and suppliers for the items and services
furnished to a beneficiary over the
course of treatment (an episode of care).
With the amount of payments
dependent on the volume of services
delivered, providers may not have
incentives to invest in qualityimprovement and care-coordination
activities. As a result, care may be
fragmented, unnecessary, or duplicative.
The goal for the EPMs is to improve the
quality of care provided to beneficiaries
in an applicable episode while reducing
episode spending through financial
accountability.1 The EPMs include
models for episodes of care surrounding
an acute myocardial infarction (AMI),
coronary artery bypass graft (CABG),
and surgical hip/femur fracture
treatment excluding lower extremity
joint replacement (SHFFT). Under this
final rule, the Centers for Medicare &
Medicaid Services (CMS) will test
whether an EPM for AMI, CABG, and
SHFFT episodes of care will reduce
Medicare expenditures while preserving
or enhancing the quality of care for
1 In this final rule, we use the terms ‘‘AMI
episode,’’ ‘‘CABG episode,’’ and ‘‘SHFFT episode’’
to refer to episodes of care as described in section
III.C. of this final rule.
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Medicare beneficiaries. We anticipate
that the finalized models will benefit
Medicare beneficiaries by improving the
coordination and transition of care,
improving the coordination of items and
services paid for through FFS Medicare,
encouraging more provider investment
in infrastructure and redesigned care
processes for higher-quality and more
efficient service delivery, and
incentivizing higher-value care across
the inpatient and post-acute care
spectrum. We proposed on August 2,
2016 to test the proposed EPMs for 5
performance years, beginning July 1,
2017, and ending December 31, 2021 (81
FR 50799) and we are finalizing those
dates as proposed in this final rule.
Within this final rule, we discuss
three distinct EPMs focused on episodes
of care for AMI, CABG, and SHFFT
episodes. We chose these episodes for
the models because, as discussed in
depth in section III.A. of this final rule
and as stated in the proposed rule, we
believe hospitals would have a
significant opportunity to redesign care
and to improve the quality of care
furnished during the applicable episode.
The EPMs will enable hospitals to
consider the most appropriate strategies
for care redesign, including: (1)
Increasing post-hospitalization followup and medical management for
patients; (2) coordinating across the
inpatient and post-acute care spectrum;
(3) conducting appropriate discharge
planning; (4) improving adherence to
treatment or drug regimens; (5) reducing
readmissions and complications during
the post-discharge period; (6) managing
chronic diseases and conditions that
may be related to the EPMs’ episodes;
(7) choosing the most appropriate postacute care setting; and (8) coordinating
between providers and suppliers such
as hospitals, physicians, and post-acute
care providers. The EPMs would offer
hospitals the opportunity to examine
and better understand their own care
processes and patterns with regard to
patients in AMI, CABG, and SHFFT
episodes, as well as the processes of
post-acute care providers and
physicians.
We previously have used our
statutory authority under section 1115A
of the Act to test other episode payment
models such as the Bundled Payments
for Care Improvement (BPCI) initiative
and Comprehensive Care for Joint
Replacement (CJR) model. Bundled
payments for multiple services in an
episode of care hold participating
organizations financially accountable
for that episode of care. Such models
also allow participants to receive
payments based in part on the reduction
in Medicare expenditures that arise
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from such participants’ care redesign
efforts. This payment can be used for
investments in care redesign strategies
and infrastructure, as well as to
incentivize collaboration with other
providers and suppliers furnishing
services to beneficiaries included in the
models.
We believe the EPMs will further the
Innovation Center’s mission and the
Administration’s goal of increasingly
paying for value and outcomes, rather
than for volume alone,2 by promoting
the alignment of financial and other
incentives for all health care providers
caring for beneficiaries during SHFFT,
CABG, or AMI episodes. The acute care
hospital where an eligible beneficiary
has a hospitalization for one of the
procedures or clinical conditions
included in these EPMs will be held
accountable for spending during the
episode of care. EPM participants could
earn reconciliation payments by
appropriately reducing expenditures
and meeting certain quality metrics.
EPM participants will also gain access
to data and educational resources to
better understand care patterns during
the inpatient hospitalization and postacute periods, as well as associated
spending. Payment approaches that
reward providers for assuming financial
and performance accountability for a
particular episode of care create
incentives for the implementation and
coordination of care redesign between
participants and other providers and
suppliers such as physicians and postacute care providers.
The AMI, CABG, and SHFFT models
will require the participation of
hospitals in multiple geographic areas
that might not otherwise participate in
testing episode payment for the
episodes of care. CMS is testing other
episode payment models with the BPCI
initiative and the CJR model. The BPCI
initiative is voluntary; providers applied
to participate and chose from 48 clinical
episodes. BPCI participants entered the
at-risk phase between 2013 and 2015
and have the option to continue
participating in the initiative through
FY 2018. In the CJR model, acute care
hospitals in selected geographic areas
are required to participate in the CJR
model for all eligible lower-extremity
joint replacement (LEJR) episodes that
initiate at a CJR participant hospital.
The CJR model began its first of 5
performance years on April 1, 2016.
Realizing the full potential of new EPMs
will require the engagement of an even
broader set of providers than have
participated to date in our episode
payment models such as the BPCI
initiative and the CJR model. As such,
we are interested in testing and
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evaluating the impact of episode
payment for the three EPMs in a variety
of circumstances, including those
hospitals that may not otherwise
participate in such a test.
While we note that testing of the CJR
model that began in April 2016 will
allow CMS to gain experience with
requiring hospitals to participate in an
episode payment model, the clinical
circumstances of the episodes we
proposed (AMI, CABG, and SHFFT)
differ in important ways from the LEJR
episodes included in the CJR model.
LEJR procedures are common among the
Medicare population, and the majority
of such procedures are elective. In
contrast, under the three EPMs, CMS
will test episode payment for certain
cardiac conditions and procedures, as
well as SHFFT. We expect the patient
population included in these episodes
will be substantially different from the
patient population in CJR episodes, due
to the clinical nature of the cardiac and
SHFFT episodes. Beneficiaries in these
episodes commonly have chronic
conditions that contribute to the
initiation of the episodes, and need both
planned and unplanned care throughout
the EPM episode following discharge
from the hospitalization that begins the
episode. Both AMI and CABG model
episodes primarily include beneficiaries
with cardiovascular disease, a chronic
condition which likely contributed to
the acute events or procedures that
initiate the episodes. About half the
average AMI model historical episode
spending was for the hospitalization,
with the majority of spending following
discharge from the hospitalization due
to hospital readmissions, while there
was relatively less spending on SNF
services, Part B professional services,
and hospital outpatient services. In
CABG model historical episodes, about
three-quarters of episode spending was
for the hospitalization, with the
remaining episode spending relatively
evenly divided between Part B
professional services and hospital
readmissions, and a lesser percentage on
SNF services. Similar to AMI episodes,
post-acute care provider use was
relatively uncommon in CABG model
historical episodes, while hospital
readmissions during CABG model
historical episodes were relatively
common. SHFFT model historical
episodes also were accompanied by
substantial spending for hospital
readmissions, and post-acute care
provider use in these episodes also was
high.2 The number of affected
2 Episodes for AMI, CABG, and SHFFT
beneficiaries initiated by all U.S. IPPS hospitals not
in Maryland and constructed using standardized
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185
beneficiaries and potential impact of the
models on quality and Medicare
spending present an important
opportunity to further the
Administration’s goal of shifting health
care payments to support the quality of
care over the quantity of services by
promoting better coordination among
health care providers and suppliers and
greater efficiency in the care of
beneficiaries in these models, while
reducing Medicare expenditures.3 Payfor-performance episode payment
models such as the three EPMs in this
rule financially incentivize improved
quality of care and reduced cost by
aligning the financial incentives of all
providers and suppliers caring for
model beneficiaries with these goals.
This alignment leads to a heightened
focus on care coordination and
management throughout the episode
that prioritizes the provision of those
items and services which improve
beneficiary outcomes and experience at
the lowest cost. A more detailed
discussion of the evidence supporting
the episode selection for these models
can be found in section III.A.1. of this
final rule.
These models will also allow CMS to
gain additional experience with
episode-payment based approaches for
hospitals with variance in (1) historic
care and utilization patterns; (2) patient
populations and care patterns; (3) roles
within their local markets; (4) volumes
of services; (5) levels of access to
financial, community, or other
resources; and (6) levels of population
and health-care-provider density,
including local variations in the
availability and use of different
categories of post-acute care providers.
We believe that participation in the
EPMs by a large number of hospitals
with diverse characteristics will result
in a robust data set for evaluating this
payment approach and will stimulate
the rapid development of new evidencebased knowledge. Testing the EPMs in
this manner will also allow us to learn
more about patterns of inefficient
utilization of health care services and
how to incentivize quality improvement
for beneficiaries receiving services in
AMI, CABG, and SHFFT episodes. This
knowledge could potentially inform
future Medicare payment policies.
We proposed the CR incentive
payment model to test the effects on
Medicare FFS Parts A and B claims, as proposed in
this rule that end in CY 2014.
3 Sylvia Mathews Burwell, HHS Secretary,
Progress Towards Achieving Better Care, Smarter
Spending, Healthier People, https://www.hhs.gov/
blog/2015/01/26/progress-towards-better-caremsarter-spending-healthier-people.html (January
26, 2015).
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quality of care and Medicare
expenditures of providing financial
incentives to hospitals for beneficiaries
hospitalized for treatment of AMI or
CABG to encourage care coordination
and greater utilization of medically
necessary CR and intensive cardiac
rehabilitation (ICR) services for 90 days
post-hospital discharge where the
beneficiary’s overall care is paid under
either an EPM or the Medicare FFS
program. Despite the evidence from
multiple studies that CR services
improve health outcomes, the literature
also indicates that these services are
underutilized, estimating that only
about 35 percent of AMI patients older
than 50 receive this indicated
treatment.4 5 6 Recent analysis confirms a
similar pattern of underutilization for
Medicare beneficiaries who are eligible
for and could benefit from CR.
Considering the evidence
demonstrating that CR/ICR services
improve long-term patient outcomes,
the room for improvement in CR/ICR
service utilization for beneficiaries
eligible for this benefit, and the need for
ongoing, chronic treatment for
underlying coronary artery disease
(CAD) among beneficiaries that have
had an AMI or a CABG, we believe that
there is a need for improved long-term
care management and care coordination
for beneficiaries that have had an AMI
or a CABG and that incentivizing the
use of CR/ICR services is an important
component of meeting this need. We
want to reduce barriers to high-value
care by testing a financial incentive for
hospitals that encourages the
management of beneficiaries that have
had an AMI or a CABG in ways that may
contribute to long-term improvements
in quality and reductions in Medicare
spending.
We sought public comment on the
proposals contained in the proposed
rule (81 FR 50794) published on August
2, 2016, and also on any alternatives
considered. Public comment and our
responses to those comments follow
under the applicable sections. The
applicable sections contain our
proposed policy changes, commenters’
reactions, and our responses.
We received approximately 175
timely pieces of correspondence
containing multiple comments on the
EPM proposed rule. We note that some
of these public comments were outside
of the scope of the proposed rule. These
5 Anderson L. et al. Exercise-based cardiac
rehabilitation for coronary heart disease. Cochrane
Database Syst Rev. 2016 Jan 5;1:CD001800.
6 Receipt of outpatient cardiac rehabilitation
among heart attack survivors—United States, 2005.
MMWR Morbidity and mortality weekly report.
2008 Feb 1:57(4):89–94.
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out-of-scope public comments are
mentioned in this section but are not
addressed with the policy responses in
this final rule. The following is a
summary of the comments received on
the proposed model as a whole,
including the authority for the model
and general comments on CMS’
implementation of the EPM model at
this time and our responses.
Comment: Some commenters
expressed support for the proposed
EPMs and for requiring participation
from specific hospitals in the selected
geographic regions. Other commenters
requested whether CMS has the
authority under section 1115A of the
Social Security Act (the Act) to
implement the EPMs as proposed, while
others stated specifically that they
believe CMS cannot compel provider
participation and further stated that
they did not believe Congress intended
to delegate its authority to make
permanent changes to the Medicare
program to the Secretary through the
Innovation Center.
Many commenters raised concerns
that interpreting section 1115A to mean
that requiring participation in models is
permissible under statute holds
significant implications for the patients
and providers included in the proposed
EPMs, as required models could
negatively impact the Medicare Shared
Savings Program (Shared Savings
Program) and/or Accountable Care
Organizations (ACOs).
Response: While we appreciate the
support expressed by some commenters,
we disagree with the contention that the
Innovation Center lacks the authority to
test models under section 1115A of the
Act in which participation is required.
Section 1115A of the Act authorizes the
Secretary to test innovative payment
and service delivery models to reduce
program expenditures while preserving
or enhancing the quality of care
furnished to Medicare, Medicaid, and
Children’s Health Insurance Program
(CHIP) beneficiaries, and section 1115A
of the Act does not specify that
participation in models must be
voluntary. As discussed in section IV. of
this final rule, one of the reasons that
we have determined it is necessary to
test the EPM models by requiring the
participation of certain hospitals is to
obtain more generalizable evaluation
results.
Moreover, the Secretary has authority
to establish regulations to carry out the
administration of Medicare.
Specifically, the Secretary has authority
under both sections 1102 and 1871 of
the Act to implement regulations as
necessary to administer Medicare,
including testing these Medicare
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payment and service delivery models.
We note that the EPMs will test different
methods for delivering and paying for
services covered under the Medicare
program, which the Secretary has clear
legal authority to regulate.
To be clear, we did not propose, and
are not finalizing, permanent changes to
Medicare, but rather are testing payment
and service delivery models under
section 1115A(b) of the Act. While the
EPMs require the participation of
certain participant hospitals, the EPMs
are not permanent changes to the
Medicare program. We acknowledge the
importance of examining the impact of
the EPMs as this test will implement
models at the geographic regional level.
The EPMs are thus intended to enable
CMS to test and evaluate the effects of
episode payment approaches on a
broader range of Medicare providers and
suppliers than would choose to
participate in an alternative payment
model. More specifically, the evaluation
is to conduct a multifaceted and multipronged examination of issues of
quality, access, and consequences.
Randomized evaluation designs of this
kind helps to reduce the systematic
differences among hospitals that are and
are not participating in the EPMs, which
helps to ensure that, on average,
differences in outcomes between
participating and non-participating
hospitals reflect the impact of the
model. Testing these models in this
manner also allows us to learn more
about patterns of inefficient utilization
of health care services and how to
incentivize the improvement of quality
for AMI, CABG, and SHFFT procedure/
diagnosis episodes. This learning can
potentially inform future Medicare
payment policy.
We do not believe the EPMs will harm
the continuation of a permanent
Medicare program such as the Shared
Savings Program, We continue to
believe that while we test the EPMs,
ACOs will still work towards the goals
of the Shared Savings Program. These
goals have been previously described
(76 FR 67801) and include ensuring the
coordination of care for beneficiaries,
regardless of the time or place of that
care, being innovative in service
delivery by drawing upon the best, most
advanced models of care, and using
modern technologies, including
telehealth and electronic health records,
and other tools to continually reinvent
care in the modern age.
We refer to our discussion about ACO
overlap with the proposed EPMs that
was included in the proposed rule (81
FR 50870) and acknowledge the
concerns expressed by some ACOs that
the current CJR and BPCI ACO overlap
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policies deprive them of a key source of
savings. Because ACOs in certain types
of two-sided risk arrangements have
stronger incentives than those in onesided risk arrangements to reduce total
cost of care, especially given the
possibility of paying CMS shared losses,
we believe that ACOs in such two-sided
risk arrangements may be best
positioned to assume the risk associated
with EPM episodes, while ACOs in onesided risk arrangements may be less
well-positioned to do so. Furthermore, it
is more operationally feasible to identify
and exclude beneficiaries who are
prospectively aligned to ACOs.
Comment: One commenter believed
that the EPMs did not satisfy the
requirement that the model address ‘‘a
defined population for which there are
deficits in care leading to poor clinical
outcomes or potentially avoidable
costs’’ as is required by section
1115A(b)(2)(A) of the Act.
Response: Models tested under
section 1115A of the Act must address
a defined population for which there are
either deficits in care leading to poor
clinical outcomes or potentially
avoidable expenditures. As discussed in
section III.C. of the proposed rule (81 FR
50829–50843) and section III.C. of this
final rule, these models satisfy the
requirements of section 1115A(b) of the
Act, as the EPMs address defined
populations (FFS Medicare beneficiaries
experiencing acute myocardial
infarctions, coronary artery bypass
grafting procedures and/or surgical hip/
femur fracture treatment) for which
there are potentially avoidable
expenditure because there are no strong
incentives for coordinated care, which
can lead to suboptimal care. As
discussed in section IV. of this final
rule, one of the reasons that we have
determined it is necessary to require the
participation of hospitals in multiple
geographic areas that might not
otherwise participate in testing episode
payment for the episodes of care is to
provide more generalizable evaluation
results of the impacts of these models.
Comment: A few commenters asserted
that the SHFFT model is equivalent to
an expansion of the CJR model under
section 1115A(c) of the Act. The same
commenters stated that the SHFFT EPM
model test should not be finalized in
this rule as the CJR model has not yet
satisfied the requirements of section
1115A(c) of the Act. One commenter
stated that before implementing the
SHFFT EPM, CMS must first complete
the evaluation of the CJR model
required under section 1115A(b)(4) of
the Act; make the determinations
required under section 1115A(c)(1) and
(3) of the Act; and receive the
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certification from the Chief Actuary
required under section 1115A(c)(2) of
the Act.
Response: Regarding the commenters’
assertion that the proposed SHFFT
model expands the CJR model prior to
the CJR evaluation, we note that this is
not the case. We agree that section
1115A of the Act establishes the
necessary criteria for the Secretary to
expand payment and service delivery
models. However, the SHFFT model we
are finalizing in this rule is not an
expansion of the CJR model under
section 1115A(c) of the Act. Rather, the
SHFFT EPM model is a new model test
under section 1115A(b) of the Act. The
CJR model is still at the initial model
test stage, and we will not make any
determinations about continuing the
CJR model test through expansion under
section 1115A(c) of the Act until there
is sufficient information from
evaluation(s) to assess its potential for
expansion. While the SHFFT EPM
model test complements the CJR model
test, it is a separate and distinct model
test. Specifically, the SHFFT model
differs from the CJR model in that the
CJR model is largely for planned
admissions for hip and knee
replacements and the episode of care
begins with an admission to a
participant hospital of a beneficiary who
is ultimately discharged under MS–DRG
469 (Major joint replacement or
reattachment of lower extremity with
major complications or comorbidities)
or 470 (Major joint replacement or
reattachment of lower extremity without
major complications or comorbidities).
In contrast, the SHFFT model tests a
hospital payment for hip fixation and
the episode of care eventually results
from a discharge paid under MS–DRG
480 (Hip and femur procedures except
major joint with major complication or
comorbidity—CC), MS–DRG 481 (Hip
and femur procedures except major joint
with complication or comorbidity—
MCC), or MS–DRG 482 (Hip and femur
procedures except major joint without
CC or MCC). Therefore, the
interventions under each model test
would not overlap. Further, the SHFFT
model test would give hospitals already
participating in the CJR model different
experience in managing care for hip and
femur fracture cases that typically
present emergently, rather than the
planned, elective surgery that is most
common for lower extremity joint
replacement. Despite this geographic
overlap, beneficiaries who initiate an
episode in either the SHFFT or CJR
model remain in that initial model and
are precluded from initiating a
simultaneous episode in the CJR or
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SHFFT models respectively. As a result,
the evaluations of the CJR model and
the SHFFT model will assess the effect
of discrete episodes.
Comment: Some commenters
expressed support for the intended goals
of the EPMs, and stated they want to
contribute to moving our health care
system to a value-based system.
However, many commenters disagreed
with the process used by CMS to
achieve this goal. Specifically,
commenters stated that CMS moved too
fast and too soon in implementing these
models. Furthermore, commenters
believe that the breadth and speed of the
CMS models expanded exponentially.
Commenters stated that in situations
when multiple initiatives are being
implemented simultaneously, for
example Meaningful Use, new
conditions of participation for
emergency preparedness, multiple
clinical and payment changes to the
existing fee-for-service payment
systems, performance requirements of
payment reforms such as the MACRA,
and state regulatory changes to health
care, commenters stated that hospitals
may have little time or resources
available for thoughtful care redesigns
to be applied to the proposed model. A
few commenters noted that the
insurance marketplace in general
remains volatile, adding further
complication to the health care
landscape, while others believe
generally that CMS is putting the
existing initiatives’ success at risk as a
result of the proposed pace of
implementation of new programs and
models.
Commenters raised concerns that they
were unable to submit informed
comments on the proposed rule because
they did not have sufficient data on the
CJR model, making it difficult to assess
even early experience with the process
of implementation of models that
require participation. Other commenters
submitted statements of experience
related to implementation of the CJR
model, specifically that implementation
was administratively challenging due to
the need to first develop a process of
care redesign and then implement
operational changes related to efficiency
as well as specific provisions of the
model, including but not limited to
collaboration agreements, provisions for
beneficiary notifications, and data
analysis. As a result of this experience,
commenters requested that CMS delay
the implementation time line of the
EPMs. The alternative time lines
proposed by commenters varied. A few
commenters stated that it would be
unreasonable to implement a new
episode payment model before
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evaluation of the outcomes and
processes of existing bundled payment
models. Other commenters suggested
that CMS generally delay
implementation until the agency can
address concerns related to risk
adjustment, minimum volume
thresholds, comprehensiveness of
payment, and episode definitions.
Commenters believed that launching the
proposed models simultaneously will
require an incredible administrative
effort, which may hinder the ability to
effectively direct clinical resources
towards best practices for success. To
this end, commenters also suggested
alternative proposals, including but not
limited to reconsideration of
implementing cardiac EPMs; delay,
pilot, or narrow the scope of the
proposed SHFFT model; delay the start
date of the proposed EPMs until no
earlier than January 1, 2018; provide
hospitals with at least 12 months of
preparation time from the date the final
rule is finalized. Other commenters
believed hospitals should not be subject
to downside risk for at least 12 months
from the implementation date of the
final rule, and other commenters
suggested that CMS delay the onset of
downside risk beyond the first quarter
of performance year 2. Commenters
suggested CMS delay implementation to
allow both CMS and EPM participants
to prepare to be successful during
testing of the model. Specifically,
commenters stated that CMS should use
the delay to establish a dialogue with
hospitals to improve the existing
bundled payment experience, perform
outcomes studies on existing models
and programs, analyze the existing CJR
model to determine the model’s impact
to beneficiaries’ outcomes and longer
term well-being, and create
infrastructure to more easily attribute
patients to the EPMs. Commenters also
stated that such a delay would allow
time for EPM participants to better
understand the clinical and financial
risk of their patient populations, to
establish collaborator relationships and
to create the internal organization
structure to manage payment bundles. A
few commenters specifically suggested
changes in payment once the riskbearing phase begins, to allow a
prospective payment to the EPM
participants upon determination of an
eligible diagnosis, as this change could
permit all collaborating providers to
share in both the upside and downside
financial risk, and not be constrained by
what Medicare pays for services during
the episode. Overall, most commenters
requested that CMS generally apply a
more strategic process to achieve the
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intended goals by building on the
experience to date to set the health care
system on a pathway to success rather
than rolling out new models before
anything concrete is gleaned from
existing models.
Response: We appreciate the
comments we received in support of our
proposed performance period and start
date. We also appreciate comments
expressing concerns around the timing
of this model. Although we believe that
it is important to initiate these EPMs
now since they are different than CJR
and BPCI and will provide essential
information about the potential for
episode payment to improve care and
lower spending, we are sensitive to
commenters’ concerns that our
proposed date to implement downside
risk may not provide sufficient time for
participants to implement the kinds of
changes needed to successfully
participate in the model, particularly
given the availability of baseline data.
Accordingly, this final rule will increase
available preparation time by not
implementing downside risk for all
participants in the EPMs until October
1, 2018. Downside risk for EPM
episodes will be applied to episodes
ending on or after January 1, 2019. As
discussed in detail in section III.D. of
this final rule, participants who are
interested in taking on downside risk
earlier can choose to begin downside
risk for episodes ending on or after
January 1, 2018. Additionally, specific
amendments to the regulations
regarding the CJR model access to
records and records retention policy,
compliance enforcement policy, and
waiver of the SNF 3 day rule will take
effect July 1, 2017. We refer readers to
sections V.H., V.I., and V.L. of the final
rule for discussions of our final
decisions. We believe that these changes
will both facilitate participants’ abilities
to be successful under these models and
allow for a more gradual transition to
full financial responsibility under the
models. CMS will also continue to work
internally to determine the extent to
which the suggestions submitted by
commenters, including performing
education and outreach activities or
outcomes studies on existing models,
will impact the implementation of the
EPMs. The EPMs will only include a
limited number of episode types, and as
such we believe it is reasonable for
hospitals to begin to analyze data and
identify care patterns and opportunities
for care redesign for these episodes prior
to assuming financial responsibility for
spending for episode beginning after
October 1, 2018. We also note that due
to the gradual implementation of
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financial responsibility that was
proposed and that will still be
incorporated in the models even given
the start of the phased-in downside risk
that we are finalizing in this rule, we
expect that hospitals will spend the first
performance year of the model
analyzing data, identifying care
pathways, forming clinical and financial
relationships with other providers and
suppliers, and assessing opportunities
for savings under the model, utilizing in
part the claims data we provide to them.
As a result of these changes, we do not
believe that further changes are needed
to the start date of implementation. We
also do not agree with commenters that
implementation of the model is
premature or that it should not be
implemented until results for CJR or
other episode-based payment models
are available. While we anticipate that
these models will offer valuable
information that should assist CMS in
developing future episode payment
models, the EPMs will offer additional
insights that are not available under the
CJR model; in particular, insights with
respect to episode payment models on
a distinct set of episodes for participants
that would not otherwise participate
under a model such as BPCI.
Likewise, we do not agree that the
models should be implemented after
certain other actions have occurred or
because of the multiple competing
mandates faced by hospitals and other
providers. Since the Medicare program’s
inception, providers have and will
continue to contend with constantly
evolving statutory and administrative
requirements that often require them to
make concurrent changes in their
practices and procedures. We do not
believe the EPMs are dissimilar to those
requirements.
Also as discussed earlier in this
section, some commenters pointed to
the potential for unintended
consequences that could result from our
proposed start date, including
impediments to beneficiary access and
reduced quality of care. As discussed in
section III.E. of this final rule, we are
including quality measures for purposes
of evaluating hospitals’ performance
both individually and in aggregate
across the models. Also, as discussed in
section III.F. of this final rule, we are
making final policies and actions to
monitor both care access and quality.
We believe these features will help
ensure that beneficiary access to high
quality care is not compromised under
the EPMs.
Comment: Commenters raised specific
concerns that the proposed EPMs’
emphasis on cost-savings could
incentivize hospitals to use the least
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costly post-acute alternative rather than
the option that is most appropriate for
the beneficiary. Furthermore,
commenters stated that under an
episode payment structure, EPM
participants that admit healthier
patients would have better financial
results. Some commenters believe this
design will consequently impact
Medicare beneficiaries and the Medicare
Trust Fund by increasing the frequency
of Medicare payments from participants
initiating a higher volume of episodes in
a healthier population of beneficiaries.
Other commenters believed that the
proposed regulation would have serious
negative impacts on Medicare
beneficiaries by encouraging
unnecessary surgeries and on health
care stakeholders by discouraging
innovation. One commenter encouraged
us to create a patient advisory panel so
that beneficiary viewpoints could be
incorporated into model planning for
the EPMs and any other Innovation
Center bundled payment models.
Response: We appreciate the
commenters’ concerns regarding the
quality of care for Medicare
beneficiaries. Improving the quality of
care is a central goal of the Innovation
Center’s work to test new payment and
service delivery models. We disagree
with commenters that the models will
negatively impact the quality of care for
beneficiaries in these models and we
refer readers to the monitoring and
beneficiary protections discussion in
section III.G. of this final rule which we
believe will address the commenters’
concerns about care stinting. We
emphasize that care stinting or denying
the provision of medically necessary
care is not permitted under the EPMs.
Medicare beneficiaries in the EPMs will
retain the right to obtain health services
from any individual or organization
qualified to participate in the Medicare
program, and EPM participants are
required to supply beneficiaries with
written information regarding the design
and implications of these models as
well as the beneficiaries’ rights under
Medicare, including their right to use
their providers of choice. We disagree
with commenters that the EPMs will
stifle innovation for care furnished
during an EPM episode. We proposed,
and are finalizing in this final rule, a
payment methodology that will account
for changes in care patterns and
utilization trends for EPM episodes as
described in section III.D. of this final
rule and will have a monitoring
contractor actively reviewing claims and
monitoring behavior of participant
providers to ensure beneficiary choice
and care are not compromised by the
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EPMs. The Federal Government has
long recognized the important role of
the public in developing effective
policies. Advisory committees are a way
of ensuring public and expert
involvement and advice in federal
decision-making. In compliance with
the Federal Advisory Committee Act
(FACA) the number of advisory
committees is carefully managed and
committee memberships reflect a
balance of viewpoints, education, and
experience. Although the establishment
of a Patient Advisory Committee for all
Innovation Center models is beyond the
scope of this rule, we believe that
stakeholder engagement is essential to
the success of these models and our
learning and monitoring contractors as
well as our evaluation contractor will be
soliciting beneficiary feedback on their
experiences with the EPMs.
Comment: While some commenters
appreciated the approach of CMS to
implement episode-based payment
models for a select group of clinical
scenarios, others suggested that
participation be voluntary, in order to
allow hospitals and providers
implementing other payment reforms
like the MACRA a more gradual
adoption process of EPMs. An
additional voluntary component to the
proposed EPMs, commenters stated,
would also permit additional
participants who are interested in the
models but not located in the MSAs in
which the models will be tested to
volunteer for participation. Still, other
commenters stated that single-episode
initiatives fail to encourage systemic
change within organizations, and may
hinder competition if implemented.
Commenters stated that as a result of
mandated participation, many surgeons
who and facilities which lack
familiarity, experience, or proper
infrastructure to support care redesign
efforts will hamper provider
participation, bias model performance
evaluation, and negatively affect patient
care. One commenter suggested that the
nature of the models will provide
information about how many
organizations, and which organizations,
fail. Other commenters commended
CMS for the episode payment models.
The commenters believed that this
overall strategy will motivate hospitals
to work more closely with other
members of the patient’s care team,
which could reduce avoidable
complications after surgery and
decrease the risk of additional
hospitalizations.
Response: We thank the commenters
for their feedback, but disagree with the
suggestion to finalize the proposed
EPMs as a voluntary initiative. The
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EPMs will give CMS the ability to test
how an episode payment model might
function among participants that would
otherwise not participate in such a
model. As such, we expect the results
from these models will produce data
that are more broadly representative
than what might be achieved under a
voluntary model. Also, these models
test a regional target pricing approach to
consider a participant hospital’s
performance relative to its regional
peers. As part of this test, we will learn
whether our alternative pricing
approach in these models will better
incentivize participants who are already
delivering high quality and efficient
care while still incentivizing historically
less efficient providers to improve. We
would not be able to test such a regional
pricing approach under a purely
voluntary model, nor could the
appropriate evaluation approach be
implemented if participants could
volunteer, because it is likely that only
the already high quality and efficient
providers would sign up.
Comment: Many commenters
supported our use of notice and
comment rulemaking for the EPMs and
encouraged us to continue to use the
notice and comment rulemaking process
to facilitate a robust public dialogue on
important issues related to the EPMs
and the CR incentive payment model.
These commenters generally agreed
with the proposed EPM episodes. A few
commenters were concerned that we
would avoid notice and comment
rulemaking requirements.
Response: We appreciate the
commenters’ support for the use of
notice and comment rule-making for the
EPM models. The EPMs are intended to
enable CMS to better understand the
effects of payment models on a broader
range of Medicare providers than what
is currently being tested under the BPCI
initiative. To this end, testing the EPMs
in the proposed manner will also allow
us to learn more about patterns of
inefficient utilization of health care
services and how to incentivize
improvement in quality for common
AMI episodes.
We respectfully disagree that we are
avoiding notice and comment
rulemaking. We note that the proposed
rule (81 FR 50794), promulgated in
accordance with the requirements of 5
U.S.C. 553, went into great detail about
the provisions of the proposed EPMs,
enabling the public to fully understand
and comment on how the proposed
models were designed and could apply
to those affected providers and
beneficiaries. In this final rule, which is
also being promulgated in accordance
with the requirements of 5 U.S.C. 553,
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we respond to the public comments
received on our proposals, and after
considering them, we are finalizing our
proposals with some modifications.
Comment: Commenters questioned
the extent to which EPM participants
would have the knowledge, skills, and
experience to successfully drive
improvements in care delivery and
health outcomes. Many commenters
asserted they do not have enough
experience to even know where the
efficiencies in care delivery are
available to take advantage of them,
which limits the ability of the EPMs’
potential success. Another commenter
recommended CMS inform the
participants that will be in these
episode payment models as early as
possible. To this end, many commenters
recommended that CMS implement a
broad-based education campaign
regarding the new EPMs that uses all of
CMS’ communication channels to reach
hospitals, post-acute care providers,
physicians, and community-based
providers of long term services and
supports.
There were many unique suggestions
by commenters to appropriately
communicate the proposed EPMs to
affected stakeholders. A few
commenters were generally uncertain
where CMS could articulate its vision
for innovative payment models. A few
other commenters believed CMS should
explain in detail the applicable EPMs,
provide contact information and a
publicly accessible list of all the
providers that are part of the model in
each region. Other commenters
requested more opportunity to analyze
the lessons learned from Health Care
Payment Learning and Action Network
(HCP–LAN), Clinical Episode Payment
(CEP) work group, and BPCI so they can
be broadly applied to care redesigns as
part of the proposed EPMs. To support
learning efforts, some commenters
recommended CMS to include in final
regulations a requirement that
participating hospitals must develop,
have approved by CMS, and implement
a comprehensive, effective clinical care
model and leadership structure for
coordinating care and managing
implementation of the EPMs. A few
suggested that CMS assign a Medicare
Project Officer to assist CJR and EPM
participants. One commenter suggested
that CMS provide advanced education
and clinical-financial tools attainable
through a blend of registries, databases
and CMS claims data. Other
commenters supported the intention of
CMS to establish a learning and
diffusion program.
Response: We agree with commenters
regarding the need to continually
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improve stakeholder outreach for
models to succeed and we intend to do
as much as we can to work to design
and deploy a helpful learning and
diffusion program. CMS is committed to
continuing to facilitate performance
improvement by identifying areas of
excellence for the purposes of
extrapolating best practices. CMS
encourages collaboration amongst
organizations and can provide guidance
on the development and
implementation of specific learning
systems. We currently deploy the
expertise and experience of The
Innovation Center’s Learning and
Diffusion Group to facilitate learning
within models by disseminating the
lessons learned across models so that
participants can benefit from the
experiences of other models, and are
always looking for better ways to
educate and assist participants in
knowledge sharing. For example, BPCI
includes a shared learning network that
brings experienced stakeholders
together for knowledge sharing,
collaboration, and peer-to-peer learning.
We continue to believe that these efforts
contribute to reducing the
administrative burden on the health
care delivery system and will be
responsive to commenters’ concerns.
Comment: One commenter stated that
they believe CMS should engage in
models which enhance sharing of best
practices rather than financial
incentives.
Response: We appreciate the
commenter’s submission and agree with
the sentiment that providers of care in
the EPMs should ensure quality of care
is maintained or improved. The design
of the episode-based payments directly
corresponds with CMS’ stated goal of
decreasing costs while maintaining or
improving quality. Within this
framework, we anticipate best practices
naturally evolving as participants
explore care redesign to achieve
efficiencies in the episode.
Comment: Many commenters
applauded many of the design features
in the new proposed models—
suggesting that the proposed rule
outlined the framework for models that
could become very successful at
reducing Medicare spending and
improving patient care. One commenter
suggested that CMS develop
accreditation standards for participation
and only select accredited EPM
participants. Another commenter
suggested considering Quality
Improvement Organizations (QIOs) as
participants, or that QIOs be more
centrally involved in such models to
continue to recognize the importance of
care transitions.
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Response: We thank commenters for
their support of the proposed design
features in the new proposed models.
The QIO Care Transitions Project 7
previously tested the extent to which
QIOs lead improvements in care
transitions. Research found reduced
rates of 30-day re-hospitalization and
all-cause hospitalization per 1,000,
however the reduced rate of all-cause
30-day re-hospitalization as a
percentage of hospital discharges was
not statistically significant. We will
continue to work internally to evaluate
the extent to which QIOs complement
the operations of the EPMs. We disagree
with the suggestion to develop
accreditation standards, as such actions
are distinct from testing of EPMs, and
the proposal to define EPM episode
initiators as only those accredited EPM
participants. The definition of the
episode initiator is discussed further in
section III.B of this final rule.
As discussed in more detail in section
V. of this final rule, we proposed
numerous modifications to the CJR
model, which began on April 1, 2016.
Section V. of this final rule contains our
proposed policy changes, commenters’
reactions, and our responses. We
discuss here comments we received on
the CJR model as a whole, including
several comments pertaining to model
policies for which we did not propose
any changes, as well as our responses.
Comment: In general, commenters
expressed support for the CJR model.
One commenter suggested that CMS
extend the model on a voluntary basis
after the conclusion of the model’s 5
performance years, to allow for
successful participants to continue
under CJR. The commenter also
suggested that in such a scenario, CMS
allow for convening organizations to
participate (as is the case currently
under the BPCI initiative) and modify
the model design to include features
such as financial risk for the post-acute
care period only. The commenter noted
that such flexibility would encourage
participation in alternative payment
models.
Another commenter expressed
support for the CJR model but noted the
significant time and effort required for
hospitals to implement the model.
Commenters also requested several
policy changes out of scope for this
rulemaking, including: Additional
relaxation of regulatory barriers to
integration between hospitals and other
stakeholders, removal of fractures in
7 Brock J, et al., Association between quality
improvement for care transitions in communities
and rehospitalizations among Medicare
beneficiaries. JAMA. 2013 Jan 23;309(4):381–91.
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their entirety from this episode payment
model, additional waivers of Medicare
program rules, additional quality
measures, policies that would encourage
use of specific medical devices
associated with lower revision rates,
and modifications to the pricing
methodology that would include
comprehensive risk adjustment. Finally,
one commenter requested that data be
provided on a more frequent basis.
Response: We thank the commenters
for their support of the CJR model. With
regard to the CJR model policies for
which we did not propose any changes,
we will continue to consider the issues
commenters brought forward and if
warranted, would address any changes
through future rulemaking as necessary.
In addition, we note that while
currently we provide CJR hospitals with
episode data on a quarterly basis, we
may begin to consider providing such
data on a monthly basis when
practicable.
Comment: A few commenters
supported CMS’ pursuit of
opportunities to spread value-based
payment to more providers through
additional episode payment models
beyond lower extremity joint
replacement.
Response: We acknowledge and
appreciate the commenters’ remarks.
Comment: A few commenters
addressed issues on the following
subject-matter areas: Alternative
administration of medications, nonmedically directed anesthesia delivery,
remote patient monitoring, data
collection for global surgical services,
and the long term care hospital
certification program.
Response: These comments pertain to
issues for which we did not include any
proposals in the proposed rule.
Therefore, we believe these comments
are outside the scope of the proposed
rule, and we are not addressing them in
this final rule. After carefully
considering all of the comments we
received on the proposed model,
including those discussed previously
and within the following pages, for the
reasons described elsewhere in this rule,
we have concluded that we can
successfully test the Episode Payment
Models with several modifications and
timing changes. The final model design
we are implementing includes
additional lead time for participants
prior to the onset of downside risk to
ensure that the models have time to
incorporate risk adjustment into pricing,
a commitment to conduct public
listening sessions on risk adjustment
during the 2017 calendar year and
rulemaking during the 2018 calendar
year on risk adjustment methods, an
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exemption for the Medicare Shared
Savings Program Track 3 ACOs from
participation in the EPMs and
adjustments to the AMI transfer policy
and the CABG quality measures. All of
these changes are discussed in detail in
this final rule.
B. Summary of the Major Provisions
1. Model Overview—EPM Episodes of
Care
The EPMs, as described further in
section III.B.2. of this final rule, are an
AMI, CABG, or SHFFT model episode
that will begin with an inpatient
admission to an anchor hospital
assigned to one of the following MS–
DRGs upon beneficiary discharge. Acute
care hospital services furnished to
beneficiaries in AMI, CABG, and SHFFT
episodes currently are paid under the
Inpatient Prospective Payment System
(IPPS) through several Medicare
Severity-Diagnosis Related Groups (MS–
DRGs): For AMI episodes, AMI MS–
DRGs (280–282) and those Percutaneous
Coronary Intervention (PCI) MS–DRGs
(246–251) representing IPPS admissions
for AMI that are treated with PCIs;
CABG MS–DRGs (231–236); and SHFFT
MS–DRGs (480–482). Episodes will end
90 days after the date of discharge from
the anchor hospital, as defined under
§ 512.2. Defining EPMs’ episodes of care
in such a manner offers operational
simplicity for both providers and CMS.
The EPMs’ episodes will include the
inpatient stays and all related care
covered under Medicare Parts A and B
within the 90 days after discharge,
including hospital care, post-acute care,
and physician services.
2. Model Scope
Consistent with the CJR model, we
proposed that acute care hospitals
would be the episode initiators and bear
financial risk under the proposed AMI,
CABG and SHFFT models. In
comparison to other health care
facilities, hospitals are more likely to
have resources that would allow them to
appropriately coordinate and manage
care throughout an episode, and
hospital staff members already are
involved in hospital-discharge planning
and post-acute care recommendations
for recovery, key dimensions of highquality and efficient care. We proposed
to require all hospitals to participate
that are paid under the IPPS, have a
CMS Certification Number (CCN), and
have an address located in selected
geographic areas to participate in the
EPMs, with limited exceptions. An
eligible beneficiary who receives care at
such a hospital will automatically be
included in the applicable EPM. We
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proposed to select geographic areas
through a random sampling
methodology.
For the CR incentive payment model,
we proposed to provide a CR incentive
payment specifically to selected
hospitals with financial responsibility
for AMI or CABG model episodes
(hereinafter EPM–CR participants)
because they are already engaged in
managing the AMI or CABG model
beneficiary’s overall care for a period of
time following hospital discharge.
Similarly, we believe there are
opportunities to test the same financial
incentives for hospitals where the
beneficiary’s overall care is paid under
the Medicare FFS program. Thus, we
also proposed to provide a CR incentive
payment specifically to selected
hospitals that are not AMI or CABG
model participants (hereinafter FFS–CR
participants).
Our geographic-area selection process
is detailed further in section III.B.4. of
this final rule.
3. Payment
We will test the AMI, CABG, and
SHFFT EPMs for 5 performance years.
The first performance year would begin
July 1, 2017. During these performance
years we will continue paying hospitals
and other providers and suppliers
according to the appropriate Medicare
FFS payment systems. However, after
the completion of a performance year,
the Medicare claims payments for
services furnished to an eligible
beneficiary during an episode, based on
claims data, will be combined to
calculate an actual episode payment.
The actual episode payment will then
be reconciled against an established
EPM quality adjusted target price. The
amount of this calculation, if positive,
will be paid to the EPM participant as
a ‘‘reconciliation payment’’ provided
they had achieved a quality category of
‘‘acceptable’’ or higher. If the amount of
this calculation is negative, we will
require a ‘‘Medicare repayment’’ from
the participant hospital beginning with
episodes ending in performance year 3
of the EPMs. We had proposed to phase
in the requirement that participants
whose actual episode payments exceed
the quality adjusted target price pay the
difference back to Medicare beginning
in the second quarter of performance
year 2, and under this proposal, CMS
would not require a Medicare
repayment from hospitals for actual
episode payments that exceed their
target price in performance year 1 and
the first quarter of performance year 2.
Our final rule implements the
requirement for Medicare repayments
during performance year 3 and includes
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an applicable discount factor that would
be used for calculating repayment
amounts for performance years 3 and 4.
Also, participants may elect to assume
downside risk for performance year 2,
which would also include an applicable
discount factor for calculating
repayment amounts.
In contrast to the CJR model, due to
the clinical characteristics and common
patterns of care in AMI episodes, we
proposed payment adjustments in the
cases of certain transfers and
readmissions of beneficiaries to
inpatient hospitals for these episodes.
These payment adjustments are
discussed in detail in sections
III.D.4.b.(1). through III.D.4.b.(2).(a). of
the proposed and this final rule. We did
not finalize one of these proposals—a
payment adjustment for AMI episodes
involving an inpatient-to-inpatient
transfer or what we referred to as a
chained anchor hospitalization. We also
proposed payment adjustments for
CABG model episodes, which we are
finalizing in this rule. We proposed and
are making final with modification
limits on how much a hospital can gain
or lose based on its actual episode
payments relative to quality adjusted
target prices, including policies to
further limit the risk of high payment
cases for special categories of
participants as described in sections
III.D.7.a. through III.D.7.d. of this final
rule. In response to comments, we are
finalizing a policy to extend separate
financial loss protections to participants
with a low volume of episodes under a
model, which we refer to as EPM
volume protection hospitals.
In addition to the EPMs, we proposed
to test a CR incentive payment model
(81 FR 50800) to encourage the
utilization of CR/ICR services for
beneficiaries hospitalized for treatment
of AMI or CABG. To determine the CR
incentive payment, we proposed to
count the number of CR/ICR services for
the relevant time periods under the
Outpatient Prospective Payment System
(OPPS) and PFS on the basis of the
presence of paid claims of the HCPCS
codes that report CR/ICR services and
the units of service billed. The initial
level of the per service CR incentive
amount would be $25 per CR/ICR
service for each of the first 11 CR/ICR
services paid for by Medicare during an
AMI or CABG model episode or AMI or
CABG care period. After 11 CR/ICR
services are paid for by Medicare for a
beneficiary, the level of the per service
CR incentive amount will increase to
$175 per CR/ICR service for each
additional CR/ICR service paid for by
Medicare during the AMI or CABG
model episode or AMI care period or
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CABG care period. A more detailed
discussion of the CR incentive payment
is located in section VI.E.1 of this final
rule. The CR performance years would
be the same as the performance years for
the EPMs in section III.D.2.a. of this
final rule. Further details about the
payment structure and design of the CR
incentive payment model can be found
in section VI. of this final rule.
4. Similar, Previous, and Concurrent
Models
The EPMs are informed by other
models and demonstrations currently
and previously conducted by CMS, and
will explore additional ways to use
episode payment to enhance
coordination of care and improve the
quality of care.
We recently announced practices that
will participate in the Oncology Care
Model (OCM), an episode payment
model for physician practices
administering chemotherapy. Under
OCM, practices will enter into payment
arrangements that include both financial
and performance accountability for
episodes of care surrounding
chemotherapy administration to cancer
patients. We will coordinate with other
payers to align with OCM in order to
facilitate enhanced services and care at
participating practices.8
The Innovation Center previously
tested innovative episode payment
approaches in the Medicare Acute Care
Episode (ACE) demonstration,9 and, as
described in this final rule, currently is
testing additional approaches under the
BPCI initiative and the CJR model. The
ACE demonstration tested an alternative
payment approach for cardiac and
orthopedic inpatient surgical services
and procedures. All Medicare Part A
and Part B services pertaining to the
inpatient stay were included in the ACE
demonstration episodes of care.
Evaluations of the ACE demonstration
found that while there was not strong
quantitative evidence indicating
improvements in quality, there was
qualitative evidence that hospitals
worked to improve processes and
outcomes as a result of their
participation in the demonstration.
Currently, we are testing the BPCI
initiative, which is composed of related
payment models that link payments for
multiple services that a Medicare
beneficiary receives during an episode
of care into a bundled payment. Under
the initiative, entities enter into
8 More information on the OCM can be found on
the Innovation Center’s Web site at https://
innovation.cms.gov/initiatives/Oncology-Care/.
9 Information on the ACE Demonstration can be
found on the Innovation Center’s Web site at https://
innovation.cms.gov/initiatives/ACE/.
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payment arrangements with CMS that
include financial and performance
accountability for episodes of care.
Episodes of care under the BPCI
initiative begin with either: (1) An
inpatient hospital stay or (2) post-acute
care services following a qualifying
inpatient hospital stay. The BPCI
initiative is evaluating the effects of
episode-based payment approaches on
patient experience of care, outcomes,
and cost of care for Medicare FFS
beneficiaries. Participating
organizations chose from 48 clinical
episodes, including hip and femur
procedures except major joint, acute
myocardial infarction, percutaneous
coronary intervention, and coronary
artery bypass graft surgery. BPCI Model
2 is an episode payment model in which
a qualifying acute care hospitalization
initiates a 30-, 60-, or 90-day episode of
care. The episode includes the inpatient
stay in an acute care hospital and all
related services covered under Medicare
Parts A and B during the episode,
including post-acute care services.10
Our experience testing BPCI Model 2
informed the design of the three
proposed EPMs. Although some interim
evaluation results from the BPCI models
are available, final evaluation results for
the models within the BPCI initiative
are not yet available. However, we
believe that CMS’ experiences with
BPCI support the design of the proposed
EPMs. Stakeholders both directly and
indirectly involved in testing BPCI
models have conveyed that they
perceive the initiative to be an effective
mechanism for advancing better, more
accountable care and aligning providers
along the care continuum. This message
has been reinforced through CMS site
visits to participating entities, the
Bundled Payments summit in
Washington, in-person meetings with
Awardees at CMS, and Awardee-led
Affinity Group discussions. The BPCI
initiative incorporates 48 clinical
episodes, including cardiac and
orthopedic episodes similar to the AMI,
CABG, and SHFFT models. These
clinical episodes are being tested by
over 1,200 Medicare providers,
including acute care hospitals,
physician group practices, skilled
nursing facilities, and home health
agencies. Cardiac and orthopedic
clinical episodes are among the most
popular episodes in BPCI, indicating
that BPCI awardees participating in
BPCI believe they can reduce cost and
10 More information on BPCI Model 2 can be
found on the Innovation Center’s Web site at https://
innovation.cms.gov/initiatives/BPCI-Model-2/.
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improve quality for beneficiaries in
these episodes of care.
Our design and implementation of the
CJR model, which is an episode
payment model for LEJR episodes, also
informed the design of the AMI, CABG,
and SHFFT EPMs. After releasing a
proposed rule in July 2015 and
receiving nearly 400 comments from the
public, in November 2015 we released
final regulations implementing the CJR
model. Approximately 800 acute care
hospitals (approximately 23 percent of
all IPPS hospitals) now participate in
the CJR model. The first CJR
performance year began on April 1,
2016. The CJR model will continue for
5 performance years, ending on
December 31, 2020. The AMI, CABG,
and SHFFT models build upon our
experience designing and implementing
the CJR model, including feedback from
providers and other public stakeholders
during the CJR model’s rulemaking and
implementation processes.
Further information on why specific
elements of the models and initiatives
were incorporated into the EPMs’
designs is discussed later in this final
rule.
5. Overlap With Ongoing CMS Efforts
We proposed to exclude from
participation in the AMI, CABG, and
SHFFT models certain acute care
hospitals participating in BPCI Models 2
and 4 for the hip and femur procedures
except major joint or for all three of the
BPCI cardiac episodes (AMI, PCI, and
CABG). We proposed to exclude from
EPMs beneficiaries prospectively
aligned to Innovation Center ACO
models which had downside financial
risk such as the Next Generation ACO
and the Comprehensive ESRD Care
models. We also sought comment
regarding whether this exclusion should
be extended to include beneficiaries
assigned to Track 3 Shared Savings
Program ACOs as these ACOs also have
prospective assignment and downside
financial risk. As discussed in the
proposed rule, other CMS programs,
such as the Shared Savings Program
(Tracks 1 and 2) and other accountable
care organization (ACO) or total cost of
care initiatives will remain eligible for
EPM episode initiation. We proposed to
account for overlap, that is, where EPM
beneficiaries also are included in other
models and programs to ensure the
financial policies of the models are
maintained and results and spending
reductions are attributed to one model
or program. Specifically, as with CJR,
we have proposed to give precedence to
existing BPCI models when a
beneficiary is admitted to an acute care
hospital for what would otherwise be a
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covered EPM episode but that acute care
hospital or the treating physician is
participating in BPCI and the admission
would meet the criteria to be covered
under BPCI. In addition, as with CJR, an
EPM episode will be cancelled if a
beneficiary whose hospitalization
initiates an EPM episode receives
treatment during the post discharge
period that would also result in the
episode being covered under BPCI.
Based on the comments received, we are
finalizing these proposals with the
modification that we will exclude from
EPMs not only those beneficiaries
prospectively assigned to the Next
Generation ACO and the
Comprehensive ESRD Care models
which also share in downside risk with
CMS, but also those beneficiaries
prospectively assigned to Track 3
Shared Savings Program ACOs. More
detail on our policies for accounting for
provider- and beneficiary-level overlap
is discussed in section III.D.6. of this
final rule.
The amendments made by the
Medicare Access and CHIP
Reauthorization Act of 2015 (MACRA)
(Pub. L. 114–10, April 16, 2015) created
two paths for eligible clinicians to link
quality to payments: The Merit-Based
Incentive Payment System (MIPS) and
Advanced Alternative Payment Models
(APMs). These two paths create a
flexible payment system called the
Quality Payment Program as finalized
by CMS in the Quality Payment Program
final rule with comment period (81 FR
77008 through 77831). The MIPS
streamlines and improves on three
current programs—the Physician
Quality Reporting System (PQRS), the
Physician Value-based Payment
Modifier (VM), and the Medicare
Electronic Health Record (EHR)
Incentive Program—and continues the
focus on quality and value in one
cohesive program. Through sufficient
participation in Advanced APMs,
eligible clinicians can become
Qualifying APM Participants (QPs) for a
payment year beginning with CY 2019
and potentially receive an APM
Incentive Payment (or, in later years, a
more favorable payment update under
the PFS) for the year.
So that the EPMs may be able to meet
the criteria to be Advanced APMs based
on the requirements in the Quality
Payment Program final rule with
comment period, we proposed to
require EPM participants to use
Certified Electronic Health Record
Technology (CEHRT) (as defined in
section 1848(o)(4) of the Act) in Track
1 of each EPM. We proposed that EPM
participants in these tracks must use
certified health information technology
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193
(IT) functions, in accordance with the
definition of CEHRT under our
regulation at 42 CFR 414.1305, to
document and communicate clinical
care with patients and other health care
professionals as described in the Quality
Payment Program final rule with
comment period. We also made similar
proposals with respect to CJR.
We proposed to implement two
different tracks within the EPMs
whereby EPM participants that meet
requirements for use of CEHRT and
financial risk would be in Track 1 (an
Advanced APM track) and EPM
participants that do not meet these
requirements would be in Track 2 (a
non-Advanced APM track). The
different tracks would not change how
EPM participants operate within the
EPM itself, beyond the requirements
associated with selecting to meet
CEHRT use requirements. The only
distinction between the two tracks is
that only Track 1 EPMs could be
considered an Advanced APM for
purposes of the Quality Payment
Program based on the criteria in the
Quality Payment Program final rule
with comment period. We made similar
proposals with respect to CJR. We
considered modifying requirements
proposed in this rule as necessary to
reconcile them with policies adopted in
the Quality Payment Program final rule.
A more detailed discussion of how
EPMs and CJR could qualify as
Advanced APMs, and how eligible
clinicians participating in the EPMs and
CJR will be identified and affected, can
be found in sections III.A.2 and V.O. of
this final rule.
Comment: One commenter suggested
that the most relevant definition of
CEHRT to the EPM is found at § 495.4.
Response: The definition at 42 FR
495.4 relates to Medicaid eligible
professionals, eligible hospitals, and
CAHs, as defined for the EHR Incentive
Programs. The definition at 45 FR
414.1305 relates to Medicare eligible
clinicians and groups participating as
defined for the CMS Quality Payment
Program. These two definitions are
substantively the same; however, we
refer readers to the definition at 42 FR
495.4 as this most closely relates to the
eligibility status of EPM participants.
We have updated and finalized this
technical correction.
6. Quality Measures and Reporting
Requirements
Similar to the quality measures
selected for the CJR model, we proposed
to use established measures used in
other CMS quality-reporting programs
for the proposed EPMs’ episodes. We
proposed to use these measures to test
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EPMs’ success in achieving its goals
under section 1115A of the Act and to
monitor for beneficiary safety. For the
SHFFT model, we proposed applying
the same quality measures selected for
the CJR model.
The quality measures for SHFFT
episodes are as follows:
• THA/TKA Complications: HospitalLevel Risk-Standardized Complication
Rate (RSCR) Following Elective Primary
Total Hip Arthroplasty (THA) and/or
Total Knee Arthroplasty (TKA)
(National Quality Forum [NQF] #1550).
• Hospital Consumer Assessment of
Healthcare Providers and Systems
(HCAPHS) Survey (NQF #0166).
• Successful Voluntary Reporting of
Patient-Reported Outcomes.
The measures for the AMI model are
as follows:
• MORT–30–AMI: Hospital 30-Day,
All-Cause, Risk-Standardized Mortality
Rate (RSMR) Following Acute
Myocardial Infarction (AMI)
Hospitalization (NQF #0230).
• AMI Excess Days: Excess Days in
Acute Care after Hospitalization for
Acute Myocardial Infarction (acute care
days include emergency department,
observation, and inpatient readmission
days).
• HCAPHS Survey (NQF #0166),
linear mean roll-up (HLMR) scores like
CJR.
The measures for the CABG model are
as follows:
• MORT–30–CABG: Hospital 30-Day,
All-Cause, Risk-Standardized Mortality
Rate (RSMR) Following Coronary Artery
Bypass Graft Surgery (NQF #2558).
• HCAPHS Survey (NQF #0166),
HLMR scores like CJR.
We proposed and requested public
feedback on options for including
successful implementation testing of the
Hybrid AMI measure as a quality
measure for the AMI episode. The
Hybrid AMI measure will assess a
hospital’s 30-day risk-standardized
acute myocardial infarction mortality
rate and will incorporate a combination
of claims data and EHR data submitted
by hospitals. Public comment and our
responses to those comments follow
under the applicable sections in section
III. of this final rule.
We are finalizing as proposed the
following quality measures for SHFFT
episodes:
• THA/TKA Complications: HospitalLevel Risk-Standardized Complication
Rate (RSCR) Following Elective Primary
Total Hip Arthroplasty (THA) and/or
Total Knee Arthroplasty (TKA)
(National Quality Forum [NQF] #1550).
• Hospital Consumer Assessment of
Healthcare Providers and Systems
(HCAPHS) Survey (NQF #0166).
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• Successful Voluntary Reporting of
Patient-Reported Outcomes.
We are finalizing as proposed the
following measures for the AMI model:
• MORT–30–AMI: Hospital 30-Day,
All-Cause, Risk-Standardized Mortality
Rate (RSMR) Following Acute
Myocardial Infarction (AMI)
Hospitalization (NQF #0230).
• AMI Excess Days: Excess Days in
Acute Care after Hospitalization for
Acute Myocardial Infarction (acute care
days include emergency department,
observation, and inpatient readmission
days).
• HCAPHS Survey (NQF #0166),
linear mean roll-up (HLMR) scores like
CJR.
We are finalizing as proposed the
following measures for the CABG
model:
• MORT–30–CABG: Hospital 30-Day,
All-Cause, Risk-Standardized Mortality
Rate (RSMR) Following Coronary Artery
Bypass Graft Surgery (NQF #2558).
• HCAPHS Survey (NQF #0166),
HLMR scores like CJR.
In addition, after consideration of
comments received, we are finalizing an
additional measure for the CABG model.
Successful voluntary reporting of the
Society of Thoracic Surgeons (STS)
CABG composite score (NQF #0696) is
a comprehensive NQF-endorsed
composite measure and will be
weighted at 10 percent of the composite
quality score for those hospitals that
report this voluntary measure.
Additionally, similar to the CJR
model, we proposed to adopt a pay-forperformance methodology for EPMs that
relies upon a composite quality score to
assign respective EPM participants to
four quality categories. These quality
categories will determine an EPM
participant’s eligibility for a
reconciliation payment should such
EPM participant achieve spending
below the quality-adjusted target price,
as well as the effective discount
percentage at reconciliation. Points for
quality performance and improvement
(as applicable) will be awarded for each
episode measure and then summed to
develop a composite quality score that
will determine the EPM participant’s
quality category for the episode. Quality
performance will make up the majority
of available points in the composite
quality score, with improvement points
available as ‘‘bonus’’ points for the
measure. This approach resembles the
CJR model methodology.
7. Beneficiary Protections
As with the CJR model, Medicare
beneficiaries in the EPM models will
retain the right to obtain health services
from any individual or organization
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qualified to participate in the Medicare
program. Eligible beneficiaries who
receive services from EPM participants
would not have the option to opt out of
inclusion in the applicable model. We
proposed to require EPM participants to
supply beneficiaries with written
information regarding the design and
implications of these models as well as
the beneficiaries’ rights under Medicare,
including their right to use their
providers of choice. We will make a
robust effort to reach out to beneficiaries
and their advocates to help them
understand the models. We also
proposed to use our existing authority,
if necessary, to audit participant
hospitals if claims analysis indicates an
inappropriate change in furnished
services. Beneficiary protections are
discussed in greater depth in section
III.G. of this final rule.
8. Financial Arrangements
We proposed a regulatory structure
for financial relationships under the
EPM to advance the goals of improving
the quality and efficiency of model
episodes, which also included program
integrity safeguards to protect against
abuse under the financial relationships
permitted for the EPM. Our EPM
proposals reflected changes from the
current CJR model regulations that
generally fell into the following four
categories: (1) Removing duplication of
requirements in similar provisions; (2)
streamlining and reorganizing the
provisions for clarity and consistency;
(3) providing additional flexibility in
response to feedback from CJR
participant hospitals and other
stakeholders; and (4) expanding the
scope of financial arrangements under
the EPM. In addition to the collaborators
permitted under the CJR model, we
proposed to add hospitals and critical
access hospitals (CAHs) to the list of
providers and suppliers eligible for
gainsharing as EPM collaborators due to
the expected participation of multiple
hospitals in the episode care for some
beneficiaries in AMI and CABG
episodes. We specifically proposed that
ACOs be eligible for gainsharing as EPM
collaborators due to the interest of ACOs
in gainsharing during the CJR model
rulemaking and the ongoing challenges
of addressing overlap between episode
payment models and ACOs. We made
additional proposals that would allow
ACOs to enter into financial
arrangements under the EPM with ACO
participants and ACO providers/
suppliers and to allow physicians group
practices (PGPs) that are ACO
participants in an ACO that is an EPM
collaborator to enter into financial
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arrangements under the EPM with PGP
members.
As discussed in section III.I. of this
final rule, after consideration of the
public comments received we are
finalizing the proposed structure for
financial arrangements under the EPM,
including that EPM participants may
enter into sharing arrangements with
EPM collaborators, EPM collaborators
may enter into distribution
arrangements with collaboration agents,
and collaboration agents may enter into
downstream distribution arrangements
with downstream collaboration agents,
subject to the requirements specific to
each type of arrangement. Our final
policies also include modifications to
specify individually based on their
enrollment in Medicare the specific
providers and suppliers of outpatient
therapy services that may be EPM
collaborators. We also make
modifications to clarify that groups of
nonphysician practitioners and groups
of therapists (physical therapy,
occupational therapy, and speechlanguage pathology) enrolled in
Medicare may be EPM collaborators and
may enter into distribution
arrangements or downstream
distribution arrangements under the
EPM that are similar to those we are
finalizing for PGPs and their members.
9. Data Sharing
Based on our experience with various
Medicare programs and models,
including the BPCI initiative, the CJR
model, the Shared Savings Program, and
the Pioneer ACO model, we believe that
providing certain beneficiary claims
data to model participants will be
essential to their success. We proposed
to share data with participants upon
request throughout the performance
period of the models to the extent
permitted by the Health Insurance
Portability and Accountability Act of
1996 (HIPAA) Privacy Rule and other
applicable law. We proposed to share
upon request both raw claims-level data
and claims summary data with
participants. This approach would
allow participants without prior
experience analyzing claims to use
summary data for analysis of care and
spending patterns, while allowing those
participants who prefer raw claims-level
data the opportunity to analyze claims.
We proposed to provide participants
with up to 3 years of retrospective
claims data upon request that will be
used to develop their quality-adjusted
target price. In accordance with the
HIPAA Privacy Rule, we will limit the
content of this data to the minimum
data necessary for the participant to
conduct quality assessment and
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improvement activities and effectively
coordinate care.
10. Program Waivers
Section 1115A of the Act authorizes
the Secretary to waive Medicare
program requirements as necessary to
implement provisions for testing
models. Under the CJR model, CMS
waived certain program rules regarding
the direct supervision requirement for
certain post-discharge home visits,
telehealth services, and the skilled
nursing facility (SNF) 3-day rule. CMS
finalized these waivers to offer
providers and suppliers more flexibility
so that they may increase coordination
of care and management of beneficiaries
in model episodes. Adopting the CJR
waivers for the proposed EPMs required
further examination to determine if such
adoption would increase financial
vulnerability to the Medicare program
or would create inappropriate
incentives to reduce the quality of
beneficiary care. As discussed in section
III.J. of this final rule, we will do the
following:
• Adopt waivers of the telehealth
originating site and geographic site
requirement and to allow in-home
telehealth visits for all three proposed
EPMs, as well as the general waiver to
allow post-discharge nursing visits in
the home;
• Provide model-specific limits to the
number of post-discharge nursing visits
and make model-specific decisions
about offering the SNF 3-day stay
waiver; and
• Adopt a waiver for furnishing
cardiac and intensive cardiac
rehabilitation services to allow a Nurse
Practitioner, Clinical Nurse Specialist,
or Physician Assistant, in addition to a
physician, to perform specific physician
functions.
C. Summary of Economic Effects
As shown in our impact analysis, we
expect the EPMs to result in savings to
Medicare of $159 million over the 5
performance years of the models. We
note that a composite quality score will
be calculated for each hospital in order
to determine eligibility for a
reconciliation payment and whether the
hospital qualifies for quality incentive
payments that will reduce the effective
discount percentage experience by the
hospital at reconciliation for a given
performance year. More specifically, in
performance year 1 of the models, we
estimate a Medicare cost of
approximately $10 million, as hospitals
will not be subject to downside risk in
the first performance year of the models.
In performance year 2 of the models, we
estimate a Medicare cost of
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195
approximately $25 million, as some
hospitals will voluntarily assume
downside risk in the second
performance year of the models and
some hospitals will receive payments
made by CMS. As we introduce
downside risk beginning in performance
year 3 of the models, we estimate
Medicare savings of approximately $34
million. In performance years 4 and 5 of
the models, we will move from target
episode pricing that is based on a
hospital’s experience to target pricing
based on regional experience, and we
estimate Medicare savings of $49
million and $112 million, respectively.
As a result, we estimate the net
savings to Medicare to be $159 million
over the 5 performance years of the
models. We anticipate there will be a
broader focus on care coordination and
quality improvement for EPMs among
hospitals and other providers and
suppliers within the Medicare program
that will lead to both increased
efficiency in the provision of care and
improved quality of the care provided to
beneficiaries.
Additionally, the CR incentive model
estimates that the impact on the
Medicare program may range from up to
$29 million of additional spending to
$32 million of savings between 2017
and 2024, depending on the change in
utilization of CR/ICR services based on
the proposed incentive structure.
Finally, the change in the estimated
net financial impact to the Medicare
program from the CJR model
modifications in this final rule is $22
million in spending, and the updated
assumptions regarding the number of
hospitals that will report quality data
result in an increase of $4 million in
spending. The total estimated net
financial impact to the Medicare
program from both the modifications in
the final rule and revised assumptions
are $26 million in spending. We note
that under section 1115A(b)(3)(B) of the
Act, the Secretary is required to
terminate or modify a model unless
certain findings can be made with
respect to savings and quality after the
model has begun. If during the course of
testing a model it is determined that
termination or modification is
necessary, such actions will be
undertaken through rulemaking.
II. Background
This final rule finalizes the
implementation of three new EPMs and
a CR incentive payment model under
the authority of section 1115A of the
Act. Under the AMI, CABG, and SHFFT
EPMs, acute care hospitals in certain
selected geographic areas will be
financially accountable for quality
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performance and spending for
applicable episodes of care. We
proposed to retrospectively apply
through a reconciliation process the
episode payment methodology;
hospitals and other providers and
suppliers would continue to submit
claims and receive payment via the
usual Medicare FFS payment systems
throughout the proposed EPMs’
performance years. Critical Access
Hospitals (CAHs) acting as EPM
collaborators would continue to receive
payment via the usual cost-based
reimbursement system. Hospitals
participating in the proposed EPMs
would receive target prices, which
reflect expected spending for care
during an episode as well as a discount
to reflect savings to Medicare, on a
prospective basis, prior to the beginning
of a performance year. All related care
covered under Medicare Parts A and B
and furnished within 90 days after the
date of hospital discharge from the
anchor hospitalization which initiated
the applicable EPM episode would be
included in the episode of care. We
proposed the CR incentive payment
model to test the effects on quality of
care and Medicare expenditures of
providing explicit financial incentives
to a subset of EPM participants and
selected hospitals that are not AMI or
CABG model participants for
beneficiaries hospitalized for treatment
of AMI or CABG to encourage care
coordination and greater utilization of
medically necessary CR/ICR services for
90 days post-hospital discharge where
the beneficiary’s overall care is paid
under either an EPM or the Medicare
FFS program. We believe the models
will further our goals of improving the
efficiency and quality of care for
Medicare beneficiaries for these medical
conditions and procedures.
III. Episode Payment Models
A. Selection of Episodes, Advanced
Alternative Payment Model
Considerations, and Future Directions
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1. Selection of Episodes for Episode
Payment Models in This Rulemaking
a. Overview
We have been engaged since 2013 in
testing various approaches to episode
payment for Medicare FFS beneficiaries
for 48 clinical episodes in the BPCI
initiative. As of October 1, 2016, the
BPCI initiative has 1,403 participants in
the risk-bearing phase, comprised of 297
Awardees and 1,107 Episode Initiators.
The breakdown of BPCI participants by
provider type is as follows: Acute care
hospitals (354); skilled nursing facilities
(642); physician group practices (257);
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home health agencies (81); and inpatient
rehabilitation facilities (9).11 In BPCI
Models 2 and 3, there is participation
across all 48 clinical episodes, and in
Model 4 there is participation in 19
clinical episodes.
The 10 clinical episodes with the
most participation are: Major joint
replacement of the lower extremity;
simple pneumonia and respiratory
infections; congestive heart failure;
chronic obstructive pulmonary disease;
bronchitis; asthma; hip and femur
procedures except major joint; sepsis;
urinary tract infection; acute myocardial
infarction (medical management only);
medical non-infectious orthopedic; and
other respiratory.12
In November 2015, CMS released the
Final Rule for the Comprehensive Care
for Joint Replacement (CJR) model (80
FR 73274 through 73554), the first test
of episode-based payment model for
Medicare FFS beneficiaries in which
providers are required to participate.
The CJR model, which began on April
1, 2016, focuses on the episode-of-care
for lower-extremity joint replacement
(LEJR) procedures. As discussed in the
CJR Final Rule (80 FR 73277), LEJR
episodes were chosen for the CJR model
because they represent one of the most
common high-expenditure, highutilization procedures furnished to
Medicare beneficiaries and have
significant variation in episode
spending. We believe this high volume,
coupled with substantial variation in
utilization and spending across
individual providers and geographic
regions, created a significant
opportunity to test whether an episode
payment model focused on a defined set
of procedures could improve the quality
and coordination of care, as well as
result in savings to Medicare. Notably,
both the BPCI initiative and the CJR
model are focused on care that is related
to an inpatient hospitalization, with CJR
model and BPCI Model 2 episodes
beginning with an inpatient
hospitalization (anchor hospitalization)
and extending up to 90 days posthospital discharge.
In the proposed rule (81 FR 50805),
we proposed three new EPMs that, like
the CJR model, would require provider
participation in selected geographic
areas. Episodes in the new EPMs would
begin with admissions for
hospitalizations in IPPS hospitals, and
would extend 90 days post-hospital
discharge. The episodes included in
these three proposed EPMs would be
11 https://innovation.cms.gov/initiatives/bundledpayments/.
12 https://innovation.cms.gov/Files/x/
bpcianalyticfile.xlsx.
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AMI, CABG, and SHFFT excluding
lower extremity joint replacement. The
proposed AMI model included
beneficiaries discharged under AMI
MS–DRGs (280–282), representing IPPS
admissions for AMI that are treated with
medical management. The proposed
AMI model also included beneficiaries
discharged under PCI MS–DRGs (246–
251) with AMI International
Classification of Disease, Tenth Edition,
Clinical Modification (ICD–10–CM)
diagnosis codes for initial AMI
diagnoses in the principal or secondary
diagnosis code positions, representing
IPPS admissions for AMI that are treated
with PCIs. The proposed CABG model
included beneficiaries discharged under
CABG MS–DRGs (231–236),
representing IPPS admissions for this
coronary revascularization procedure
irrespective of AMI diagnosis. The
proposed SHFFT model included
beneficiaries discharged under hip and
femur procedures except major joint
replacement MS–DRGs (480–482),
representing IPPS admissions for hipfixation procedures in the setting of hip
fractures.
Similar to the selection of LEJR
episodes for the CJR model (80 FR
73277), we selected the AMI, CABG,
and SHFFT episodes because they
represent high-expenditure, highvolume episodes-of-care experienced by
Medicare beneficiaries. Based on
analysis of historical episodes beginning
in CY 2012–2014, the average annual
number of episodes that began with
IPPS hospitalizations and extended 90
days post-hospital discharge, and
therefore would have been included in
the proposed models, is approximately
168,000 for AMI; 48,000 for CABG; and
109,000 for SHFFT.13 The total annual
Medicare spending for these historical
episodes was approximately $4.1
billion, $2.3 billion, and $4.7 billion,
respectively.14 Each of the episodes
provides different opportunities in an
EPM to improve the coordination and
quality of care, as well as efficiency of
care during the episode, based on
varying current patterns of utilization
and Medicare spending.
However, in contrast to LEJR episodes
in the CJR model, which are
predominantly elective and during
which hospital readmissions are rare
13 Episodes for AMI, CABG, and SHFFT
beneficiaries initiated by all U.S. IPPS hospitals not
in Maryland and constructed using standardized
Medicare FFS Parts A and B claims, as proposed in
the proposed rule that began in CY 2012–2014.
14 Episodes for AMI, CABG, and SHFFT
beneficiaries initiated by all U.S. IPPS hospitals not
in Maryland and constructed using standardized
Medicare FFS Parts A and B claims, as proposed in
the proposed rule that began in CY 2012–2014.
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and substantial post-acute care provider
utilization is common, the proposed
AMI, CABG, and SHFFT episodes have
very different current patterns of care.
Beneficiaries in these episodes
commonly have chronic conditions that
contribute to the initiation of the
episodes and need both planned and
unplanned care throughout the EPM
episode following discharge from the
initial hospitalization that begins the
episode. Both AMI and CABG episodes
primarily include beneficiaries with
cardiovascular disease, a chronic
condition which likely contributed to
the acute events or procedures that
initiate the episodes. About half the
average AMI model historical episode
spending was for the initial
hospitalization, with the majority of
spending following discharge from the
initial hospitalization due to hospital
readmissions, while there was relatively
less spending on SNF services, Part B
professional services, and hospital
outpatient services. In CABG model
historical episodes, about three-quarters
of episode spending was for the initial
hospitalization, with the remaining
episode spending relatively evenly
divided between Part B professional
services and hospital readmissions, and
a lesser percentage on SNF services.
Similar to AMI episodes, post-acute care
provider use was relatively uncommon
in CABG model historical episodes,
while hospital readmissions during
CABG model historical episodes were
relatively common. SHFFT model
historical episodes also were
accompanied by substantial spending
for hospital readmissions, and postacute care provider use in these
episodes also was high.15 The number of
affected beneficiaries and potential
impact of the models on quality and
Medicare spending present an important
opportunity to further the
Administration’s goal of shifting health
care payments to support the quality of
care over the quantity of services by
promoting better coordination among
health care providers and suppliers and
greater efficiency in the care of
beneficiaries in these models, while
reducing Medicare expenditures.16 Payfor-performance episode payment
models, such as the three EPMs
proposed in the proposed rulemaking,
15 Episodes for AMI, CABG, and SHFFT
beneficiaries initiated by all U.S. IPPS hospitals not
in Maryland and constructed using standardized
Medicare FFS Parts A and B claims, as proposed in
the proposed rule that end in CY 2014.
16 Sylvia Mathews Burwell, HHS Secretary,
Progress Towards Achieving Better Care, Smarter
Spending, Healthier People, https://www.hhs.gov/
blog/2015/01/26/progress-towards-better-caresmarter-spending-healthier-people.html (January
26, 2015).
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financially incentivize improved quality
of care and reduced cost by aligning the
financial incentives of all providers and
suppliers caring for model beneficiaries
with these goals. This alignment leads
to a heightened focus on care
coordination and management
throughout the episode that prioritizes
the provision of those items and
services which improve beneficiary
outcomes and experience at the lowest
cost.
We selected all of the proposed EPM
episodes based on their clinical
homogeneity, site-of-service, and MS–
DRG assignment considerations. We
anticipated these proposed new EPMs,
like the CJR model, would benefit
Medicare beneficiaries by improving the
coordination and transition of care
among various care settings to facilitate
beneficiaries’ return to their
communities as their recoveries
progress, improving the coordination of
items and services paid through
Medicare FFS, encouraging provider
investment in infrastructure and
redesigned care processes for higher
quality and more efficient service
delivery, and incentivizing higher value
care across the inpatient and post-acute
care spectrum spanning the episode-ofcare (80 FR 73276). However, improving
value in the EPMs through these means
requires a cohort of beneficiaries with
similar clinical features such that
coordination and care redesign efforts
can be targeted. Therefore, we proposed
EPM episodes built on common
pathologic and treatment processes; that
is, beneficiaries included in both the
AMI and CABG models have
cardiovascular pathologies that drive
their clinical courses during the
episodes, and SHFFT model
beneficiaries all share similar diagnoses
of hip fracture and treatment with hip
fixation that drive their clinical courses
during their respective episodes.
The following is a summary of the
comments received on our overall
proposal of three new EPMs in which
participation would be required and our
responses.
Comment: Many commenters
commended CMS for its continued
commitment to testing episode-based
payments demonstrated through the
proposal to implement three new EPMs.
MedPAC identified conditions with
high post-acute care use as an
appropriate setting to test bundled
payments that would offer ample
opportunities to improve care and lower
spending. MedPAC also suggested that
another consideration for bundled
payments is whether the condition has
a relatively uniform clinical pathway
that simplifies the rules defining and
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197
pricing the bundle. In addition,
MedPAC emphasized that conditions
that lend themselves to patient selection
should be avoided in bundled payment
models, at least in the near term, to limit
the undesirable provider responses to
financial incentives that may occur.
Other commenters expressed
appreciation for the opportunity to test
innovative care models under the
Innovation Center authority. They stated
that EPMs could hold significant
promise for furthering the Triple Aim
goals of providing high quality care at
lower cost to produce better outcomes
and advance population health.
However, some commenters
expressed concern about the pace of
changes proposed by CMS through its
models and the associated expectation
and burden that rapid changes in the
delivery system and related payment
structure place on hospitals and
providers. Some commenters noted that
CMS has been swift in releasing rules
aimed at improving the quality of care
delivered, reducing the cost of care, and
coordinating patient care across
multiple settings. The commenters
pointed out the large volume of
significant requirements announced by
CMS over the last 2 years, including
MACRA, the CJR model, and the
proposed Part B drug payment model, as
well as alternative payment models and
programs, including the Shared Savings
Program, Next Generation ACOs, BPCI
initiative, and OCM, coupled with state
level initiatives. The commenters
believe the breadth and amount of new
activities make it difficult to understand
how the various models and program
will interact with each other and impact
individual delivery systems. While
directed toward laudable goals, the
commenters encouraged CMS to be
vigilant in its review and analysis of
these models and programs and to
consider the impact and burden on
hospitals as it continues to release
models and programs impacting the
hospital community. The commenters
believe it is in everyone’s best interest
that these models are successful, yet the
pace and complexity of implementation
likely will be a critical factor in the
achievement of these goals. Therefore,
they encouraged CMS to slow the pace
of EPM implementation to establish
‘‘proof of concept’’ through the CJR
model and BPCI Model 2 results before
implementing new EPMs where
participation is required. Without
adequate time to understand the
appropriate role these payment
innovations play in transforming care
delivery and build upon lessons learned
and best practices, the commenters
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concluded that both CMS and the
provider community would miss an
important opportunity to create
programs that will advance patient care
and successfully transform systems of
care.
The commenters recommended that
CMS establish a solid framework upon
which to build payment initiatives and
transform care. Before finalizing any
more bundled payment initiatives, some
commenters believe that CMS should
articulate its vision and set a clear path
for innovative payment models,
establishing a consistent, predictable
and transparent framework, giving
providers the necessary tools to succeed
in creating a higher-quality, more
efficient health care system. The
commenters suggested that the
framework should include tools such as
incorporating a predictable pricing
trend factor so that participants can
make decisions about investing in care
design in the context of stable future
prices; providing necessary risk
adjustment methodologies; releasing
consistent quality measures and
reporting requirements and reliable
target pricing; and holding fast to the
principle of attributing no more than
one patient to one bundled payment
initiative at a time.
A few commenters expressed
concerns about CMS’ proposal to test
three new bundled payment models.
The commenters contended that the
proposed EPMs would make treatment
more difficult to access for high need
patients; discourage truly innovative
approaches to managing underlying
health problems; encourage unnecessary
surgeries; encourage further
consolidation in the health care
industry; provide fewer choices for
consumers; and result in higher prices
for private payers. One commenter
requested that CMS present a much
more comprehensive analytic work to
understand the prevalence and needs of
the beneficiaries who have serious
illness or disabilities prior to and during
the episode and who therefore require
substantial attention to the elements of
comprehensive care and quality
measurement that are tailored for these
beneficiaries prior to implementing the
EPMs. Several commenters
recommended CMS not to limit
alternative payment models to episode
payment approaches because for many
types of patients, the biggest
opportunity for improving quality and
achieving savings is avoiding
unnecessary episodes and events, and
not simply paying differently for
episodes and events when they occur.
Some commenters strongly cautioned
against EPMs that may subordinate
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future provider-led models. Other
commenters recommended CMS to
develop and implement payment reform
models that incorporate populationbased models, rather than look
exclusively at episode payment models
which can hamper growth of
population-based models by limiting
their financial opportunity.
Response: We appreciate the support
of many commenters for CMS’
continued development of new episode
payment models and agree with these
commenters that episode payment
models provide substantial opportunity
to improve the quality and efficiency of
care for specific clinical conditions. We
also agree that bundled payment models
are just one strategy to incentivize the
health care system moving toward the
provision of more accountable,
coordinated, high-value care, while
provider-led and population-based
models, as well as other types of
payment reform models, play
complementary roles. The Innovation
Center is continuing to develop,
implement, and evaluate a variety of
different types of models that test
different approaches to achieving better
care, lower costs, and improved health.
The three EPMs are part of that portfolio
of models. Issues of concern raised by
some of the commenters about the
proposed EPMs, including the
implementation timeline, are discussed
in the specific sections of this final rule
that address the relevant policies.
b. SHFFT Model
The SHFFT model was selected to
complement the CJR model. We
proposed to test the SHFFT model in
most of the same hospitals participating
in the CJR model as discussed in section
III.B.4. of the proposed rule (81 FR
50794), so that all surgical treatment
options for Medicare beneficiaries with
hip fracture (hip arthroplasty and
fixation) would be included in episode
payment models. Hip fracture is a
serious and sometimes catastrophic
event for Medicare beneficiaries. In
2010, 258,000 people aged 65 and older
were admitted to the hospital for hip
fracture, with an estimated $20 billion
in lifetime cost for all hip fractures in
the United States in a single year.17 In
2013, fracture of the neck of the femur
(the most common location for hip
fracture) was the eighth most common
principal discharge diagnosis for
hospitalized Medicare FFS
beneficiaries, constituting 2.7 percent of
17 Smith et al. Increase in Disability Prevalence
Before Hip Fracture. J Am Geriatr Soc. 2015
Oct;63(10):2029–35.
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discharges.18 Mortality associated with
hip fracture is 5–10 percent after 1
month and approximately 33 percent at
1 year.19 Hip arthroplasty and hip
fixation, or ‘‘hip pinning,’’ represent the
two broad surgical options for treating
hip fractures.20 The CJR episodes begin
with admission to acute care hospitals
for LEJR procedures assigned to MS–
DRG 469 (Major joint replacement or
reattachment of lower extremity with
major complications or comorbidities)
or MS–DRG 470 (Major joint
replacement or reattachment of lower
extremity without major complications
or comorbidities) upon beneficiary
discharge and paid under the IPPS,
including total and partial hip
replacement in the setting of hip
fracture (80 FR 73280). Therefore, the
SHFFT model, which would test an
additional episode payment for hip
fixation, provides an opportunity to
complete the transition to episode
payment for the surgical treatment and
recovery of the significant clinical
condition of hip fracture.
The following is a summary of the
comments received and our responses.
Comment: Some commenters
expressed support for the SHFFT model,
which CMS proposed to implement in
the same MSAs as the CJR model, which
was implemented beginning in April
2016, and in particular expressed
appreciation for the design consistency
proposed for the SHFFT model with the
CJR model and the two proposed
cardiac EPMs. Analysis by MedPAC
found that most SHFFT episodes
include at least some post-acute care
services use and that the spending on
post-acute care services comprises a
sizable share of total episode spending,
about one-third. MedPAC concluded
that SHFFT was a good candidate for
bundled payment. MedPAC also
reasoned that the SHFFT episode would
give hospitals already participating in
the CJR model the experience of
managing care for hip and femur
fracture cases that typically present
emergently, rather than as the planned,
elective surgery that is most common for
lower extremity joint replacement.
MedPAC, which recommended
proceeding only with the SHFFT model
in the context of CMS’ proposal for
three new EPMs, maintained that this
18 Krumholz HM, Nuti SV, Downing NS,
Normand ST, Wang Y. Mortality, Hospitalizations,
and Expenditures for the Medicare Population Aged
65 Years or Older, 1999–2013. JAMA. 2015;
314(4):355–365.
19 Parker et al. Hip Fracture. BMJ. 2006 Jul
1;333(7557):27–30.
20 American Academy of Orthopaedic Surgeons,
OrthoInfo: Hip Fractures, https://orthoinfo.aaos.org
(April 12, 2016).
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would simplify the set of models that
providers are adapting to and simplify
the administrative requirements for
CMS because CMS would not need to
select new markets for testing the
cardiac EPMs. Other commenters found
it positive that CMS noted that there are
differences between CJR and SHFFT
beneficiaries, notably the latter being
more likely to have multiple chronic
conditions and frailty.
However, many commenters opposed
CMS’ proposal for the SHFFT model,
encouraging CMS either to abandon the
model altogether or to substantially
delay implementation pending
additional CJR model experience and
evaluation results from BPCI Model 2
regarding SHFFT episodes. These
commenters recommended that CMS
proceed at a more deliberate pace and
simplify the proposed rule for the three
different EPMs by eliminating the
SHFFT model because CMS is already
testing an episode payment model that
requires participation through the CJR
model. Therefore, they believe that CMS
should test only a cardiac bundled
payment model in a different clinical
area as a next step in required bundled
payment models. The commenters
stated that the SHFFT model would be
overly burdensome to providers who
just began participating in the CJR
model in April 2016 and had
insufficient financial safeguards for
hospitals and quality safeguards for
beneficiaries, including no quality
measures specific to SHFFT model
beneficiaries, to substantially improve
beneficiaries’ care experience through
successful surgery and recovery. Several
commenters stated that the proposed
SHFFT model was not a true valuebased payment model because the
clinical outcome quality measures that
were proposed did not capture hip
fracture patients. Given CMS’ proposal
to implement the SHFFT model in the
same MSAs as the CJR model, the
commenters stated that due to limited
implementation time of the CJR model,
it would be inappropriate to add the
very sick and frail SHFFT cohort to the
relatively stable CJR model cohort
without substantial investigation as to
how to proceed with adequate
monitoring against harm. They also
recommended not proceeding without
risk adjustment to account for variable
costs experienced by hospitals treating
different populations of SHFFT model
beneficiaries. Several commenters
claimed that because SHFFT
beneficiaries would receive emergency
care, care coordination would be less
predictable and no planning would be
possible prior to hospital admission, so
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the burden on potential family
caregivers would be escalated in
comparison to the CJR model if there
was only a short hospital and/or SNF
stay. The commenters stated that in
comparison with beneficiaries
undergoing elective LEJR, those with
hip fracture require more time and
resources from providers to optimize
planning and rehabilitation and,
therefore, limited efficiencies would be
possible for SHFFT model beneficiaries
without significant risk to the quality of
care.
Response: We appreciate the
perspective of some commenters that
the opportunities for care redesign to
improve quality and reduce spending
are substantial for Medicare
beneficiaries undergoing SHFFT
procedures. We agree with those
commenters about the potential value of
the SHFFT model for beneficiaries,
providers, and CMS to complement the
CJR model by testing bundled payment
for beneficiaries requiring emergency
lower extremity joint surgery compared
to testing episode payment for lower
extremity surgeries that are mainly
elective. We also acknowledge the
concerns of the commenters around
various proposed design elements of the
SHFFT model, specifically the lack of
risk adjustment to protect SHFFT model
participants from undue financial risk
for complex beneficiaries and the lack of
quality measures that are specific to
SHFFT beneficiaries in the pay-forperformance methodology to reward
SHFFT model participants that improve
quality for these beneficiaries and
protect SHFFT beneficiaries from harm
due to the model. We refer to sections
III.D.4.b.(2) and III.E.2.d. of this final
rule for further discussion of the
comments on these issues and our
responses.
We also appreciate the concerns of
commenters regarding the proposed
implementation of the SHFFT model in
the same MSAs as CJR participant
hospitals, and the additional
responsibilities this model would place
on participants early in their CJR model
implementation experience. However,
we continue to believe that there are
efficiencies in care redesign that can be
achieved by testing the models
concurrently at the same hospitals. We
note that those commenters opposing
CMS’ proposal to implement the SHFFT
model did not dispute the care redesign
opportunities identified by CMS for
such a model. We refer to section
III.D.2.a. of this final rule for a
discussion of the comments on the
proposed implementation timeline for
the SHFFT model and our responses.
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199
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal to implement the
SHFFT model, with modifications to
specific policies as described
throughout this final rule. We refer to
section III.D.2.a. of this final rule for the
implementation timeline that applies to
the SHFFT model.
c. AMI and CABG Models
The AMI and CABG models, which
we proposed to be tested at a single set
of hospitals as discussed in section
III.B.5. of the proposed rule (81 FR
50794), were selected to include all
beneficiaries who have an AMI treated
medically or with revascularization
with PCI, as well as all beneficiaries
who undergo CABG (whether performed
during the care of an AMI or performed
electively for stable ischemic heart
disease or other indication). Both
cardiac models represent clinical
conditions that result in a significant
burden of morbidity and expenditures
in the Medicare population. CABG
typically is the preferred
revascularization modality for patients
with ST (the part of an
electrocardiogram between the QRS
complex and the T wave) elevation AMI
where the coronary anatomy is not
amenable to PCI or there is a mechanical
complication (for example, ventricular
septal defect, rupture of the free wall of
the ventricle, or papillary-muscle
rupture with severe mitral
regurgitation); for patients with CAD
other than ST elevation AMI where
there is left main coronary artery disease
or multivessel disease with complex
lesions; and for patients with clinically
significant CAD in at least one vessel
and refractory symptoms despite
medical therapy and PCI.21 Despite the
greater acute morbidity related to major
cardiothoracic surgery, CABG is
associated with lower longer-term rates
of major adverse cardiac and
cerebrovascular events in comparison to
PCI for certain groups of patients.22
Moreover, a recent study found that in
a group of patients with ischemic
cardiomyopathy, the rates of death from
any cause, death from cardiovascular
causes, and death from any cause or
hospitalization for cardiovascular
causes were significantly lower over 10
years among patients who underwent
CABG in addition to receiving medical
21 Alexander JH, Smith PK. Coronary-Artery
Bypass Grafting. N Engl J Med. 2016 May
19;374(2):1954–1964.
22 Sepehripour et al. Developments in surgical
revascularization to achieve improved morbidity
and mortality. Expert Rev Cardiovasc Ther. 2016
Mar;14(3):367–79. doi: 10.1586/
14779072.2016.1123619. Epub 2015 Dec 17.
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therapy than among those who received
medical therapy alone.23 While about 30
percent of CABGs are performed during
the care of AMIs, we proposed to
include these particular AMI
beneficiaries generally in the same
episode as CABG for other indications,
rather than in the AMI episode, since
we anticipate hospitals will seek to
improve the quality and efficiency of
care for that surgical intervention,
regardless of indication.24
We proposed AMI as the episode for
an EPM because we recognized it as a
significant clinical condition for which
evidence-based clinical guidelines are
available for the most common AMI
scenarios that begin with a beneficiary’s
presentation for urgent care, most
commonly to a hospital emergency
department. The hospital phase
involves medical management for all
patients, as well as potential
revascularization, most commonly with
PCI. Secondary prevention and plans for
long-term management begin early
during the hospitalization, extend
following hospital discharge, and are
addressed in clinical guidelines.25 26 The
AMI model is the first Innovation Center
episode payment model that includes
substantially different clinical care
pathways (medical management and
PCI) for a single clinical condition in
one episode in a model and, as such,
represents an important next step in
testing episode payment models for
clinical conditions which involve a
variety of different approaches to
treatment and management.
The American Heart Association
estimates that every 42 seconds,
someone in the United States has a
23 Velazquez et al. Coronary Artery Bypass
Surgery in Patients with Ischemic Cardiomyopathy.
N Engl J Med. 2016 Apr 3.
24 Episodes for CABG beneficiaries initiated by all
U.S. IPPS hospitals not in Maryland and
constructed using standardized Medicare FFS Parts
A and B claims, as proposed in the proposed rule
that end in CY 2014.
25 Amsterdam EA, Wenger NK, Brindis RG, Casey
DE Jr, Ganiats TG, Holmes DR Jr, Jaffe AS, Jneid H,
Kelly RF, Kontos MC, Levine GN, Liebson PR,
Mukherjee D, Peterson ED, Sabatine MS, Smalling
RW, Zieman SJ. 2014 ACC/AHA guideline for the
management of patients with non–ST-elevation
acute coronary syndromes: a report of the American
College of Cardiology/American Heart Association
Task Force on Practice Guidelines. Circulation.
2014;130:e344–e426.
26 O’Gara PT, Kushner FG, Ascheim DD, Casey DE
Jr, Chung MK, de Lemos JA, Ettinger SM, Fang JC,
Fesmire FM, Franklin BA, Granger CB, Krumholz
HM, Linderbaum JA, Morrow DA, Newby LK,
Ornato JP,Ou N, Radford MJ, Tamis-Holland JE,
Tommaso CL, Tracy CM, Woo YJ, Zhao DX. 2013
ACCF/AHA guideline for the management of STelevation myocardial infarction: a report of the
American College of Cardiology Foundation/
American Heart Association Task Force on Practice
Guidelines. Circulation. 2013;127:
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myocardial infarction.27 AMI remains
one of the most common hospital
diagnoses among Medicare FFS
beneficiaries, and almost 20 percent of
beneficiaries discharged for AMI are
readmitted within 30 days of hospital
discharge.28 29 In 2013, AMI was the
sixth most common principal discharge
diagnosis for hospitalized Medicare FFS
beneficiaries, constituting 2.9 percent of
discharges.30 Of the approximately
395,000 Medicare FFS beneficiaries
with short-term acute care hospital
discharges (excluding Maryland) for
AMI in FY 2014, 60 percent were
discharged under MS–DRGs proposed to
be included in the AMI model,
specifically 33 percent under AMI MS–
DRGs and 25 percent under PCI MS–
DRGs.31 An additional 3 percent of
beneficiaries were in MS–DRGs for
death from AMI in the hospital.
Although 5 percent of beneficiaries with
hospital discharges for AMI were
discharged under CABG MS–DRGs, we
note that because both PCI and
fibrinolysis can restore blood flow in an
acutely occluded coronary artery more
quickly than CABG, these interventions
are currently preferred to CABG in most
cases of AMI. Furthermore, over recent
years cardiovascular clinical practice
patterns have generally shifted away
from surgical treatment of coronary
artery occlusion toward percutaneous,
catheter-based interventions.32 The
remaining 34 percent of beneficiaries
27 Mozaffarian D, Benjamin EJ, Go AS, Arnett DK,
Blaha MJ, Cushman M, Das SR, de Ferranti S,
´
Despres J–P, Fullerton HJ, Howard VJ, Huffman MD,
´
Isasi CR, Jimenez MC, Judd SE, Kissela BM,
Lichtman JH, Lisabeth LD, Liu S, Mackey RH,
Magid DJ, McGuire DK, Mohler ER III, Moy CS,
Muntner P, Mussolino ME, Nasir K, Neumar RW,
Nichol G, Palaniappan L, Pandey DK, Reeves MJ,
Rodriguez CJ, Rosamond W, Sorlie PD, Stein J,
Towfighi A, Turan TN, Virani SS, Woo D, Yeh RW,
Turner MB; on behalf of the American Heart
Association Statistics Committee and Stroke
Statistics Subcommittee. Heart disease and stroke
statistics—2016 update: a report from the American
Heart Association. Circulation. 2016 Jan 26;
133(4):447–54.
28 Krumholz HM, Nuti SV, Downing NS,
Normand ST, Wang Y. Mortality, Hospitalizations,
and Expenditures for the Medicare Population Aged
65 Years or Older, 1999–2013. JAMA. 2015;
314(4):355–365.
29 Dharmarajan K, Hsieh AF, Lin Z, et al.
Diagnoses and Timing of 30-Day Readmissions
After Hospitalization for Heart Failure, Acute
Myocardial Infarction, or Pneumonia. JAMA. 2013;
309(4):355–363.
30 Krumholz HM, Nuti SV, Downing NS,
Normand ST, Wang Y. Mortality, Hospitalizations,
and Expenditures for the Medicare Population Aged
65 Years or Older, 1999–2013. JAMA. 2015;
314(4):355–365.
31 Inpatient claims from all U.S. IPPS hospitals
not in Maryland were derived from the October
2013—September 2014 Inpatient Claims File
located in the Chronic Conditions Warehouse.
32 Epstein et al. JAMA. 2011 May 4; 305(17):1769–
1776.
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with AMI diagnoses were distributed
across a heterogeneous group of over
300 other MS–DRGs, such as
septicemia, respiratory system diagnosis
with ventilator support, and major
cardiovascular procedures. For this
latter group of beneficiaries, the AMI
diagnosis appeared in a secondary
position on the hospital claim in more
than 90 percent of the cases, therefore
most likely representing circumstances
where the beneficiary while
hospitalized for another clinical
condition experienced an AMI during
the hospital stay. By focusing the AMI
model on AMIs treated medically or
with revascularization with PCI, we
proposed to test a condition-specific
EPM that was discretely defined and
includes a significant majority of
beneficiaries with AMI in the AMI
model. In CYs 2012–2014, the average
Medicare spending for an AMI episode
that extends 90 days post-hospital
discharge was approximately $24,200.33
From the AMI model, we expect to
better understand the impact that such
an EPM can have on efficiency and
quality of care for beneficiaries across
the entire spectrum of AMI care,
including diagnosis, treatment, and
recovery, as well as short-term
secondary prevention.
Beneficiaries in the AMI and CABG
models will all have CAD. In 2010 in
the U.S., the prevalence of CAD in the
population 65 years and older was about
20 percent.34 Patients with CAD also
often experience other significant health
conditions, including diabetes. To
improve care for patients with CAD,
most approaches in the private and
public sectors focus on improving the
efficiency and quality of care around
procedures such as PCI and CABG. The
BPCI models are an example of such an
approach. As discussed previously in
this section, our proposal for the AMI
model extends beyond a procedurebased EPM to include beneficiaries
hospitalized for medical management or
PCI for AMI in a single EPM, and we
proposed to test the CABG model,
which also would include beneficiaries
with AMI, at the same participant
hospitals. We believe that
hospitalization for AMI, whether
accompanied solely by medical
management or including
revascularization during the initial
hospitalization or in a planned CABG
33 Episodes for beneficiaries with AMI diagnosis
initiated by all U.S. IPPS hospitals not in Maryland
and constructed using standardized Medicare FFS
Parts A and B claims, as proposed in the proposed
rule that began in CYs 2012–2014.
34 National Center for Chronic Disease Prevention
and Health Promotion, Division for Heart Disease
and Stroke Prevention, August 10, 2015.
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readmission, is a sentinel event
indicating the need for an increased
focus on condition-specific
management, as well as on care
coordination and active management to
prevent future acute events, both during
the AMI and CABG episodes and
beyond. We also believe that improving
the quality and efficiency of CAD care
over a long period of time is important
given the chronic nature of this
condition that has serious implications
for beneficiary health.
The AMI and CABG models provide
an opportunity for us to incentivize
CAD-specific care management and care
coordination for AMI and CABG model
beneficiaries that lays the groundwork
for longer-term improvements in quality
and efficiency of care for beneficiaries
with CAD. We note that the quality
measures proposed for use in the payfor-performance methodologies of the
AMI and CABG models do not currently
include longer-term outcomes or patient
experience outside of the AMI or CABG
episode itself, as discussed in sections
III.E.2.b. and c. of the proposed rule (81
FR 50794), although we were interested
in comments about potential future
measures that could incorporate longerterm outcomes. Moreover, as discussed
in section VI. of the proposed rule (81
FR 50794), we also proposed to test a
cardiac rehabilitation (CR)/intensive
cardiac rehabilitation (ICR) incentive
payment, hereinafter CR incentive
payment, in AMI and CABG model
participants located in some of the
MSAs selected for AMI and CABG
model participation, as well as in
hospitals located in some of the MSAs
that are not selected for AMI or CABG
model participation. We proposed to
evaluate the effects of the CR incentive
payment in the context of an episode
payment model and Medicare FFS on
utilization of CR/ICR, as well as shortterm (within the period of time
extending 90 days following hospital
discharge from an AMI or CABG
hospitalization) and longer-term
outcomes. We believe this test may
result in valuable findings about
effective strategies to increase
utilization of CR/ICR services that have
a strong evidence-base for their
effectiveness but a long history of
underutilization.
The following is a summary of the
comments received and our responses.
Comment: A number of commenters
expressed support for the proposed AMI
and CABG models, characterizing the
proposals as a good first step toward
achieving greater focus not only on
cardiac care quality improvement but
also care coordination for the anchor
admission through post-acute care
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management of patients and families.
Several commenters believe that CMS’
proposal to implement separate models
for beneficiaries undergoing treatment
for AMI versus CABG surgery was
sensible given the typical recovery
pathways experienced by beneficiaries.
One commenter noted that while the
majority of beneficiaries with AMI or
CABG have CAD, not all will have this
condition as CMS stated in the proposed
rule (81 FR 50807).
Several commenters commended
CMS for developing a clinically
appropriate definition for AMI because
AMI is a condition that can require a
range of treatments, including both
medical treatments and PCI. The
commenters observed that the
combination of AMI medical
management and PCI into a single AMI
episode is likely to present AMI model
participants with greater opportunity
than if the hospital managed just one of
the MS–DRG groupings. They stated
that the proposal to include both
medical and PCI MS–DRG groupings in
the AMI model would increase each
hospital’s AMI episode volume relative
to a single MS–DRG grouping, and
further noted that sufficient volume in
any bundled payment model is key to
ensuring that financial results are not
primarily driven by random variation.
Several commenters observed that the
proposed AMI model would be the first
Innovation Center bundled payment
model to combine medical and
procedural care in a single episode and
that the majority of beneficiaries in the
AMI model would be experiencing a
life-threatening emergency. These
commenters believe the proposed AMI
model has the potential for patient harm
and serious unintended consequences
and recommended CMS to maintain a
dialogue with practicing clinicians from
medical specialty and subspecialty
societies so that unintended
consequences are caught early. One
commenter recommended that CMS
refocus the proposed AMI model to be
treatment-based, separating
beneficiaries with AMI into two
different treatment-based EPMs based
on medical management or PCI. The
commenter contended that this
approach would be more
straightforward for model participants
and allow CMS to conduct longer-term
analyses of BPCI-like models in a more
representative cross-section of hospitals.
Other commenters recommended that
CMS pursue only the CABG model,
arguing that the proposed AMI model,
with complex, care pathway-dependent
prices and transfer pathways, would
influence attribution and result in
serious uncertainties for AMI model
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201
participants. One commenter reasoned
that isolated CABG procedures are
particularly well-positioned for a
bundled payment model that requires
participation because, despite the
availability of robust clinical guidelines,
variability in the costs and outcomes of
CABG persist. The commenter noted
that other entities, such as Arkansas and
Tennessee Medicaid, Washington
State’s Bree Collaborative, and
commercial payers, have seen the
potential to improve the cost and
quality of CABG through the
implementation of bundled payments.
Several commenters stated that initial
implementation of the CABG model
alone would allow CABG model
participants to focus efforts on a specific
population that includes the
opportunity to excel in the care of CAD
and gain some experience in the care of
emergent patients. This limited
implementation strategy would allow
model participants to start to develop
systems and models of care that address
the unique needs of these populations
in a value-driven equation. The
commenters added that as hospitals
work through implementation and gain
experience with the CABG model, CMS
could then phase in the inclusion of the
much more complicated AMI model,
which would introduce a myriad of
factors that would add to the complexity
of EPMs in which the hospital was a
participant.
Another commenter who did not
favor implementation of the proposed
AMI model reasoned that, in addition to
the built-in incentives of MS–DRGs that
currently reward hospitals and
physicians for complications that occur
during the beneficiary’s hospitalization
by providing a higher IPPS payment for
beneficiaries with complications, the
proposed AMI model lacked incentives
to manage beneficiaries to reduce CAD
complications such as AMI. Instead, the
commenter stated that the proposed
AMI model would incentivize admitting
patients who are marginally
symptomatic for AMI that is a
complication of CAD, contrary to the
overall goals of EPMs to lower the
incidence of complications. The
commenter cited a body of research that
has shown that optimal management of
CAD can significantly lower the
incidence of AMI. The commenter
recommended CMS to move toward
condition-specific episode payment
defined by diagnosis codes, and to halt
implementation of an event-based EPM
for AMI that is, in itself, a complication
from the lack of optimal management of
CAD. The commenter also stated that
CMS should implement site-agnostic
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PCI episodes so the incentives under the
model would be to provide care in the
place of service best suited for the
patient. Another commenter expressed
concerns about bundling AMI care, as it
encompasses a broad spectrum of many
different complex illnesses. Several
commenters observed that while some
AMI patients require less complex care,
other patients are admitted with
multiple comorbidities and require a
higher intensity of care, which may
involve multiple organs and a variety of
care resources. Other commenters
believe that if CMS implements the AMI
model as proposed, more beneficiaries
would move into the CABG model
because of the AMI model financial
incentives, which would not be in the
best interests of beneficiaries.
While some commenters
recommended a short implementation
delay for the AMI and/or CABG models,
several other commenters recommended
that CMS delay the AMI and CABG
models, with recommendations ranging
from 6 to 36 months. These commenters
believe this delay would provide
sufficient time for CMS to incorporate
known best practices from the
Healthcare Payment Learning and
Action Network (LAN) Clinical Episode
Payment (CEP) Work Group and lessons
learned from both the BPCI and CJR
models into the design of the cardiac
EPMs. Otherwise, the commenters were
concerned that the cardiac EPMs would
both put beneficiaries at risk and
disadvantage providers, as the episodes
would be built using designs that were
not supported by CMS’ own panel of
industry experts.
Some commenters expressed concern
about expanding EPMs to complex
conditions such as AMI and CABG,
where treatment can follow multiple
evidence-based care pathways. One
commenter pointed out that the
proposed AMI and CABG models would
generally include beneficiaries receiving
unplanned care due to an acute event,
making the population’s care difficult to
manage. The commenter requested that
CMS not implement the proposed
cardiac EPMs. Several commenters
stated that the complexity of the
proposed cardiac EPMs was so great that
CMS had essentially proposed a
completely different payment system for
cardiac care and would provide EPM
participants with little time to prepare
and plan for implementation. The
commenters believe that decisions about
appropriate care should be made by
physicians and their patients and
should be based on each patient’s
medical necessity and care preferences.
They stated that bundling clinically
complex episodes with multiple care
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pathways may lead to factors other than
medical necessity and care preferences
influencing the decisions that providers
make, and that such decisions could
have a long-term impact on a patient’s
health and well-being and may increase
costs in the long run while achieving
the short-term goal of reducing episodic
costs. The commenters believe that this
potentially serious issue warranted
immediate attention by CMS, given the
lack of evidence on the impact of the
EPMs on key patient-centered outcomes,
and concluded that the proposed EPMs
require further consideration and study
before additional bundling initiatives
are implemented.
MedPAC stated that the proposed
AMI episodes did not appear to be a
promising place to further test bundled
payment because AMI episodes have
relatively low post-acute care use and
the associated post-acute care spending
makes up a small share of total episode
spending. They concluded that savings
opportunities for participating providers
would be smaller compared with other
conditions. Consistent with the
observations of a few other commenters,
MedPAC stated that complex medical
conditions such as AMI do not involve
a single clinical pathway but rather can
involve patient transfers to hospitals
with more intensive cardiac capabilities
and subsequent readmissions for CABG.
While MedPAC acknowledged that
CMS’ proposed rule addressed these
issues, they noted that if the benchmark
prices are not accurate, the prices could
inadvertently shape clinical practice or
encourage selective admissions. Instead
of an EPM, MedPAC suggested that CMS
consider allowing hospitals to share
savings with physicians as a way to
focus physicians on reducing the cost of
the inpatient stay for AMI care.
MedPAC further concluded that
CABG was also not an ideal condition
for testing bundled payment models
because, although the majority of
beneficiaries undergoing CABG go on to
use post-acute care services, the
spending on post-acute care services is
relatively low compared to other
clinical conditions. They noted that
with the inpatient stay comprising the
vast majority of total episode spending,
the opportunities to realize savings by
changing clinical practice would be
small. MedPAC presented an additional
concern regarding the potential for
undesirable provider responses to
financial incentives, including patient
selection, in the proposed CABG model.
They claimed that providers of cardiac
care have been shown to engage in
patient selection and expressed concern
that, with larger savings at stake, these
behaviors could increase. They
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recommended that CMS delay testing
the CABG model until the benefits of
episode efficiency outweigh the
concerns about patient selection.
Response: We appreciate the support
of some of the commenters for our
proposal to implement the AMI and
CABG models. The proposed cardiac
models represent clinical conditions
that result in a significant burden of
morbidity and expenditures in the
Medicare population. However, we
acknowledge the great diversity of views
about the AMI and CABG models
reflected in the comments.
We proposed AMI as the episode for
an EPM because we recognized it as a
significant clinical condition for which
evidence-based clinical guidelines are
available for the most common AMI
scenarios that begin with a beneficiary’s
presentation for urgent care, most
commonly to a hospital emergency
department. The hospital phase
involves medical management for all
patients, as well as potential
revascularization, most commonly with
PCI. As commenters observed, the AMI
model is the first Innovation Center
episode payment model that includes
substantially different clinical care
pathways (medical management and
PCI) for a single clinical condition in
one episode in a model. In this sense the
AMI model is a condition-specific EPM,
although it is not focused on the
underlying CAD condition that puts
some beneficiaries at risk for the AMI
but rather on the AMI itself. While we
recognize that AMI may be a
complication of care from inadequately
managed CAD, we continue to believe
that there is an important role for the
AMI model in testing bundled payment
for beneficiaries with AMI who follow
a variety of clinical pathways because
AMI is a sentinel event indicating the
need for an increased focus on
condition-specific management. The
proposed 90 day post-discharge episode
duration would provide a springboard
to heighten the focus on CAD-specific
management. While future models may
focus on CAD management itself,
including reducing the risk of AMI, in
addition to the current Million Hearts®
Cardiovascular Risk Reduction Model,
we believe that the proposed AMI
model also plays an important role in
testing an EPM for this clinical
condition which is not always avoidable
even in the context of the best practices
to manage CAD on an ongoing basis.35
We believe that it is important to test
EPMs like the AMI model where
35 Million Hearts®: Cardiovascular Disease Risk
Reduction Model. https://innovation.cms.gov/
initiatives/Million-Hearts-CVDRRM/.
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beneficiaries can follow multiple
clinical pathways, including transfers
among hospitals with different cardiac
care capacity because, more commonly
than not, beneficiaries who are
hospitalized for an emergent clinical
condition do not constitute as
homogeneous a group as those who
choose to undergo elective surgery.
However, there likely are significant
opportunities to improve the quality
and efficiency of episode care through
care redesign that improves care
coordination and management for
beneficiaries unexpectedly hospitalized
for treatment following a cardiac event.
We disagree with the commenter who
recommended that we create two
treatment-based EPMs, AMI medical
management and PCI, because, in the
context of our proposed pricing
methodology that sets MS–DRG-specific
EPM-episode benchmark prices and
quality-adjusted target prices as
discussed in section III.D.4.b.(1). of this
final rule, we believe we can
appropriately include beneficiaries
following the two different treatment
approaches in the same EPM without
concern that the financial incentives of
the EPM are influencing the treatment
choice for beneficiaries.
We appreciate the support of many
commenters for the proposed CABG
model. We believe that CABG may play
a role for some beneficiaries with
symptomatic CAD, either with or
without AMI, because CABG is
associated with lower longer-term rates
of major adverse cardiac and
cerebrovascular events in comparison to
PCI for certain groups of patients. As a
number of commenters pointed out,
multiple other entities, including states,
are testing CABG bundled payment
models due to the variability in costs
and outcomes despite robust clinical
guidelines.
In response to those commenters who
recommended that the AMI and CABG
models be delayed in order to
incorporate known best practices from
the LAN CEP Work Group, we note that
the LAN is a public-private partnership
established by the U.S. Department of
Health and Human Services (HHS) to
increase the adoption of APMs that
promote better care, smarter spending,
and healthier people. The LAN has a
voluntary collaborative structure and its
consensus recommendations do not
necessarily reflect the views of its
individual participants. Representatives
from CMS, along with representatives
from states, purchasers, providers,
commercial payers, and consumers,
were active participants in the CEP
Work Group and developed, with input
from the broader LAN network, a set of
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recommendations that reflect a
consensus view, balancing innovation
with current practice to move the health
care delivery system forward. The CEP
Work Group full recommendations have
not yet been tested in the market. The
LAN CEP Work Group
recommendations and the proposed
CMS CABG and AMI EPMs, although
incorporating different design features,
both support the implementation of
episode-based payment models for
cardiac care. We anticipate that both the
LAN recommendations and the CMS
AMI and CABG models will expand
provider experience and expertise
regarding the necessary resources and
most effective strategies for providing
high quality, efficient care through
episode-based payment models and will
help prepare the market for further
adoption of innovative payment models
in the future. Therefore, we believe that
best practices for episode payment
models are continuously being
identified and refined based on
providers’ actual implementation
experiences with episode payment
models of various designs. Rather than
redesigning the proposed cardiac care
models to conform to the LAN CEP
Work Group recommendations, we look
forward to testing the AMI and CABG
models based on the policies included
in this final rule and sharing our
evaluation findings with stakeholders to
inform other episode payment models
for cardiac care.
We do not agree with MedPAC’s
conclusion that the proposed AMI and
CABG models do not hold promise
because of limited post-acute care
spending in AMI episodes and the high
percentage of CABG episode spending
due to the anchor hospitalization in
CABG episodes coupled with the risk of
patient selection due to the financial
incentives of the CABG model. While
care redesign to improve the efficiency
of post-acute care use may be an
obvious strategy to address variation in
episode spending for those episodes,
such as SHFFT and LEJR episodes with
high utilization of post-acute care
services, AMI and CABG beneficiaries
have substantial episode spending
during 90 days post-discharge from the
anchor hospitalization as a result of
complications, further treatment, and
ongoing care management of their
underlying chronic conditions. We
believe that increased efficiencies in the
post-discharge care and improved care
coordination represent a significant
opportunity to improve the quality and
reduce the cost of AMI and CABG
episodes.
As commenters pointed out, the
cardiac EPMs create some risks of harm
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203
to beneficiaries from patient selection
and different treatment choices EPM
participants could adopt based on the
financial incentives under the EPMs,
although we believe these concerns are
generally present for every episode
payment model that sets a price that
Medicare pays for an episode-of-care. As
discussed further in sections III.G.4.
through 6. of this final rule, we will take
steps to prevent potential harm by
monitoring for access to care, quality of
care, and delayed care under the EPMs
and may take remedial action against
EPM participants if we find evidence
that supports concerns in these areas. In
addition, the evaluation as discussed in
section IV. of this final rule will analyze
beneficiary outcomes and their
relationship to clinical pathways under
the EPMs.
We refer to section III.D.2.a. of this
final rule for a discussion of the
comments on the proposed
implementation timeline for the AMI
and CABG models and our responses.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal to implement the
AMI and CABG models, with
modifications to specific policies as
described throughout this final rule. We
refer to section III.D.2.a. of this final rule
for the implementation timeline that
applies to the AMI and CABG models.
2. Advanced Alternative Payment
Model Considerations
For ease of reading the subsequent
sections regarding our proposals and
our final policies around the EPMs as
Advanced APMs, we first present the
proposals outlined in the Quality
Payment Program proposed rule (81 FR
28161) followed by the policies outlined
in the Quality Payment Program final
rule with comment period (81 FR
77008).
a. Overview for the EPMs
The MACRA created two paths for
eligible clinicians to link quality to
payments: The MIPS and Advanced
APMs. These two paths create a flexible
payment system called the Quality
Payment Program as proposed by CMS
in the Quality Payment Program
proposed rule (81 FR 28161 through
28586).
As proposed in the Quality Payment
Program proposed rule, an APM must
meet three criteria to be considered an
Advanced APM (81 FR 28298). First, the
APM must provide for payment for
covered professional services based on
quality measures comparable to
measures described under the
performance category described in
section 1848(q)(2)(B)(i) of the Act,
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which is the MIPS quality performance
category. We interpret this criterion to
require the APM to incorporate quality
measure results as a factor when
determining payment to participants
under the terms of the APM. Under the
Quality Payment Program proposed
rule, we proposed that the quality
measures on which the Advanced APM
bases payment for covered professional
services (as that term is defined in
section 1848(k)(3)(A) of the Act) must
include at least one of the following
types of measures, provided that they
have an evidence-based focus and are
reliable and valid (81 FR 28302):
• Any of the quality measures
included on the proposed annual list of
MIPS quality measures.
• Quality measures that are endorsed
by a consensus-based entity.
• Quality measures developed under
section 1848(s) of the Act.
• Quality measures submitted in
response to the MIPS Call for Quality
Measures under section 1848(q)(2)(D)(ii)
of the Act.
• Any other quality measures that
CMS determines to have an evidencebased focus and be reliable and valid.
As we discussed in the Quality
Payment Program proposed rule,
because the statute identifies outcome
measures as a priority measure type and
we wanted to encourage the use of
outcome measures for quality
performance assessment in APMs, we
further proposed in that rule that, in
addition to the general quality measure
requirements, an Advanced APM must
include at least one outcome measure if
an appropriate measure is available on
the MIPS list of measures for that
specific QP Performance Period,
determined at the time when the APM
is first established (81 FR 28302 through
28303).
Second, the APM must either require
that participating APM Entities bear risk
for monetary losses of a more than
nominal amount under the APM or be
a Medical Home Model expanded under
section 1115A(c) of the Act. Except for
Medical Home Models, we proposed in
the Quality Payment Program proposed
rule that, for an APM to meet the
nominal amount standard, the specific
level of marginal risk must be at least 30
percent of losses in excess of expected
expenditures; a minimum loss rate, to
the extent applicable, must be no greater
than 4 percent of expected
expenditures; and total potential risk
must be at least 4 percent of expected
expenditures (81 FR 28306).
Third, the APM must require
participants to use CEHRT (as defined
in section 1848(o)(4) of the Act), as
specified in section 1833(z)(3)(D)(i)(I) of
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the Act, to document and communicate
clinical care with patients and other
health care professionals. Specifically,
where the APM participants are
hospitals, the APM must require each
hospital to use CEHRT (81 FR 28298
through 28299).
In the proposed rule (81 FR 50794),
we proposed to adopt two different
tracks for the EPMs—Track 1 in which
EPMs and EPM participants would meet
the criteria for Advanced APMs as
proposed in the Quality Payment
Program proposed rule, and Track 2 in
which the EPMs and EPM participants
would not meet those proposed criteria.
For the proposed AMI, CABG, and
SHFFT models, we proposed pay-forperformance methodologies that use
quality measures that we believe would
meet the proposed Advanced APM
quality measure requirements in the
Quality Payment Program proposed
rule. As discussed in sections III.E.2.
and 3. of the proposed rule (81 FR
50794), all but one of the AMI, CABG,
and SHFFT model measures used in the
EPM pay-for-performance
methodologies are NQF-endorsed and
have an evidence-based focus and are
reliable and valid. Therefore, we believe
they would meet the proposed
Advanced APM general quality measure
requirements. The Excess Days in Acute
Care after Hospitalization for AMI (AMI
Excess Days) measure, which was
proposed for the AMI model, is not
currently NQF-endorsed, but was
reviewed, recommended for
endorsement, and is expected to be
formally endorsed within the first
quarter of 2017. We believe it meets the
measure requirements by having an
evidence-based focus and being reliable
and valid because this measure has been
proposed and adopted through
rulemaking for use in the Hospital
Inpatient Quality Reporting (HIQR)
Program.
Each of the proposed EPM pay-forperformance methodologies included
one outcome measure that is NQFendorsed, has an evidence-based focus,
and is reliable and valid. The EPM
quality measures were discussed in
detail in section III.E. of the proposed
rule (81 FR 50794), where we assigned
the quality measures to quality domains.
For the AMI model, we proposed to use
the Hospital 30-Day, All-Cause, RiskStandardized Mortality Rate (RSMR)
Following Acute Myocardial Infarction
(NQF #0230) (MORT–30–AMI) outcome
measure. For the CABG model, we
proposed to use the Hospital 30-Day,
All-Cause, Risk-Standardized Mortality
Rate (RSMR) Following Coronary Artery
Bypass Graft (CABG) Surgery (NQF#
2558) (MORT–30–CABG) outcome
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measure. Finally, for the SHFFT model,
we proposed to use the Hospital-level
RSCR following elective primary THA
and/or TKA (NQF #1550) (Hip/Knee
Complications) outcome measure. Thus,
based on the proposed use of these three
outcomes measures in the EPMs, we
believed the proposed AMI, CABG, and
SHFFT models would meet the
requirement proposed for Advanced
APMs in the Quality Payment Program
proposed rule for use of an outcome
measure that also meets the general
quality measure requirements.
In terms of the proposed nominal risk
criteria for Advanced APMs, beginning
in performance year 2 for episodes
ending between April 1, 2018 and
December 31, 2018, we proposed that
EPM participants would begin to bear
downside risk for excess actual EPMepisode spending above the qualityadjusted target price as discussed in
section III.D.2.c. of the proposed rule
(81 FR 50794). The marginal risk for
excess actual EPM-episode spending
above the quality-adjusted target price
would be 100 percent over the range of
spending up to the stop-loss limit,
which would exceed 30 percent
marginal risk, and there would be no
minimum loss rate. As a result, we
believed the EPMs would meet the
marginal risk and minimum loss rate
elements of the nominal risk criteria for
Advanced APMs proposed in the
Quality Payment Program proposed
rule. We proposed that total potential
risk for most EPM participants would be
5 percent of expected expenditures
beginning in the second quarter of
performance year 2, and increasing in
subsequent performance years as
discussed in section III.D.7.b. of the
proposed rule (81 FR 50794). Therefore,
in the proposed rule, we stated our
belief that the total proposed potential
risk applicable to most EPM
participants, with the lowest total
potential risk being 5 percent for EPM
episodes ending on or after April 1,
2018 in performance year 2, would meet
the total potential risk element of the
nominal risk amount standard for
Advanced APMs proposed in the
Quality Payment Program proposed rule
because it was greater than the value of
at least 4 percent of expected
expenditures.
We note that we proposed that EPM
participants that are rural hospitals, sole
community hospitals (SCHs), Medicare
Dependent Hospitals (MDHs) and Rural
Referral Centers (RRCs) would have a
stop-loss limit of 3 percent beginning in
the second quarter of performance year
2 as discussed in section III.D.7.c. of the
proposed rule (81 FR 50794). Because 3
percent was less than the proposed
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threshold of at least 4 percent of
expected expenditures for total potential
risk proposed for Advanced APMs in
the Quality Payment Program proposed
rule, those rural hospitals, SCHs, MDHs,
and RRCs that are EPM participants
subject to special protections would be
in Track 2 EPMs that would not meet
the proposed nominal risk standard for
Advanced APMs for performance year 2.
We recognized that this proposal might
initially limit the ability of rural
hospitals, SCHs, MDHs, and RRCs to be
in Track 1 EPMs that are Advanced
APMs. In the proposed rule, we
explained our belief that this potential
limitation on rural hospitals, SCHs,
MDHs, and RRCs is appropriate for the
following reasons: (1) Greater risk
protections for these hospitals proposed
for the EPMs beginning in the second
quarter of performance year 2 and
subsequent performance years
compared to other EPM participants are
necessary, regardless of their
implications regarding Advanced APMs
based on the nominal risk standard
proposed in the Quality Payment
Program proposed rule, because these
hospitals have unique challenges that
do not exist for most other hospitals,
such as being the only source of health
care services for beneficiaries or certain
beneficiaries living in rural areas or
being located in areas with fewer
providers, including fewer physicians
and post-acute care facilities; and (2)
under the risk arrangements proposed
for the EPMs, these hospitals would not
bear an amount of risk in performance
year 2 that we determined to be more
than nominal in the Quality Payment
Program proposed rule. However, we
sought comment on whether we should
allow EPM participants that are rural
hospitals, SCHs, MDHs, or RRCs to elect
a higher stop-loss limit for the part of
performance year 2 where downside
risk applies in order to permit these
hospitals to be in Track 1 EPMs for that
part of performance year 2. We noted
that by performance year 3, the stop-loss
limit for these hospitals with special
protections under the EPMs would
increase to 5 percent under our
proposal, so these hospitals could be in
Track 1 EPMs based on the nominal risk
standard proposed in the Quality
Payment Program proposed rule.
As addressed in the Quality Payment
Program proposed rule, it would be
necessary for an APM to require the use
of CEHRT in order to meet the criteria
to be considered to be an Advanced
APM. Therefore, according to the
requirements proposed in the Quality
Payment Program proposed rule, so that
the EPMs may meet the proposed
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criteria to be Advanced APMs, we
proposed to require EPM participants to
use CEHRT (as defined in section
1848(o)(4) of the Act) to participate in
Track 1 of the EPMs. We proposed that
Track 1 EPM participants must use
certified health IT functions, in
accordance with the definition of
CEHRT under our regulation at
§ 414.1305 (81 FR 77537), to document
and communicate clinical care with
patients and other health care
professionals as proposed in the Quality
Payment Program proposed rule (81 FR
28299). We believed this proposal
would allow Track 1 EPMs to be able to
meet the proposed criteria to be
Advanced APMs.
Without the collection of identifying
information on eligible clinicians
(physicians, non-physician
practitioners, physical and occupational
therapists, and qualified speechlanguage pathologists) who would be
considered Affiliated Practitioners as
proposed in the Quality Payment
program proposed rule under the EPMs,
CMS would not be able to consider
participation in the EPMs in making
determinations as to whom could be
considered a QP (81 FR 28320). As
detailed in the Quality Payment
Proposed rule, these determinations are
based on whether the eligible clinician
meets the QP threshold under either the
Medicare Option starting in payment
year 2019 or the All-Payer Combination
Option, which is available starting in
payment year 2021 (81 FR 28165). Thus,
we made proposals in the following
sections to specifically address these
issues that might otherwise preclude the
EPMs from being considered Advanced
APMs, or prevent us from
operationalizing them as Advanced
APMs. Based on the proposals for
Advanced APM criteria in the Quality
Payment Program proposed rule, we
sought to align the design of the
proposed EPMs with the proposed
Advanced APM criteria and enable CMS
to have the necessary information on
eligible clinicians to make the requisite
QP determinations.
For ease of reading the subsequent
sections regarding our proposals and
final policies for the EPMs as Advanced
APMs, we present the following
definitions from § 414.1305 that have
now been finalized in the Quality
Payment Program final rule with
comment period (81 FR 77008).
Alternative Payment Model (APM)
means any of the following: (1) A model
under section 1115A of the Act (other
than a health care innovation award); (2)
The shared savings program under
section 1899 of the Act; or (3) A
demonstration under section 1866C of
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205
the Act. (4) A demonstration required by
federal law.
Episode payment model means an
APM or other payer arrangement
designed to improve the efficiency and
quality of care for an episode of care by
bundling payment for services furnished
to an individual over a defined period
of time for a specific clinical condition
or conditions.
APM Entity means an entity that
participates in an APM or payment
arrangement with a non-Medicare payer
through a direct agreement or through
Federal or State law or regulation.
Advanced Alternative Payment Model
(Advanced APM) means an APM that
CMS determines meets the criteria set
forth in § 414.1415.
Advanced APM Entity means an APM
Entity that participates in an Advanced
APM or Other Payer Advanced APM.
Participation List means the list of
participants in an APM Entity that is
compiled from a CMS-maintained list.
Eligible Clinician means ‘‘eligible
professional’’ as defined in section
1848(k)(3) of the Act, as identified by a
unique TIN and NPI combination and,
includes any of the following: (1) A
physician; (2) A practitioner described
in section 1842(b)(18)(C) of the Act; (3)
A physical or occupational therapist or
a qualified speech language pathologist;
or (4) A qualified audiologist (as defined
in section 1861(ll)(3)(B) of the Act).
Affiliated Practitioner means an
eligible clinician identified by a unique
APM participant identifier on a CMSmaintained list who has a contractual
relationship with the Advanced APM
Entity for the purposes of supporting the
Advanced APM Entity’s quality or cost
goals under the Advanced APM.
Affiliated Practitioner List means the
list of Affiliated Practitioners of an APM
Entity that is compiled from a CMSmaintained list.
Qualifying APM Participant (QP)
means an eligible clinician determined
by CMS to have met or exceeded the
relevant QP payment amount or QP
patient count threshold under
§ 414.1430(a)(1), (a)(3), (b)(1), or (b)(3)
for a year based on participation in an
Advanced APM Entity.
QP Patient Count Threshold means
the minimum threshold score specified
in § 414.1430(a)(3) and (b)(3) that an
eligible clinician must attain through a
patient count methodology described in
§§ 414.1435(b) and 414.1440(c) to
become a QP for a year.
QP Payment Amount Threshold
means the minimum threshold score
specified in § 414.1430(a)(1) and (b)(1)
that an eligible clinician must attain
through the payment amount
methodology described in
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§§ 414.1435(a) and 414.1440(b) to
become a QP for a year.
Threshold Score means the
percentage value that CMS determines
for an eligible clinician based on the
calculations described in § 414.1435 or
§ 414.1440.
Merit-based Incentive Payment
System (MIPS) means the program
required by section 1848(q) of the Act.
MIPS APM means an APM that meets
the criteria specified under
§ 414.1370(b).
Improvement Activities means an
activity that relevant MIPS eligible
clinicians, organizations and other
relevant stakeholders identify as
improving clinical practice or care
delivery and that the Secretary
determines, when effectively executed,
is likely to result in improved outcomes.
Based on the proposals for Advanced
APM criteria in the Quality Payment
Program proposed rule (81 FR 28161),
we sought to align the design of the
proposed EPM Advanced APM track
with the proposed Advanced APM
criteria and enable CMS to have the
necessary information on Eligible
Clinicians to make the requisite QP
determinations. As detailed in the
Quality Payment Program final rule
with comment period, QP
determinations are based on whether
the Eligible Clinician meets the QP
threshold under either the Medicare
Option starting in payment year 2019 or
the All-Payer Combination Option,
which is available starting in payment
year 2021 (81 FR 77013). Eligible
clinicians seeking QP determinations as
early as performance year 2 would need
to meet the QP threshold under the
Medicare Option. The three criteria for
an Advanced APM were finalized in the
Quality Payment Program final rule
with comment period (81 FR 77008),
and we continue to align the design of
the finalized EPMs with the finalized
Advanced APM criteria so that EPM
participants who choose to use and
attest to use of CEHRT may participate
in an EPM that meets the criteria of an
Advanced APM. To be determined to be
an advanced APM, an APM must meet
three Advanced APM criteria identified
in § 414.1415 and discussed specifically
later in this section.
First, the APM must require
participants to use CEHRT (as defined
in section 1848(o)(4) of the Act), as
specified in section 1833(z)(3)(D)(i)(I) of
the Act, to document and communicate
clinical care with patients and other
health care professionals (81 FR 77406).
Specifically, where the APM
participants are hospitals, the APM
must require each hospital to use
CEHRT. As addressed in the Quality
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Payment Program final rule with
comment period, it is necessary for an
APM to require the use of CEHRT in
order to meet the criteria to be
considered to be an Advanced APM.
Therefore, according to the
requirements now finalized in the
Quality Payment Program final rule
with comment period, so that the EPMs
may meet the finalized criteria to be
Advanced APMs, we proposed that
those EPM participants who choose to
participate in Track 1 of the EPMs must
use certified health IT functions, in
accordance with the definition of
CEHRT under our regulation at 42 CFR
414.1305, to document and
communicate clinical care with patients
and other health care professionals. We
believe that this proposal set forth in the
EPM proposed rule would allow EPM
participants who use and attest to use of
CEHRT to be in an EPM that meets the
first finalized Advanced APM criterion.
Second, the APM must provide for
payment to participants based on
performance on quality measures
comparable to measures described
under the performance category
described in section 1848(q)(2)(B)(i) of
the Act, which is the MIPS quality
performance category. We interpret this
criterion to require the APM to
incorporate quality measure results as a
factor when determining payment to
participants under the terms of the APM
as described in the Quality Payment
Program final rule with comment period
(81 FR 77414). In order to align the
EPMs with the Quality Payment
Program final rule with comment
period, the quality measures on which
the Advanced APM bases payment to
participants must include at least one of
the following types of measures,
provided that they have an evidencebased focus and are reliable and valid
(81 FR 77418):
Any of the quality measures included
on the proposed annual list of MIPS
quality measures.
Quality measures that are endorsed by
a consensus-based entity.
Quality measures developed under
section 1848(s) of the Act.
Quality measures submitted in
response to the MIPS Call for Quality
Measures under section 1848(q)(2)(D)(ii)
of the Act.
Any other quality measures that CMS
determines to have an evidence-based
focus and be reliable and valid.
As we discussed in the Quality
Payment Program final rule with
comment period, because the statute
identifies outcome measures as a
priority measure type and we want to
encourage the use of outcome measures
for quality performance assessment in
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APMs, we further finalized in that rule
that, in addition to the general quality
measure requirements, an Advanced
APM must include at least one outcome
measure if an appropriate measure is
available on the MIPS list of measures
for that specific QP Performance Period,
determined at the time when the APM
is first established (81 FR 77418).
Therefore, according to the
requirements finalized in the Quality
Payment Program final rule with
comment period and the quality
measures finalized in section III.E of
this final rule that are the proposed EPM
quality measures with an additional
voluntary measure for the CABG model,
the EPMs will meet the second finalized
criterion of the Advanced APM criteria.
Third, the Quality Payment Program
final rule with comment period requires
that for an APM to meet the Advanced
APM criteria, the APM must either
require that participating APM Entities
bear risk for monetary losses of a more
than nominal amount under the APM or
be a Medical Home Model expanded
under section 1115A(c) of the Act. For
the purposes of the EPM, the generally
applicable nominal amount standard for
an Advanced APM in the Quality
Payment Program final rule with
comment period (81 FR 77425) means
the total amount an APM Entity
potentially owes CMS or foregoes under
an APM must be at least equal to 3
percent of the expected expenditures for
which an APM Entity is responsible
under the APM. The generally
applicable financial risk standard (81 FR
77422) means when an APM Entity’s
actual expenditures for which the APM
Entity is responsible under the APM
exceed expected expenditures during a
specified QP Performance Period, the
APM Entity is required to owe
payment(s) to CMS. We refer to the
Quality Payment Program final rule
with comment period for a discussion
regarding why we did not finalize the
specific level of marginal risk or
minimum loss rate (81 FR 77426).
However, consistent with the
commitments we made to adhere to the
proposed marginal risk and minimum
loss rate requirements in the Quality
Payment Program proposed rule, we
note that the financial risk in this final
rule when the EPMs involve downside
risk exceeds the proposed marginal risk
and minimum loss rate requirements
proposed for the Quality Payment
Program. As discussed in sections
III.D.7.b. and c. and displayed in Table
12 of this final rule, the final total initial
risk of expected expenditures for EPM
participants of 5 percent, and 3 percent
for rural hospitals, SCHs, MDHs, RRCs,
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and EPM volume protection hospitals
subject to separate stop-loss protections,
beginning in performance year 3 when
downside risk for all participants first
applies, would meet the total potential
risk element of the nominal risk amount
standard for Advanced APMs finalized
in the Quality Payment Program final
rule with comment period (81 FR
77427) because they are greater than or
equal to the value of at least 3 percent
of expected expenditures. Those EPM
participants who elect voluntary
downside risk beginning in performance
year 2 will be subject to the same total
risk of expected expenditures in
performance year 2 and, therefore, will
be in an EPM that meets the total
potential risk element of the nominal
risk amount standard for Advanced
APMs beginning in performance year 2.
Therefore, according to the
requirements finalized in the Quality
Payment Program final rule with
comment period and the payment
methodology for EPM participants
finalized in section III.D of this final
rule, those EPM participants who
voluntarily elect downside risk for EPM
episodes ending on or after January 1,
2018 will be in an EPM that meets the
third finalized criterion of the Advanced
APM criteria in performance year 2. All
other EPM participants will be in an
EPM that meets the third finalized
criterion of the Advanced APM criteria
in performance year 3.
Finally, we finalized in the Quality
Payment Program final rule with
comment period (81 FR 77442) that for
Advanced APMs, such as episode
payment models, in which there are
some Advanced APM Entities that
include Eligible Clinicians on a
Participation List and other Advanced
APM Entities that identify Eligible
Clinicians only on an Affiliated
Practitioner List, we will identify
Eligible Clinicians for QP
determinations based on the
composition of the Advanced APM
Entity. In the scenario that applies to the
EPM which includes only hospitals as
Advanced APM Entities on the
Participation List, for those Advanced
APM Entities where there is an
Affiliated Practitioner List that
identifies Eligible Clinicians, that
Affiliated Practitioner List will be used
to identify the Eligible Clinicians for
purposes of QP determinations, and
those Eligible Clinicians will be
assessed individually. Thus, to
operationalize the EPM as an Advanced
APM, our proposal for the EPM to
identify Eligible Clinicians on a
clinician financial arrangements list to
construct the Affiliated Practitioner list
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would identify those Eligible Clinicians
for purposes of QP determination,
consistent with the policies finalized in
the Quality Payment Program final rule
with comment period.
We received a number of public
comments on our proposals for the
EPMs as Advanced APMs. A few
commenters requested changes to the
policies proposed by CMS in the
Quality Payment Program proposed rule
and not to specific proposals for the
EPMs set forth in the EPM proposed
rule. These comments are out of scope
for this rulemaking and no responses are
provided in this final rule. Nevertheless,
we have summarized this feedback
related to the Quality Payment Program
proposed rule, as CMS will continue
work to improve the Quality Payment
Program in part through future notice
and comment rulemaking.
One commenter requested change to
the definition of Affiliated Practitioner
to include rehabilitation therapists.
Many commenters requested changes to
the definitions of the Affiliated
Practitioner List and/or Participation
List to identify Eligible Clinicians for
the purposes of Advanced APMs, MIPS
APMs, and the assignment by CMS of an
Improvement Activities score, which
fulfills one of four categories for MIPS
assessment of cost and quality. Another
commenter requested changes to the
performance period or the December 31
date by which an Eligible Clinician
could qualify for automatic credit for
incentive payment and/or clinical
Improvement Activities performance.
This commenter reasoned that such
changes would permit more Eligible
Clinicians to receive a QP
determination, which may qualify them
for an APM incentive payment under
MACRA. One commenter expressed
uncertainty regarding the process by
which Eligible Clinicians could receive
a QP determination for the efforts of the
EPM participant, and requested that
CMS clarify on the pathway for
participating physicians to be in an
Advanced APM generally. Another
commenter suggested CMS replace the
QP determination with the proposal
that, for EPM providers who meet the
CEHRT use requirement and have 50 or
more Medicare beneficiaries attributed
to these EPMs, the threshold for
Advanced APMs would be met
automatically. A few commenters
wanted CMS to use the Meaningful Use
program to gather attestation to CEHRT
use from hospitals. A few commenters
strongly recommended CMS lower the
patient count and payment revenue
thresholds used in the calculation of the
Threshold Score to meet QP Threshold
Status as specified in the Quality
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207
Payment Program proposed rule. Many
commenters urged CMS to work closely
with the affected professional
organizations and/or physician specialty
societies to design QP thresholds. One
commenter requested changes to the
APM Entity such that the APM Entity
lose the right to all or part of otherwise
guaranteed payment or payments as one
of the options if the APM Entity’s actual
aggregate expenditures exceed expected
aggregate expenditures. A few
commenters requested changes to the
categorical exclusion that Medicare
Advantage (MA) and other private plans
paid to act as insurers on the Medicare
program’s behalf are not Advanced
APMs, in light of the amount of risk
taken by physicians in MA. Finally, one
commenter requested changes to the
allow Independence at Home
participants who use CEHRT to qualify
for Advanced APM incentive payments.
The following is a summary of the
comments received on our proposals
and our responses.
Comment: MedPAC commented that
the EPM and CJR models should not be
considered Advanced APMs for the
purposes of MACRA. MedPAC stated
they believe the following six principles
should apply to Advanced APMs: the
Advanced APM entity should assume
the financial risk and enroll clinicians;
be at financial risk for total Part A and
Part B spending; be responsible for a
beneficiary population sufficiently large
to detect changes in spending and
quality; have the ability to share savings
with beneficiaries; be provided certain
regulatory relief by CMS; and the
enrolled clinicians should receive an
incentive payment only if the Advanced
APM entity in which they participate is
successful in controlling cost,
improving quality, or both. Under the
proposed EPMs, MedPAC believes the
proposed rule contemplates large,
loosely connected groups of clinicians
who may have very little involvement
with the beneficiaries in EPMs and
hence have little reason to change their
practice patterns or reduce
inappropriate episodes. If CMS intends
for clinicians to bear risk, MedPAC
made the alternative proposal that they
could do so directly without having the
hospital as the intermediary.
Response: While we appreciate the
principles for Advanced APMs offered
by MedPAC, we note that according to
the Advanced APM definition in the
Quality Payment Program final rule
with comment period (81 FR 77008), the
Track 1 EPMs that we proposed qualify
as Advanced EPMs as discussed
previously in this section.
While we recognize EPM participants
are the participating APM Entities for
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the purposes of the Quality Payment
Program, CMS will consider
participation of Eligible Clinicians in
the Track 1 EPMs through collection of
identifying information from Track 1
EPM participants on clinician financial
arrangements lists as discussed in
section III.A.2.c. of this final rule who
would then be included on the
Affiliated Practitioner List as defined in
the Quality Payment Program final rule
with comment period at § 414.1305 (81
FR 77537), in order to determine who
could be considered a QP. The
requirements for Eligible Clinicians to
be reported on the clinician financial
arrangements lists help ensure that
these clinicians have specific
involvement in caring for EPM
beneficiaries and advancing the goals of
the EPMs to improve the quality and
reduce the cost of care. Finally, Eligible
Clinicians can only be considered
Qualifying Professionals or Partial
Qualifying Professionals and, therefore,
potentially be exempt from MIPS, if the
Eligible Clinician meets the QP
threshold or partial QP threshold as
described in the Quality Payment
Program final rule with comment period
(81 FR 77433). Additionally, while we
recognize the concerns with EPM
participants or CJR participant hospitals
intermediating the APM incentive
payments, we believe that the QP
threshold incentivizes Eligible
Clinicians to work with such
participants to improve health care
delivery for Medicare beneficiaries.
The qualification of the CJR model as
an Advanced APM is discussed in
section V.O. of this final rule.
Comment: Many commenters
expressed support for all organizations
to have the opportunities to participate
as Advanced APMs and noted that as
proposed, rural hospitals, SCHs, MDHs,
and RRCs that are EPM participants
would not potentially qualify for
participation in an Advanced APM until
performance year 3 due to the proposed
lower stop-loss limits for these hospitals
under the EPMs. Additionally, one
commenter recommended that a distinct
CEHRT program be developed and
funding be allocated for non-physician
and non-prescribing professionals as
soon as possible, as the cost of
acquisition, implementation, and
maintenance of an EHR is a significant
barrier to adoption, particularly for
small practices. One commenter
observed this proposal as an important
illustration of why CMS must be flexible
in its definition of nominal risk, and
how nominal will not mean the same
thing for every provider. As such,
commenters supported retention of the
proposed stop-loss limits under the
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EPMs as the default rule for these
hospitals, thus enabling them to meet
the nominal financial risk standard for
Track 1 EPMs (Advanced APMs) in
performance year 3 rather than
performance year 2 when other EPM
participants would be eligible for Track
1 EPMs. However, commenters also
believe CMS should also explore
options to allow these hospitals with
additional stop-loss protection under
the EPMs to voluntarily elect a higher
stop-loss limit in order to participate in
Track 1 EPMs in performance year 2.
Response: The Quality Payment
Program final rule with comment period
(81 FR 77427) finalized the policy that
an APM would meet the nominal
amount standard for an Advanced APM
if, under the terms of the APM, the total
annual amount that an APM Entity
potentially owes us or foregoes is equal
to at least 3 percent of the expected
expenditures for which an APM Entity
is responsible under the APM.
Therefore, rural hospitals, SCHs, MDHs,
RRCs, as well as EPM volume protection
hospitals as discussed in section
III.D.7.c of this final rule, that are EPM
participants with special stop-loss limits
could potentially qualify as being in an
Advanced APM as participants in a
Track 1 EPM in performance year 3,
along the same timeframe as all other
EPM participants when downside risk
for all participants is implemented, or in
performance year 2 when voluntary
downside risk may be elected by EPM
participants (section III.D.2.c. of this
final rule), based on the stop-loss limits
finalized in this rule for these hospitals
as discussed in section III.D.7.c. of this
final rule.
Comment: Commenters proposed
alternative processes by which a QP
determination could be made, including
collective assessment of QP status
across both the AMI and CABG models,
so as not to create siloed EPMs. In cases
where there is an overlap of
beneficiaries in more than one CMS
model or program, other commenters
proposed that beneficiaries should be
counted toward a physician’s QP
Threshold Score (a part of a QP
determination) if a beneficiary would
have been assigned to a particular
model if it were not for the fact that a
different model that has required
participation overlapped.
Response: The QP determination
discussed in the Quality Payment
Program final rule with comment period
depends on the level of payments or
patients furnished services through an
Advanced APM based on the
calculations described in § 414.1435 and
§ 414.1440, as applicable. Under certain
Advanced APMs such as a Track 1 EPM,
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the responsibility of cost and quality
measurement and reporting is with EPM
participants that are hospitals rather
than Eligible Clinicians. However, we
have specified that Eligible Clinicians
who are on Affiliated Practitioner Lists
may also be assessed for a QP
determination based on their Affiliated
Practitioner status if there are no eligible
clinicians on an Advanced APM’s
Participation List. Therefore, as
finalized in the Quality Payment
Program final rule with comment period
(81 FR 77443), if an Eligible Clinician
participates in multiple Advanced APM
Entities during a QP Performance
Period, and is not determined to be a QP
based on participation in any of those
Advanced APM Entities, then we will
assess the Eligible Clinician
individually using combined
information for services associated with
that individual’s NPI and furnished
through all the Eligible Clinician’s
Advanced APM Entities during the QP
Performance Period. This includes all
Advanced APM Entities for which the
Eligible Clinician is represented on
either a Participation List or Affiliated
Practitioner List that CMS uses for QP
determinations. We will make
adjustments to ensure that patients and
payments for services that may be
counted in the QP calculations for
multiple Advanced APM Entities (for
example, payments for services
furnished to a beneficiary attributed to
an ACO that are also part of an episode
in an episode payment model) are not
double-counted for the individual. We
believe that this policy maintains the
general principles behind Advanced
APM Entity-level QP determinations,
while acknowledging the broader
commitment of individual Eligible
Clinicians who are participating in
multiple Advanced APMs. We believe
considering these Eligible Clinicians
individually is the most reasonable
approach to capturing the multiple
potential permutations of participation
in Advanced APMs and providing
Eligible Clinicians an equitable
opportunity to become a QP.
Thus, with respect to the commenters’
concerns that CMS would only make a
model-specific QP determination for the
Track 1 AMI model and Track 1 CABG
model and not a collective
determination across the two models,
for Advanced APMs for which there is
not a Participation List that identifies
eligible clinicians and there is an
Affiliated Practitioner List that
identifies eligible clinicians, the Quality
Payment Program final rule with
comment period (81 FR 77442) notes
that Affiliated Practitioner List will be
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used to identify the eligible clinicians
for purposes of QP determinations.
Eligible clinicians on an Affiliated
Practitioner List will be assessed
individually, unlike eligible clinicians
on a Participation List who are assessed
as a group. Thus, we could make a
determination across the two models if
an Eligible Clinician was not
determined to be a QP based on
participation in any one of the Track 1
EPMs. Finally, as specified in the
Quality Payment Program final rule
with comment period (81 FR 77013),
QPs are Eligible Clinicians in an
Advanced APM who have a certain
percentage of their patients or payments
through an Advanced APM. Thus, we
will only count beneficiaries attributed
to an Advanced APM Entity toward a
clinician’s QP Threshold Score and will
not count those beneficiaries who
would have been attributed to an
Advanced APM Entity if it were not for
the fact that a different model
overlapped. Beneficiary attribution is
further discussed in the Quality
Payment Program final rule with
comment period (81 FR 77436)
b. EPM Participant Tracks
To be considered an Advanced APM,
the APM must require participants to
use CEHRT (as defined in section
1848(o)(4) of the Act), as specified in
section 1833(z)(3)(D)(i)(I) of the Act. We
proposed that all EPM participants must
choose whether to meet the CEHRT use
requirement. EPM participants that do
not choose to meet and attest to the
CEHRT use requirement would be in
Track 2 of the EPMs. EPM participants
selecting to meet the CEHRT use
requirement would be in Track 1 of the
EPMs and would be required to attest in
a form and manner specified by CMS to
their use of CEHRT that meets the
definition in our regulation at
§ 414.1305 (81 FR 77537) to document
and communicate clinical care with
patients and other health professionals,
consistent with the proposal in the
Quality Payment Program proposed rule
for the CEHRT requirement for
Advanced APMs (81 FR 28299). EPM
participants choosing not to meet and
attest to the CEHRT use requirement
would not be required to submit an
attestation.
We believe that the voluntary
selection by EPM participants to elect
downside risk for EPM episodes ending
on or after January 1, 2018, and to meet
and attest to the CEHRT use
requirement would create no significant
additional administrative burden on
EPM participants. Moreover, the choice
of whether to meet and attest to the
CEHRT use requirement would not
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otherwise change any EPM participant’s
requirements or opportunity under the
EPM. However, to the extent that
eligible clinicians who enter into
financial arrangements related to EPM
participants in the Track 1 EPM are
considered to furnish services through
an Advanced APM, those services could
be considered for purposes of
determining whether the eligible
clinicians are QPs.
The proposals for CEHRT use and
attestation for EPM participants were
included in proposed § 512.120(a). We
sought comment on our proposals for
EPM participant CEHRT use
requirements.
The following is a summary of the
comments received and our responses.
Comment: Commenters expressed
appreciation for CMS’ efforts to expand
the Advanced APM participation
opportunities as they commented that
the 5 percent Advanced APM incentive
payment is time-limited under current
law. They applauded the proposal to
expand the list of eligible Advanced
APMs through Track 1 EPMs as it
provides an incentive for physicians to
collaborate with hospital participants in
the EPM and could provide specialists,
who otherwise may have limited
avenues, to participate in an Advanced
APM. Other commenters requested
specifically that CMS clarify the steps
necessary when a provider group wishes
to change from Track 2 to Track 1 in the
EPMs.
Response: We appreciate the
commenters’ support for our proposal of
the Track 1 EPMs as Advanced APMs
and agree that providing greater
opportunities for physician
participation in Advanced APMs is an
important goal that can be advanced
through our proposal. We remind
commenters that only the EPM
participant can choose to participate in
a Track 1 EPM by using and attesting to
use of CEHRT. If Eligible Clinicians
enter into a financial arrangement
associated with a Track 1 EPM
participant, then the EPM participant
must submit a clinician financial
arrangements list that determines the
Eligible Clinicians to be included on the
Affiliated Practitioner List for the
purposes of the Track 1 EPM that is an
Advanced APM. Therefore, a provider
group interested in their members
becoming Affiliated Practitioners with
an Advanced EPM Entity in an
Advanced APM could work with a
Track 1 EPM participant to enter into a
financial arrangement with that EPM
participant so that the members of the
provider group could be included in the
clinician financial arrangements list
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209
submitted by the Track 1 EPM
participant to CMS.
Comment: While commenters
appreciated the proposal to include two
tracks for EPM participants and CJR
participant hospitals, other commenters
made additional proposals to CMS to
help operationalize these tracks. A few
commenters urged CMS to go further to
align the EPMs and the CJR model with
the proposed Quality Payment Program
and configure Track 2 (the NonAdvanced APM) so that it could qualify
as a MIPS APM. In addition to the
request that CMS reconfigure Track 2,
commenters also proposed that Track 2
EPM participants must also submit a
clinician financial arrangements list, so
that Eligible Clinicians could receive
credit for Improvement Activities under
MIPS and/or satisfy criteria to be
considered participants in MIPS APMs,
for which the Quality Payment Program
applies unique scoring rules. One
commenter believes that the multiple
options due to the proposed tracks
increases the level of complexity and
administrative burden on the hospitals
for activities such as record keeping.
Response: We disagree that the
presence of two EPM tracks increases
administrative burden as we continue to
believe that the proposed tracks allow
flexibility for EPM participants to
choose to participate in an Advanced
APM. While a Track 1 EPM participant
needs to attest to CEHRT and submit a
clinician financial arrangements list to
meet the requirements for participation
in an Advanced APM and allow us to
operationalize the Track 1 EPM as an
Advanced APM, we do not believe that
these additional requirements create
significantly increased administrative
burden on the Track 1 EPM participant
versus a Track 2 EPM participant in
view of the documentation and record
access and retention requirements for all
EPM participants, which require EPM
participants to maintain a subset of that
list that constitutes the Eligible
Clinicians, nor that the requirements to
identify and maintain related lists
regarding collaboration agents and
downstream collaboration agents is a
substantial burden. Beyond these
additional activities for Track 1 EPM
participants, the policies of the EPMs
are the same for Track 1 and Track 2
EPM participants.
In addition, we disagree with the
suggestion by commenters that we add
the requirement for Track 2 EPM
participants to submit to CMS clinician
financial arrangements lists, information
that we did not propose to require Track
2 EPM participants to submit to us.
Submission of clinician financial
arrangements lists is not necessary for
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implementation of the Track 2 EPMs,
and Track 2 EPM participants do not
meet the definition of Advanced APM
Entities in the Quality Payment Program
final rule with comment period at
§ 414.1305 (81 FR 77537). To require
Track 2 EPM participants to submit
such a list would create unnecessary
additional administrative burden on
these participants. Furthermore, a Track
2 EPM does not meet the criteria of a
MIPS APM in § 414.1370(b) of the
Quality Payment Program final rule
with comment period. Specifically, the
MIPS APM criteria requires at least one
Eligible Clinician on a Participation List
for the APM, while currently all EPM
and CJR participants are hospitals.
Thus, the EPM and CJR Participation
Lists do not include Eligible Clinicians
and, therefore, a Track 2 EPM and the
Track 2 CJR model are not MIPS APMs.
As a result, EPM or CJR collaborators,
collaboration agents, and downstream
collaboration agents are not engaged
with Track 2 EPM participants or Track
2 CJR participant hospitals in a MIPS
APM. Therefore, we will not adopt a
requirement in regulation for Track 2
EPM participants or Track 2 CJR
participant hospitals to submit clinician
financial arrangements lists at this time.
We agree with commenters that we
should continue to consider whether
there are opportunities for additional
APMs, including episode payment
models, to become MIPS APMs. We will
continue to consider the balance in
models between the most appropriate,
streamlined model design for the
intended model participants to advance
the goals of the model and the
requirements for models to be MIPS
APMs or Advanced APMs as we strive
to create more opportunities for Eligible
Clinicians to participate in MIPS APMs
and Advanced APMs.
Comment: Commenters urged CMS to
consider reversing the proposed Track 1
and Track 2 designations to represent an
APM and Advanced APM, respectively,
or identifying an alternative naming
convention as the term ‘‘tracks’’ are
already used in the Shared Savings
Program.
Response: We appreciate the
perspective of the commenters but
believe that our proposed designations
of a Track 1 EPM as an Advanced APM
and a Track 2 EPM as a Non-Advanced
APM under the EPMs are
straightforward and appropriate for the
distinctions we make between
Advanced and Non-Advanced EPMs.
The track designations for the EPMs are
relevant to the EPM participants in the
specific track of the EPM and the
individuals and entities that have
financial arrangements under the EPMs.
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We never intend to refer solely to the
term Track 1 or Track 2 in the context
of the EPMs but always in combination
with the term EPM as a Track 1 EPM or
Track 2 EPM. Therefore, we do not
believe that Track 1 EPMs or Track 2
EPMs will be confused with tracks in
the Shared Savings Program. We will be
working closely with EPM participants
and other stakeholders during EPM
implementation to explain the various
requirements of the EPMs in general and
the tracks of the EPMs in particular.
Comment: Additional proposals were
submitted by commenters that
encouraged CMS to work further by
creating additional tracks, including a
MIPS APM track and accommodating
those that may wish to accept financial
risk sooner in order to qualify as an
Advanced APM. Commenters believe
CMS should continue to develop
pathways and provide assistance to
organizations who wish to develop or
become participants in Advanced
APMs; and to expand beyond the
current inpatient-based episode
payment model tracks to include not
only a physician-focus but also a focus
that meaningfully incorporates
additional roles and activities, for
example, specialty service providers,
rehabilitation therapy providers, BPCI
early adopters, home health care, and
transitional care.
Response: We appreciate the
suggestions of commenters. We respond
earlier in this section on requests for
additional MIPs APMs and for voluntary
election of early increased downside
risk to allow rural hospitals, SCHs,
MDHs, and RRCs with special stop-loss
limits under the EPMs to be in a Track
1 EPM at the same time as other EPM
participants without special stop-loss
limits under the EPM. We will continue
our efforts to develop pathways and
provide assistance to organizations who
wish to develop or become participants
in Advanced APMs. We refer the
commenters to section III.A.3 of this
final rule for additional considerations
for future EPMs.
Comment: Commenters expressed
appreciation for the proposed alignment
resulting from use of the same definition
of CEHRT across the EPM and Quality
Payment Program, and acknowledged
that CMS’ proposal to permit those EPM
participants who do not use CEHRT to
be in a different track of the EPM offers
appropriate flexibility. A few
commenters requested that CMS
consider using a process through the
Medicare EHR Incentive Program to
gather the attestations from the
hospitals.
Response: We appreciate the
recognition from commenters of CMS’
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efforts to utilize the flexibilities of the
Quality Payment Program for Eligible
Clinicians to link quality to payments
through meaningful participation in an
Advanced APM.
We also appreciate the suggestions by
the commenters about existing
processes and information CMS might
use to streamline CEHRT use attestation
for EPM participants in Track 1 EPMs.
We reiterate that EPM participants
choose to attest to CEHRT use and
submit a clinician financial
arrangements list beginning in
performance year 3 and, therefore, be a
Track 1 EPM participant (or elect
voluntary downside risk in performance
year 2, attest to CEHRT use, and submit
a clinician financial arrangements list,
and therefore, be a Track 1 EPM
participant beginning in performance
year 2), or choose not to attest to CEHRT
use and be a Track 2 EPM participant.
We will consider the feedback from
commenters on CEHRT attestation
methodologies as we develop the
operational information for EPM
participants about EPM processes and
procedures. We further note that CMS
and ONC also offer continued support
and guidance through educational
resources to support participating in
and reporting CEHRT use to CMS
models and programs, such as the EHR
Incentive Program. We will
communicate closely with EPM
participants about the form and manner
of attestation to CEHRT use for Track 1
EPMs early in the process of EPM
implementation.
Comment: Many commenters urged
CMS to consider the significant upfront
investments in health IT infrastructure
that providers must make to participate
and be successful in the Quality
Payment Program and EPMs or CJR
model, given that, as one commenter
stated, this investment exists even in
upside-only models. As a result, these
commenters recommended that CMS
consider permitting EPM participants to
be Advanced APM Entities in
performance year 1 and/or that entry
into Track 1 for EPM participants and
CJR participant hospitals begin as soon
as possible. Other commenters pointed
out the lack of resources/support for
Eligible Clinicians, such as therapists, to
adopt EHRs. The commenters believe
that Eligible Clinicians participating in
an Advanced APM where the Advanced
APM Entity is a hospital must also use
and attest to use of CEHRT, and further
stated that such a requirement would
put these professionals at a significant
disadvantage. To this end, a few
commenters requested that CMS clarify
whether the CEHRT requirement only
applies to the hospitals that are EPM
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participants and whether Eligible
Clinicians who have entered into
sharing arrangements as EPM
collaborators will potentially meet the
requirements to attest to use of CEHRT
for participating in an Advanced APM
under the Quality Payment Program.
Response: Like the commenters, we
appreciate the important role health IT
may play in meeting the goals of
Advanced APMs, including Track 1
EPMs, to improve the quality and
reduce the cost of care. As a result of the
Quality Payment Program final rule
with comment period (81 FR 28306), in
order for an APM to be considered an
Advanced APM, the APM must either
require that participating APM Entities
bear risk for monetary losses of a more
than nominal amount under the APM or
be a Medical Home Model expanded
under section 1115A(c) of the Act. As a
result of this final rule, a Track 1 CJR
participant hospital will be considered
to be participating in an Advanced
APM, and could qualify as an Advanced
APM Entity beginning in performance
year 2 for episodes ending on or after
January 1, 2017, the time at which CJR
participant hospitals would begin to
bear downside risk for excess actual CJR
episode spending above the qualityadjusted target price. Track 1 EPM
participants will be considered to be
participating in an Advanced APM, and
could qualify as an Advanced APM
Entity beginning in performance year 2
for episodes ending on or after January
1, 2018, the time at which EPM
participants in performance year 2
would begin to bear downside risk for
excess actual episode spending above
the quality-adjusted target price.
The Advanced APM criteria
established in the Quality Payment
Program final rule with comment period
at § 414.1415 (81 FR 77549) require that
for APMs in which hospitals are the
APM Entities, such as the EPMs, each
hospital must use CEHRT to document
and communicate clinical care to their
patients or other health care providers
to meet the CEHRT use requirement for
Advanced APMs. Thus, there is no
requirement that Eligible Clinicians who
would be included on an Affiliated
Practitioner List for Track 1 EPMs attest
to CEHRT use and, therefore, we will
not develop CEHRT attestation
processes for Eligible Clinicians in
Track 1 EPMs nor will we provide funds
to support EHR adoption. In addition,
we encourage participants to consider
utilizing any shared savings obtained as
part of the model to invest in health IT
infrastructure that can help EPM
collaborators improve care coordination
for beneficiaries.
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Final Decision: After consideration of
the public comments received, we are
finalizing the proposal to include in
§ 512.120(a) the CEHRT use and
attestation for EPM participants, with
modification to specify that the policy
applies for performance year 2 if the
EPM participant elects downside risk,
and to use the term ‘‘specified’’ for
consistency with CEHRT attestation in
other CMS programs.
For performance year 2 if the EPM
participant elects downside risk and for
performance years 3 through 5, EPM
participants choose either of the
following:
• CEHRT use. EPM participants attest
in a form and manner specified by CMS
to their use of CEHRT as defined in
§ 414.1305 of this chapter to document
and communicate clinical care with
patients and other health professionals.
• No CEHRT use. EPM participants
do not attest in a form and manner
specified by CMS to their use of CEHRT
as defined in § 414.1305 of this chapter
to document and communicate clinical
care with patients and other health
professionals.
c. Clinician Financial Arrangements
Lists Under the EPMs
In order for CMS to make
determinations as to eligible clinicians
who could be considered QPs based on
services furnished under the EPMs (to
the extent the models are determined to
be Advanced APMs), we require
accurate information about eligible
clinicians who enter into financial
arrangements under the Track 1 EPMs
under which the Affiliated Practitioners
support the participants’ cost or quality
goals as discussed in section III.I. of this
final rule. We note that eligible
clinicians could be EPM collaborators
engaged in sharing arrangements with
an EPM participant; PGP members who
are collaboration agents engaged in
distribution arrangements with a PGP
that is an EPM collaborator; or PGP
members who are downstream
collaboration agents engaged in
downstream distribution arrangements
with a PGP that is also an ACO
participant in an ACO that is an EPM
collaborator. These terms as they apply
to individuals and entities with
financial arrangements under the EPMs
are discussed in section III.I. of this final
rule. A list of physicians and
nonphysician practitioners in one of
these three types of arrangements could
be considered an Affiliated Practitioner
List of eligible clinicians who are
affiliated with and support the
Advanced APM Entity in its
participation in the Advanced APM as
proposed in the Quality Payment
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211
Program proposed rule. Therefore, this
list could be used to make
determinations of who would be
considered for a QP determination
based on services furnished under the
EPMs (81 FR 28320).
Thus, we proposed that each EPM
participant that chooses to meet and
attest to the CEHRT use requirement
must submit to CMS a clinician
financial arrangements list in a form and
manner specified by CMS on a no more
than quarterly basis. The list must
include the following information for
the period of the EPM performance year
specified by CMS:
• For each EPM collaborator who is a
physician, nonphysician practitioner, or
provider of outpatient therapy services
during the period of the EPM
performance year specified by CMS:
++ The name, tax identification
number (TIN), and national provider
identifier (NPI) of the EPM collaborator.
++ The start date and, if applicable,
end date, for the sharing arrangement
between the EPM participant and the
EPM collaborator.
• For each collaboration agent who is
a physician or nonphysician
practitioner of a PGP that is an EPM
collaborator during the period of the
EPM performance year specified by
CMS:
++ The TIN of the PGP that is the
EPM collaborator, and the name and
NPI of the physician or nonphysician
practitioner.
++ The start date and, if applicable,
end date, for the distribution
arrangement between the EPM
collaborator that is a PGP and the
physician or nonphysician practitioner
who is a PGP member.
• For each downstream collaboration
agent who is a physician or
nonphysician practitioner member of a
PGP that is also an ACO participant in
an ACO that is an EPM collaborator
during the period of the EPM
performance year specified by CMS:
++ The TIN of the PGP that is the
ACO participant, and the name and NPI
of the physician or nonphysician
practitioner.
++ The start date and, if applicable,
end date, for the downstream
distribution arrangement between the
collaboration agent that is both PGP and
an ACO participant and the physician or
nonphysician practitioner who is a PGP
member.
• If there are no individuals that meet
the requirements to be reported as EPM
collaborators, collaboration agents, or
downstream collaboration agents, the
EPM participant must attest in a form
and manner required by CMS that there
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are no individuals to report on the
clinician financial arrangements list.
As discussed in the Quality Payment
program proposed rule, those
physicians or nonphysician
practitioners who are included on the
Affiliated Practitioner List as of
December 31 of a performance period
would be assessed to determine whether
they qualify for APM Incentive
Payments (81 FR 28320). The Quality
Payment Program final rule with
comment period (81 FR 77444) modified
this process to identify eligible
clinicians on the Affiliated Practitioner
List for QP determinations at any one of
three snapshots. The first snapshot will
be on March 31 of the QP Performance
Period, the second snapshot will be on
June 30 of the QP Performance Period,
and the third snapshot will be on
August 31, which will be the last day of
the QP Performance Period.
We noted that while the required
submission of this information might
create some additional administrative
requirements for certain EPM
participants, we expected that EPM
participants in a Track 1 EPM could
modify their contractual relationships
with their EPM collaborators and,
correspondingly, require those EPM
collaborators to include similar
requirements in their contracts with
collaboration agents and in the contracts
of collaboration agents with
downstream collaboration agents.
The proposal for the submission of a
clinician financial arrangements list by
EPM participants that meet and attest to
the CEHRT use requirement for the EPM
was included in § 512.120(b). We sought
comments on the proposal for
submission of this information. We were
especially interested in comments about
approaches to information submission,
including the periodicity and method of
submission to CMS that would
minimize the reporting burden on EPM
participants while providing CMS with
sufficient information about eligible
clinicians in order to facilitate QP
determinations to the extent EPMs are
considered Advanced APMs.
The following is a summary of the
comments received and our responses.
Comment: While some commenters
supported CMS’ plans to recognize
Eligible Clinicians who participate in
APMs from an Affiliated Practitioner
List, others raised concerns about the
means to identify Eligible Clinicians as
Affiliated Practitioners of Advanced
APMs. A few commenters disagreed
with the development of an Affiliated
Practitioner List from a clinician
financial arrangements list. Some
commenters believe that to assume risktaking threatens the financial viability of
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most physician-led entities. Other
commenters expressed concern that the
definition of such an agreement suggests
that risk must be shifted to the
clinicians to achieve QP status. These
commenters agreed that the clinicians
must support the cost or quality goals of
the Advanced APM, but do not believe
that to be included on the Affiliated
Practitioner List the clinician must take
risk. Other commenters assumed that
Eligible Clinicians must assume risk
under the EPM to qualify for QP
incentive payment under the Quality
Payment Program, and suggested that
CMS base the risk requirements on
physician practice or APM organization
revenues. One commenter noted that
not all physicians bound contractually
to the requirements of the EPMs would
be captured on clinician financial
arrangements lists, as hospitals may
have agreements with their employed
physicians that cascade the
programmatic requirements of the
EPMs, but do not necessarily alter their
underlying compensation or include
gainsharing/risk-sharing/internal cost
savings parameters. Instead,
commenters offered alternatives to the
submission of clinician financial
arrangements lists, including such
proposals as modeling the EPM along
the lines of the Medical Home Model
standard and using claims data to
identify and attribute Eligible Clinicians
to populate the EPM Affiliated
Practitioner List for the purposes of the
Quality Payment Program.
Response: Under Track 1 EPMs, the
Advanced APM Entity is always a
hospital, and no physicians are EPM
participants. As we discussed in the
Quality Payment Program final rule
with comment period (81 FR 77442), for
Advanced APMs, such as episode
payment models, in which there are
some Advanced APM Entities that
include Eligible Clinicians on a
Participation List and other Advanced
APM Entities that identify Eligible
Clinicians only on an Affiliated
Practitioner List, we will identify
Eligible Clinicians for QP determination
based on the composition of the
Advanced APM Entity: (1) For
Advanced APM Entities that include
and identify Eligible Clinicians on a
Participation List, that Participation List
will be used to define the Advanced
APM Entity group, regardless of
whether or not there is also an Affiliated
Practitioner List or other list of Eligible
Clinicians, and those Eligible Clinicians
will be assessed as a group; (2) for
Advanced APM Entities that do not
include and identify Eligible Clinicians
on a Participation List and there is an
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Affiliated Practitioner List that
identifies Eligible Clinicians, that
Affiliated Practitioner List will be used
to identify the Eligible Clinicians for
purposes of QP determinations, and
those Eligible Clinicians will be
assessed individually. Track 1 EPMs fall
into the second category because the
EPMs do not include and identify
Eligible Clinicians on a Participation
List so, therefore, we will use an
Affiliated Practitioner List for Track 1
EPMs to identify Eligible Clinicians for
purposes of QP determinations.
In the Quality Payment Program final
rule with comment period in § 414.1305
(81 FR 77537), an Affiliated Practitioner
is defined as an Eligible Clinician
identified by a unique APM participant
identifier on a CMS-maintained list who
has a contractual relationship with the
Advanced APM Entity for the purposes
of supporting the Advanced APM
Entity’s quality or cost goals under the
Advanced APM. Furthermore, in the
Quality Payment Program final rule
with comment period (81 FR 77440), we
provided the example that an Affiliated
Practitioner List comprised of
gainsharers under an APM might
include Eligible Clinicians whereas a
Participation List may only include
hospitals. We believe this example
applies to the Track 1 EPMs.
We believe that constructing the
Affiliated Practitioner List from the list
of clinicians with financial
arrangements submitted by each EPM
participant that chooses to use and
attest to use of CEHRT allows us to
appropriately identify clinicians for the
Affiliated Practitioner List under the
EPMs. All of these clinicians have
contractual relationships under the
EPMs, and because the determination of
the amount of gainsharing payment,
distribution payment, or downstream
distribution payment under their
arrangement is required to be
substantially based on quality of care
and the provision of EPM activities
(activities related to promoting
accountability for the quality, cost, and
overall care for EPM beneficiaries,
including managing and coordinating
care; encouraging investment in
infrastructure, enabling technologies,
and redesigned care processes for high
quality and efficient service delivery;
the provision of items and services
during an EPM episode in a manner that
reduces costs and improves quality; or
carrying out any other obligation or duty
under the EPM), we believe that their
contractual relationship supports the
cost and quality goals of the Track 1
EPM participant and, therefore, that
they meet the definition of Affiliated
Practitioner.
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Regarding those commenters who
were concerned that constructing the
Affiliated Practitioner List in this way
would shift the financial risk of the
APM Entity (Track 1 EPM participant)
to the clinician in order for the clinician
to be eligible for a QP determination, we
want to emphasize that distribution
arrangements and downstream
distribution arrangements allow only
distribution of payments that may be
comprised of hospital internal cost
savings and/or reconciliation payments
for savings beyond the quality-adjusted
target price under the EPMs, without
allowing the collaboration agent or
downstream collaboration agents to
assume any downside risk. Sharing
arrangements may include the sharing
of upside and downside risk with EPM
collaborators, but we note that in our
experience with other bundled payment
models, sharing with individual
physicians has generally been upside
risk only. We understand that the
Quality Payment Program final rule
with comment period does not require
that an Affiliated Practitioner take on
upside or downside risk to be eligible
for a QP determination, while our
proposed methodology to identify
Eligible Clinicians for the EPM
Affiliated Practitioner List requires
those clinicians to have a financial
arrangement under the EPM. However,
we based our proposal on the most
streamlined approach to identifying
Eligible Clinicians under the Track 1
EPM who meet the definition of
Affiliated Practitioner to build off
policies that apply across the EPMs in
general, in order to limit any additional
administrative burden on EPM
participants for Track 1 participation.
Under the EPMs, the only contractual
relationships for which we specify
requirements as part of the model
design for all participants and which
ensure the Eligible Clinicians meet the
Affiliated Practitioner definition are
financial arrangements. Therefore,
under our proposal for identifying
Eligible Clinicians for each EPM
participant that chooses to use and
attest to use of CEHRT we would use the
clinician financial arrangements list
submitted to us to construct the EPM
Affiliated Practitioner List.
In terms of constructing the Affiliated
Practitioner List from claims data based
on those clinicians furnishing services
to EPM beneficiaries, we would not be
able to know if such physicians,
nonphysician practitioners, or therapists
had a contractual relationship with the
EPM participant to support the EPM
participant’s cost or quality goals under
the Track 1 EPM (the requirement for
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Affiliated Practitioners), so we are
unable to adopt this suggestion by the
commenters. Moreover, we believe we
can only know the information about
contractual relationships between an
EPM participant and an Eligible
Clinician if the EPM participant reports
this to us as we do not otherwise require
such reporting under the EPMs.
We understand that there are
circumstances where an EPM
participant might want to enter into a
contract with a clinician to support the
cost or quality goals of the EPM. At this
point, EPM participants that choose to
use and attest to use of CEHRT may not
report these clinicians to us through the
clinician financial arrangements list for
inclusion on the Affiliated Practitioner
List because we made no specific
proposals about what such contractual
relationships would entail. As discussed
previously in this section, MedPAC
expressed concern that the EPMs
contemplate large, loosely connected
groups of clinicians who may have very
little involvement with the beneficiaries
in EPMs and hence have little reason to
change their practice patterns or reduce
inappropriate episodes. Thus, in order
to identify the circumstances in which
Eligible Clinicians without financial
arrangements under a Track 1 EPM
participant could meet the definition of
Affiliated Practitioner, we will further
consider the scenarios raised by the
commenters and intend to propose an
additional methodology for EPM
participants to identify other Eligible
Clinicians who may be included on the
Affiliated Practitioner List in future
rulemaking. This additional
methodology would be targeted for
implementation in performance year 3
when downside risk for all participants
under the EPMs applies.
We are finalizing our proposal to
construct the EPM’s Affiliated
Practitioner List from the clinician
financial arrangements lists submitted
by those EPM participants that attest to
CEHRT use.
Comment: Several commenters urged
CMS to identify Eligible Clinicians
through a streamlined reporting process,
and ensure that a minimum burden is
applied to EPM participants when
providing lists. To this end, the
commenters proposed alterations to the
proposed contents of the clinician
financial arrangements list, including
the recommendation that CMS require
EPM participants or CJR participant
hospitals to submit an electronic form
listing all collaborators, collaboration
agents, and downstream collaboration
agents and their tax identification
numbers (TIN) on a yearly basis.
Finally, some commenters requested
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213
that CMS enable more frequent updates
to the list.
Response: We appreciate the interest
of the commenters in creating the
minimal necessary reporting burden on
EPM participants and CJR participant
hospitals. For those EPM participants
that choose to use and attest to use of
CEHRT and are required to submit a
clinician financial arrangements list, we
agree with the commenters that the most
streamlined process that provides us
with the timely, necessary information
is desirable. We proposed that the
submission must occur on a no more
than quarterly basis and we continue to
believe that this timing is the most
appropriate. It establishes the maximum
required submission burden on EPM
participants of quarterly in view of the
three planned ‘‘snapshots’’ of the
Affiliated Practitioner List each year (81
FR 77444) to capture timely new
Affiliated Practitioners that were not
previously identified for the EPM
participant, while allowing us the
flexibility to determine a lower
reporting periodicity for EPM
participants whose list does not change
during the EPM performance year. We
also note that while under our proposal
we could not require submission of the
list more than quarterly, the submission
timing requirement does not preclude
us from accepting more frequent than
quarterly voluntary updates to the list if
EPM participants have more frequent
changes to their list of clinicians with
financial arrangements under the EPM.
We proposed that Eligible Clinicians
on the clinician financial arrangements
list that we would use to construct an
Affiliated Practitioner List would be
EPM collaborators who are physicians,
nonphysician practitioners, and
providers of outpatient therapy services
engaged in sharing arrangements with
an EPM participant; PGP members who
are physicians and nonphysician
practitioners who are collaboration
agents engaged in distribution
arrangements with a PGP that is an EPM
collaborator; and PGP members who are
physicians and nonphysician
practitioners who are downstream
collaboration agents engaged in
downstream distribution arrangements
with a PGP that is also an ACO
participant in an ACO that is an EPM
collaborator. To reflect our final policies
for financial arrangements discussed in
section III.I. of this final rule, and taking
into consideration the issues discussed
later in this section, we are revising the
categories of individuals who qualify as
Eligible Clinicians and clarifying the
information to be reported on the
clinician financial arrangements list in
this final rule. It was our intention in
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the proposed rule and our policy in this
final rule that the full complement of
physicians, nonphysician practitioners,
and therapists who have financial
arrangements under the EPMs be
reported on the EPM participant’s
clinician financial arrangements list. We
see no reason to treat physicians,
nonphysician practitioners, or therapists
differently for purposes of being
considered Eligible Clinicians based on
their specific type of financial
arrangement under the EPM as the
requirements for each type of
contractual relationship are aligned
with the cost and quality goals of the
EPM.
We proposed that providers of
outpatient therapy services that are EPM
collaborators be reported on the
clinician financial arrangements list,
although the term provider of outpatient
therapy services also encompassed
entities that were not individual
therapists and that, therefore, could not
be Eligible Clinicians. However, as
discussed in section III.I.3. of this final
rule we are adopting the specific term
therapist in private practice for those
individual therapists who are EPM
collaborators. Thus, we are refining the
reporting of EPM collaborators on the
clinician financial arrangements list to
include physicians, nonphysician
practitioners, and therapists in private
practice to focus on individual
therapists in private practice, who may
be Eligible Clinicians under the
provisions of the Quality Payment
Program final rule with comment
period, rather than all providers of
outpatient therapy services.
In addition, our proposal did not
identify as Eligible Clinicians therapists
who are collaboration agents and
downstream collaboration agents as
members of PGPs or ACO providers/
suppliers who are physicians,
nonphysician practitioners, or therapists
who are collaboration agents. While we
did not propose that therapists who are
collaboration agents or downstream
collaboration agents as members of
PGPs be reported on the clinician
financial arrangements list, we did
propose that a therapist could be a PGP
member and we note that therapists can
also be Eligible Clinicians under the
provisions of the Quality Payment
Program final rule with comment
period. We also did not identify in our
proposal that physicians, nonphysician
practitioners, and therapists who are
collaboration agents and ACO
providers/suppliers in an ACO that is an
EPM collaborator would be Eligible
Clinicians on the clinician financial
arrangements list. This was an oversight
as we intended to include all
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collaboration agents who are physicians,
nonphysician practitioners, and
therapists on the clinician financial
arrangements list, regardless of the
entity that is their associated EPM
collaborator. Moreover, our proposal did
not take into account the provisions of
this final rule that allow NPPGPs and
TGPs to be EPM collaborators or
collaboration agents and, therefore, we
did not propose that the nonphysician
practitioners and therapists who have
financial arrangements with these
entities would also be Eligible
Clinicians on the clinician financial
arrangements list. Therefore, in this
final rule we are clarifying that all
physicians, nonphysician practitioners,
and therapists who are collaboration
agents or downstream collaboration
agents are reported on the clinician
financial arrangements list, without
regard to the type of entity that is the
associated party with which the
collaboration agent or downstream
collaboration agent has his or her
distribution arrangement or downstream
distribution arrangement. We note that
we proposed to require that physicians
and nonphysician practitioners who are
members of a PGP that is an EPM
collaborator or members of a PGP that
is also an ACO participant in an ACO
that is an EPM collaborator and that
have a distribution arrangement or
downstream distribution arrangement,
respectively, with the PGP be reported
on the list. Therefore, we believe there
is only a small additional burden on
EPM participants to report on the list all
collaboration agents or downstream
collaboration agents that are physicians,
nonphysician practitioners, or therapists
with distribution arrangements or
downstream distribution arrangements,
in order to ensure that the clinician
financial arrangements list reports all
Eligible Clinicians with financial
arrangements under the EPM.
We proposed that the information to
be reported on the clinician financial
arrangements list would include the
name and NPI and, in some cases the
TIN, of the Eligible Clinician with the
financial arrangement under the EPM.
We also proposed to collect the TIN of
the PGP that is an EPM collaborator or
collaboration agent and with which the
physician or nonphysician practitioner
reported on the list has a financial
relationship, which would have
provided us with information for
purposes of monitoring and compliance
on some of the entities related to the
contracts of those physicians or
nonphysician practitioners under the
EPM. While we did not propose to
similarly require information be
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submitted on the ACO that would be an
EPM collaborator for those Eligible
Clinicians that are collaboration agents
or downstream collaboration agents, in
this final rule, we are clarifying that the
name and NPI of the entity (that is, the
PGP, NPPGP, TGP, or ACO) that is an
EPM collaborator and the entity (that is,
the PGP, NPPGP, or TGP) that is a
collaboration agent, if applicable, must
also be reported on the clinician
financial arrangements list for each
Eligible Clinician who is a collaboration
agent or downstream collaboration
agent. Thus, the final requirements
provide us with sufficient information
to monitor the full series of related
financial relationships under the EPM
that result in the reporting of an Eligible
Clinician on the clinician financial
arrangements list. Because we do not
expect that EPM participants will enter
into sharing arrangements with many
ACOs, due to the limited number of
ACOs to which beneficiaries are
typically assigned in a given geographic
area, we do not believe that requiring
the reporting of the name and TIN of the
ACO that is an EPM collaborator is a
significant additional burden on the
EPM participant submitting the list to
CMS.
In summary, based on the previous
discussion, for purposes of clarity and
consistency we are streamlining the
requirements for reporting information
on the clinician financial arrangements
list. For each physician, nonphysician
practitioner, or therapist that is an EPM
collaborator, collaboration agent, or
downstream collaboration agent, we
require the name, TIN, and NPI to be
reported, in addition to the start date
and, if applicable, end date, for the
individual’s sharing arrangement,
distribution arrangement, or
downstream distribution arrangement.
We further require for a collaboration
agent that the name and TIN of the EPM
collaborator be reported and that for a
downstream collaboration agent the
name and TIN of the EPM collaborator
and the name and TIN of the
collaboration agent be reported.
We will be working closely with EPM
participants on the format and process
for submission of clinician financial
arrangements lists, including the
potential for electronic submission of
the required information, during the
early phases of EPM implementation,
seeking to ensure that the format and
process is as streamlined as possible for
EPM participants that choose to use and
attest to use of CEHRT, while meeting
CMS’ need to maintain an EPM
Affiliated Practitioner List that can be
used to identify Eligible Clinicians for a
QP determination.
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Final Decision: After consideration of
the public comments received, we are
finalizing the proposal in § 512.120(b)
for EPM participants that use and attest
to use of CEHRT to submit to CMS a
clinician financial arrangements list on
a no more than quarterly basis, with
modification to include on that list
information on all physicians,
nonphysician practitioners, and
therapists with financial arrangements
under the EPM and, if applicable,
identifying information for the related
parties with sharing arrangements,
distribution arrangements, and
downstream distribution arrangements
under the EPM as finalized in section
III.I. of this final rule.
Each EPM participant that chooses
CEHRT use must submit to CMS a
clinician financial arrangements list in a
form and manner specified by CMS on
a no more than quarterly basis. The list
must include the following information
on individuals and entities for the
period of the EPM performance year
specified by CMS:
• EPM collaborators. For each
physician, nonphysician practitioner, or
therapist in private practice who is an
EPM collaborator during the period of
the EPM performance year specified by
CMS:
++ The name, TIN, and NPI of the
EPM collaborator.
++ The start date and, if applicable,
end date, for the sharing arrangement
between the EPM participant and the
EPM collaborator.
Collaboration agents. For each
physician, nonphysician practitioner, or
therapist who is a collaboration agent
during the period of the EPM
performance year specified by CMS:
++ The name and TIN of the EPM
collaborator and the name, TIN, and NPI
of the collaboration agent.
++ The start date and, if applicable,
end date, for the distribution
arrangement between the EPM
collaborator and the collaboration agent.
• Downstream collaboration agents.
For each physician, nonphysician
practitioner, or therapist who is a
downstream collaboration agent during
the period of the EPM performance year
specified by CMS:
++ The name and TIN of the EPM
collaborator, the name and TIN of the
collaboration agent and the name, TIN,
and NPI of the downstream
collaboration agent.
++ The start date and, if applicable,
end date, for the downstream
distribution arrangement between the
collaboration agent and the downstream
collaboration agent
• Attestation to no individuals. If
there are no individuals that meet the
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requirements to be reported, as specified
in paragraphs (b)(1) through (3) of this
section, the EPM participant must attest
in a form and manner required by CMS
that there are no individuals to report
on the clinician financial arrangements
list.
d. Documentation Requirements
For each EPM participant that chooses
to meet and attest to CEHRT use, we
proposed that the EPM participant must
maintain documentation of their
attestation to CEHRT use and clinician
financial arrangements lists submitted
to CMS. These documents would be
necessary to assess the completeness
and accuracy of materials submitted by
an EPM participant in the Track 1 EPM
and to facilitate monitoring and audits.
For the same reason, we further
proposed that the EPM participant must
retain and provide access to the
required documentation in accordance
with § 512.110.
The proposal for documentation of
attestation to CEHRT use and clinician
financial arrangements lists submitted
to CMS was included in § 512.120(c).
We sought comment on this proposal for
required documentation.
Final Decision: We did not receive
comments pertaining to § 512.120(c).
Therefore, we are finalizing the
proposal, without modification, for EPM
participant documentation of attestation
to CEHRT use and clinician financial
arrangements lists submitted to CMS.
The following documentation
requirements apply to EPM participants
choosing to use and attest to use of
CEHRT.
• Each EPM participant that chooses
CEHRT use must maintain
documentation of their attestation to
CEHRT use and clinician financial
arrangements lists.
• The EPM participant must retain
and provide access to the required
documentation in accordance with
§ 512.110.
3. Future Directions for Episode
Payment Models
a. Refinements to the BPCI Initiative
Models
The BPCI initiative Models 2, 3, and
4 would not currently qualify as
Advanced APMs based on two of the
Advanced APM criteria in the Quality
Payment Program (QPP) final rule with
comment period (81 FR 77008),
payment based on quality measures and
CEHRT use. Specifically, BPCI
participants are not currently required
to use CEHRT, and although CMS
examines the quality of episode care in
the BPCI evaluation, BPCI episode
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215
payments are not specifically tied to
quality performance. Instead, BPCI
episode payments are based solely on
episode spending performance,
although we expect that reductions in
spending would generally be linked to
improved quality through reductions in
hospital readmissions and
complications. However, building on
the BPCI initiative, the Innovation
Center intends to implement new
bundled payment model for CY 2018
where the model(s) would be designed
to meet the criteria to be an Advanced
APM.
The following is a summary of the
comments received and our responses.
Comment: A number of commenters
expressed support for a new voluntary
bundled payment model in CY 2018.
Specifically, commenters expected any
new design to include the ability of the
BPCI Initiative to qualify as meeting the
requirements for an advanced APM
under the QPP. Commenters also
requested that data be provided by CMS
on a monthly basis with quarterly
reconciliation reports to allow
participants to meaningfully engage in
reforms to the delivery of health care.
Consistent with the existing BPCI
model, CMS was encouraged by
commenters to continue assigning
precedence to self-selected model
participants over participants in
assigned models. Additional
recommended features included
financial stop-gain and stop-loss limits
and the incorporation of composite
quality score similar to that used in the
CJR model. Other specific features
included recommendations for
additional post-acute care bundles and
the exclusion of ACOs.
More broadly, CMS received several
recommendations calling for increased
stakeholder input in the design,
implementation, and evaluation of new
voluntary bundled payment models.
Commenters requested that hospitals
currently participating in BPCI should
be allowed to test additional episodes,
and new hospitals should be allowed to
enter the program. While ranging in
degree, most commenters highlighted a
need for input from external clinical
experts in addition to consumers,
patients, and purchasers as well as
institutional stakeholders such as QIOs.
To better align with other available EHR
incentive payments, several commenters
stated a need for future bundled
payment models to include CEHRT
measures.
Response: We appreciate these
considerations as we design a new
voluntary bundled payment model.
Comment: A few commenters
suggested that since post-acute care
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providers are the predominant care
provider for LEJR patients, post-acute
care should play a more prominent role
in the BPCI initiative.
Response: CMS thanks the
commenters for this suggestion.
Comment: One commenter
recommended CMS use a consistent
policy to address overlap of all
Medicare bundled payment initiatives
and population-based payment models.
The commenter raised concerns with
respect to overlap of beneficiaries in the
EPMs, CJR model, and BPCI initiative,
and suggested that, in a future BPCI
initiative, beneficiaries should be
excluded from bundled payments
unless a collaborative agreement exists
between an ACO and a hospital that is
not a participant in that ACO. The
commenter also had concerns for the
extent to which Medicare beneficiaries
benefit from allowing private for-profit
awardee conveners to absorb the risk for
providers. Therefore, the commenter
recommended also that CMS exclude
for-profit risk-taking conveners which
do not provide patient care.
Response: We acknowledge and
appreciate all comments, and
specifically recognize the shared
interest in improving Medicare for its
beneficiaries.
Comment: A few commenters
requested that CMS take into
consideration several additional pricing
flexibilities and regulatory waivers for a
new voluntary bundled payment model.
Specifically, commenters believed that
reducing costs and increasing shared
savings could be difficult, therefore,
participants should have the flexibility
in a new voluntary bundled payment
model to modify practice or utilization
patterns by reducing length of stay or
intensity of services. Commenters stated
that the next iteration of BPCI should
feature program elements such as caps
on total losses that gradually increase
over time, variable discounts based on
quality scoring, and elimination of
financial responsibility for payments
above a threshold. Other commenters
proposed that CMS adopt a method of
population risk stratification, as this
could provide incentive to providers by
reimbursing more for greater
comorbidities. Finally, in setting the
bundled payment amounts, commenters
recommended that CMS incorporate
clinical practice guidelines and
appropriate use criteria to ensure that
patients are not receiving inadequate
care. One commenter suggested that
CMS provide patient navigators to
Medicare beneficiaries receiving items
or services paid under an EPM.
Additionally, the regulatory waivers
requested included the home health
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homebound requirement, the IRF 60
percent rule, the IRF 3-hour therapy
intensity rule, and the LTCH 25 day
average length of stay restriction. One
commenter suggested that occupational
therapy be recognized as a ‘‘qualifying
service’’ under the Medicare home
health care benefit and occupational
therapists could, in future APMs be
permitted to open ‘therapy only’ cases if
occupational therapy is in the
physician’s order.
Response: We recognize commenters’
requests for consideration of additional
flexibilities in care redesign efforts as
part of a new voluntary bundled
payment model.
Final Decision: As we did not propose
changes to the BPCI initiative in the
proposed rule, we do not have any
changes to finalize in this final rule.
b. Potential Future Condition-Specific
Episode Payment Models
In the context of our proposal for the
AMI and CABG models that include
beneficiaries with CAD who experience
an acute event or a major surgical
procedure, we sought comment on
model design features for potential
future condition-specific episode
payment models that could focus on an
acute event or procedure or longer-term
care management, including other
models for beneficiaries with CAD that
may differ from the design of the EPMs
proposed in the proposed rule (81 FR
50794). We believe such future models
may have the potential to be Advanced
APMs that emphasize outpatient care
and, like the proposed AMI and CABG
models, could incentivize the alignment
of physicians and other eligible
professionals participating in the
Advanced APM through accountability
for the costs and quality of care. Such
condition-specific episode payment
models may provide for a transition
from hospital-led EPMs to physician-led
accountability for episode quality and
costs, especially given the importance of
care management over long periods of
time for beneficiaries with many
chronic conditions.
We requested that commenters
provide specific information regarding
all relevant issues for potential future
condition-specific episode payment
models, including identifying
beneficiaries for the model; including
services in the episode definition;
beginning and ending episodes; pricing
episodes, including risk-adjustment;
designating the accountable entity for
the quality and cost of the episode,
including the role of physician-led
opportunities; sharing of responsibility
for quality and spending between
primary care providers, specialty
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physicians, and other health care
professionals; incentivizing the
engagement of physicians and other
providers and suppliers in episode care;
measuring quality and including quality
performance and improvement in the
payment methodology; interfacing with
other CMS models and programs
responsible for population health and
costs, such as ACOs and Primary Care
Medical Homes (PCMHs); other
considerations specific to identifying
future models as Advanced APMs; and
any other issues of importance for the
design of such an EPM.
The following is a summary of the
comments received and our responses.
Comment: A few commenters
requested that in future conditionspecific EPMs, CMS should consider
episodes beginning before a
hospitalization, as one commenter
believed that this earlier future EPM
episode trigger would engage more
meaningful shared care planning. Other
commenters stated that future
condition-specific EPMs should be
based on episodes that are not
necessarily tied to a hospital stay. One
commenter noted that there is a great
degree of variation in cardiac care
beyond the two proposed EPM episodes.
For example, the commenter noted
regional differences in ambulatory and
hospital care for heart failure, which the
commenter did not believe are
explained by disease severity and
therefore the commenter suggested such
additional cardiac care may become a
favorable population-based payment
model. Several commenters provided
recommendations and perspectives on
future condition-specific episode
payment models based on MS–DRGs,
including examples such as sepsis.
However, other commenters suggested
the alternative to use the Episode
Grouper for Medicare (EGM) for future
condition-specific EPMs. The
framework for the EGM involves
organizing administrative claims data
into episodes-of-care, or simply
episodes, which are sets of services
provided to care for an illness or injury
during a defined period of time. One
commenter stated that the EGM
organizes Medicare beneficiary total
cost around two constructs—episodes
for specific conditions and episodes for
specific treatments. For conditionspecific episodes, each episode would
be defined by one or more diagnosis
codes, however, treatment episodes
would be defined by a combination of
procedure and diagnosis codes. A few
commenters provided specific diagnoses
that could be attributable to organized
future EPMs, including but not limited
to gastroesophageal reflux disease and
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obesity. Another commenter disagreed,
stating it is inappropriate to expand the
current EPM approach to future
treatment of chronic conditions because,
the commenter suggested, a bigger
opportunity for improving quality and
achieving savings is avoiding
unnecessary episodes and events. In
turn, the costs of treatment episodes
could be packaged into the costs of
managing underlying condition
episodes. Commenters stated further
that the EGM should also examine
utilization patterns, perform
comparative analyses for similar
conditions, and identify careimprovement opportunities. As such,
commenters suggested that the EGM
would be better suited to pricing and
resource allocation while identifying
chronic conditions.
Response: We thank the commenters
for their suggestion.
Comment: Another commenter,
referencing the Program of All-Inclusive
Care for the Elderly (PACE),
recommended that CMS consider a
comprehensive episode payment model
for services for medical care that could
be tied with private payment,
enrollment in available community
services, or an arrangement with
Medicaid. Beneficiaries requiring daily
help or supervision would serve as a
qualifying condition, which could
extend for varying durations.
Response: We appreciate the
commenter’s support for PACE and will
work internally to incorporate lessons
learned from existing programs in the
proposal of future condition-specific
EPMs.
Comment: Highlighting the efforts of
national medical specialty societies,
several commenters provided several
condition-specific EPMs which may be
successful in reducing emergency
department visits, hospital admissions,
and excessive testing. Specifically,
several commenters gave such examples
as coronary artery disease, headache,
epilepsy, asthma, opioid use disorder,
diabetes, and specialty medical home.
Of note, commenters stated that CMS
should give additional consideration to
defined episode triggers. For example,
some commenters suggested that each
new episode should be accompanied by
time criteria and have a unique but
expected time course. These efforts,
commenters suggested, might further
result in disease prevention, reduced
exacerbations, and improved care.
Response: We appreciate commenters’
eagerness to participate in this dialogue
and to be a part of transforming care.
Comment: Commenters believed that
CMS should view organized provider
models as qualifying for condition-
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specific EPMs. Other commenters
suggested that CMS simply include
more types of participants, including
examples such as ACOs and PCMHs.
Still, others commented that
participation in future conditionspecific EPMs be limited to those
organizations that are fully committed
to coordinated care planning, shared
decision-making, comparative quality
information, chronic disease
management, transparent payments and
care transition support. As an
alternative approach to considering
future condition-specific EPMs,
MedPAC suggested that CMS consider
allowing hospitals to share savings with
physicians as a way to focus doctors on
reducing the cost of the inpatient stay.
Response: We acknowledge and
appreciate the suggestion to incorporate
more participant types in future
condition-specific EPMs.
Comment: Additionally, MedPAC
recommended that for conditions that
are not promising for bundled
payments, CMS could focus on an array
of other strategies to support providers
in lowering costs while improving
patient outcomes. For example, the
Medicare spending per beneficiary
(MSPB) measure in the hospital valuebased purchasing (VBP) program
encourages lower spending and
improved care coordination. Alteration
of the ‘‘weight’’ of the MSPB could be
increased to further incentivize
hospitals to reduce spending.
Furthermore, MedPAC noted that the
hospital readmission policy already
encourages hospitals to avoid
readmissions for AMIs and CABGs. To
increase the pressure to reduce
readmissions, it was suggested that CMS
move forward with readmission policies
in all sectors to increase the penalties
for providers with high risk- adjusted
potentially avoidable readmission rates.
Response: We appreciate any
recommendations MedPAC can provide
and will continue to collaborate with
stakeholders to develop additional
means to improve patient outcome
measures. Furthermore, we will work
internally to find additional alignment
between Innovation Center programs
and Medicare payment policies.
Comment: One commenter
recommended consideration of an
episode that should address behavioral
health integration with primary care.
The commenter suggested that
guidelines which embed behavioral
health measurements into any care
setting would equip providers with
quantification necessary to impact both
physical and mental health of patients.
Response: We appreciate the
commenter’s proposal. We appreciate
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the many comments received regarding
the request for comment and while we
did not propose any changes to this
section of the final rule, we intend to
continually seek to connect those
interested to further information on
consideration of future conditionspecific EPMs that would result in
improvement in care for Medicare
beneficiaries.
c. Potential Future Event-Based Episode
Payment Models for Procedures and
Medical Conditions
Given the proposed EPM
methodology discussed in section
III.C.4.a. of this final rule for the three
models that would begin the episodes
with initial hospitalizations, the
proposed AMI, CABG, and SHFFT
episodes are similar to the LEJR
episodes in the CJR model because they
reflect clinical conditions for which care
is almost always begun during an
inpatient hospitalization, either on an
emergency or elective basis. In addition,
the clinical conditions represented by
these EPM episodes generally result in
straightforward assignment to MS–DRGs
at discharge that are specific to clinical
conditions included in the episodes.
This contrasts with procedure-related
clinical conditions for which the site-ofservice can be inpatient or outpatient
(for example, elective PCI for non-AMI
beneficiaries) or hospitalization for
medical conditions for which the
ultimate MS–DRG assigned is less clear
at the beginning of an episode (for
example, hospitalization for respiratory
symptoms which may lead to discharge
from heart failure, pneumonia, or other
MS–DRGs based on reporting of ICD–
CM diagnosis codes on hospital claims).
To address the issues related to the
development of future episode payment
models for a broader range of clinical
conditions, we sought comment on
model design features that would be
important for episode payment models
targeting procedures that may be
performed in both the inpatient and
outpatient setting, as well as models
focused on hospitalization for acute
medical conditions which may overlap
or interact (for example, sepsis related
to pneumonia or acute kidney injury
related to congestive heart failure
exacerbation). In particular, episode
payment models must clearly define the
beginning of the episode as well as set
an episode price that is appropriate for
beneficiaries included in the episode,
which has commonly been based on
historical spending for such
beneficiaries in both existing CMS
models and the three proposed EPMs.
These parameters pose specific
challenges as the variety of clinical
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conditions targeted for episode
payments expands beyond lower
extremity orthopedic procedures and
acute cardiac conditions, and we expect
that such potential future models would
need to be designed differently than the
CJR model or the EPMs in this
rulemaking.
For example, because procedures
such as PCI for non-AMI beneficiaries or
cardioverter defibrillator implantations
can occur in the inpatient or outpatient
setting, an episode payment model
would need to include beneficiaries
receiving such procedures at all sites-ofservice so as to not influence decisions
on where procedures are performed
based on payment-related rather than
clinical considerations. Episode
payment models that begin with the
same procedure performed in the
inpatient or outpatient setting would
require methodological development
beyond the approaches that have been
used thus far in CMS’ other EPMs that
rely upon the MS–DRG for a
hospitalization to begin an episode and
identify historical episodes for setting
episode prices. Such models that
involve episode payment for procedures
furnished in the inpatient or outpatient
setting may allow for significant
physician-led opportunities that would
allow the models to be identified as
Advanced APMs. We sought comment
on how these types of procedures could
be included in future episode payment
models, including identifying the
accountable entity, and the role of
physician-led opportunities; defining
the episode beginning and end; setting
episode prices; applying risk-adjustment
to account for differences in expected
episode spending for a heterogeneous
population of beneficiaries; and any
other issues of importance for the design
of such an episode payment model.
We also sought comment on potential
future episode payment models that
would include care for medical
conditions that result in the serious
health event of an inpatient
hospitalization, which often represents,
regardless of the specific reason for the
hospitalization, a common pathway that
includes failure of outpatient care
management and care coordination for
beneficiaries with chronic conditions.
While we include beneficiaries who
solely receive medical treatment in the
proposed AMI model, we note that
beneficiaries with AMI are almost
always hospitalized and their MS–DRGs
at discharge are generally predictable
and consistent based on their AMI
diagnoses. This is not the case for a
number of medical conditions for which
grouping by MS–DRGs is more
complicated or less consistent. Many
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non-procedural hospitalizations of
Medicare beneficiaries are ultimately
categorized based on the principal ICD–
CM diagnosis code reported on a claim,
which in turn is mapped to a Major
Diagnostic Category (MDC) based on the
involved organ system, which then
leads to the assignment of any of various
specific MS–DRGs based on the medical
groups in the MDC. For example, the
medical groups for the Respiratory
System MDC are pulmonary embolism,
infections, neoplasms, chest trauma,
pleural effusion, pulmonary edema and
respiratory failure, chronic obstructive
pulmonary disease, simple pneumonia,
RSV pneumonia and whooping cough,
interstitial lung disease, pneumothorax,
bronchitis and asthma, respiratory
symptoms and other respiratory
diagnoses.36 Unlike a beneficiary who
undergoes a surgical procedure or who
is hospitalized for a specific medical
condition such as AMI, the ultimate
MS–DRG at discharge assigned to a
beneficiary hospitalized for diagnosis
and management of respiratory
symptoms may not be clear during the
hospitalization itself, or even afterward,
until the inpatient claim is submitted
and paid by Medicare. This makes it
challenging for providers to engage in
care delivery redesign targeted to a
specific patient population identified by
MS–DRG. Additionally, it is possible
that beneficiaries hospitalized for
certain medical conditions also may
follow common clinical pathways
before and after discharge for which
similar care redesign strategies could be
developed and used despite those
beneficiaries’ assignments to different
MS–DRGs for their anchor
hospitalizations. Thus, we believe that
hospitalization for most medical
conditions would require special
consideration in the development of
potential future episode payment
models that goes beyond CMS’s current
approach of relying upon the MS–DRG
for the anchor hospitalization to begin
an episode and identify historical
episodes for setting episode prices. We
sought comment on design features
needed to address these considerations,
including defining the beginning and
end of episodes; setting episode prices,
including risk-adjustment, that would
support the provision of appropriate
and coordinated care for beneficiaries
following hospital discharge for a period
of time during the episode; and any
other issues of importance for the design
of such an episode payment model.
36 Medical Severity Diagnosis Related Groups
(MS–DRGs): Definitions Manual. Version 33.0A. 3M
Health Information Systems. (October 1, 2015).
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The following is a summary of the
comments received and our responses.
Comment: Many commenters
expressed support for the continued
commitment of the Agency to testing
episode-based payment models under a
range of settings. One commenter
suggested that CMS generally consider
both clinical and economic expertise as
well as include large databases as part
of the development of future eventbased EPM. While recommendations
included both specific surgical
procedures, such as PCI or spine
surgery, chronic conditions, such as
diabetes, and discrete events including
colonoscopy and an arm arthroplasty,
several commenters submitted more
general suggestions that CMS take an
expansive approach in general for the
consideration of future models and not
limit alternative payment models to
episode payment approaches. When
considering future models to qualify as
Advanced APMs, one commenter
suggested that CMS count capitated MA
relationships in MACRA’s APM
threshold calculation.
Some commenters preferred an
emphasis on future EPMs that consider
the role of preventative efforts. For
example, one commenter suggested that
conditions such as osteoporosis could
include efforts to improve bone health
and functional level to achieve
meaningful reduction in falls and
subsequent fracture. The commenter
followed that concerns such as fracture
prevention be included in future
models. To this end, one commenter
stated that CMS should take a ‘‘bottomup approach’’ that encourages providers
to develop alternative payment models.
Response: We thank the commenters
for their remarks, and will continue to
apply the bottom-up approach to
improving the coordination among
providers in future EPMs.
Comment: Some commenters
expressed concern about the
continuation of hospital-based models
and recommended that future
expansions should include more types
of participants, including physicians,
and participation should be voluntary.
Physicians, one commenter suggested,
are best suited to ensure efficient
utilization of resources while preserving
patient quality by virtue of their direct
relationship with the patient during an
acute episode. One commenter
suggested expansion of physicianfocused payment models beyond the
Focused Payment Model Technical
Advisory Committee (PTAC). In a
parallel thought process, many other
commenters expressed a desire for CMS
to consider post-acute care bundles,
ACO based models, and shared
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accountability payment models for
Inpatient Rehabilitation Facilities
(IRFs). One commenter strongly
recommended CMS to allow
manufacturers to enter into voluntary
agreements with CMS to link payment
to outcomes. One such outcome
proposed by the commenter was the
long-term revision rates for total joint
arthroplasty (TJA). Any shared savings
relative to the average rate of revision
among Medicare patients, the
commenter suggested, could be shared
between implanting surgeons, hospitals
and medical device manufacturers.
Commenters stated that these additional
types of participants could provide a
means to ensure efficient utilization
within a particular market. In addition,
another commenter noted that
procedures performed in ambulatory
surgical centers may be better situated
to serve as the financially accountable
entity in order to optimize care
coordination to better achieve the goals
envisioned by episode-based payment
models.
Response: We thank the commenters
for their commitment to working with
CMS in developing future episode
payment models.
Comment: Commenters commonly
recommended that future bundles be
sensitive to considering risk adjustment,
appropriate use criteria, patient
expectations, stage of disease
progression, treatment options, and
appropriate quality measures regardless
of setting. Commenters also
recommended that future measures in
future condition-specific payment
models should be more directly related
to the condition of the beneficiaries
within the EPM. To this end, one
commenter recommended that CMS
include measures of patient engagement
and shared care planning. Another
commenter suggested that those who
participate in geriatric fracture programs
and/or obtain CORE Certification, be
incentivized to continue such progress.
Even as CMS proposed to exclude IPPS
new technology add-on payments and
OPPS transitional pass-through
payments for medical technologies from
EPM episodes, one commenter
requested that future EPM episodes
include additional innovative
technologies to qualify for a payment
adjustment similar to the Medicare
New-Technology add-on payment.
Many commenters stressed the
importance of shared decision-making
in the development of future models.
One commenter, for example noted the
Clinical Practice Improvement
Activities Category of the MIPS could be
an important first step to greater shared
decision-making across healthcare
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delivery and recommended CMS look to
research conducted by PCORI and
others for future direction. Specifically,
one commenter also noted that shared
decision-making and patient
engagement tools could be especially
informative in situations not triggered
by an acute care hospitalization. Several
other commenters further strongly
encouraged the participation of
hospitals, physicians, patients, and
other stakeholders in the development,
implementation, and testing of future
models. Additionally, in future EPM
models, a few comments directed CMS
to consider directly extending the risk to
the other providers, including clinicians
as physicians shape the spending during
the hospital stay and the selection of the
initial post-acute care provider but are
not required to be at risk for the 90-day
episode spending. Similarly, some
commenters noted that post-acute care
providers can influence how much
spending for post-acute care services is
used and the rate of hospital
readmissions but are not directly at risk
for the 90-day episode spending.
Therefore, these commenters suggested
such changes to future EPMs would
ensure that the financial incentives of
the key actors shaping care are aligned.
In addition to model design, one
commenter recommended that QIOs
serve in a technical assistance role for
model participants to include data
analyses, convening providers in the
area, structuring implementation of
improvement activities, and monitoring
tests of improvement.
Response: We thank the commenters
for these suggestions and will consider
the recommendations as we consider
future event-based procedures and
medical conditions to include in future
rulemaking.
Comment: One commenter pointed to
the Continuing Care Hospital model,
and suggested CMS pilot future eventbased episode payment models for
procedures and medical conditions. The
commenter stated that the CCH would
allow predictable and reduced costs to
the Medicare program.
Response: We thank the commenter
for the reference.
Comment: One commenter suggested
the implementation of an evaluation
EPM, whereby the episode initiates
when a beneficiary enters an inpatient
setting with a set of symptoms that may
be difficult to attribute to one or more
MS–DRGs. Such an evaluation EPM,
stated the commenter, would need to be
limited to a specific set of symptoms,
such as the example CMS provided
regarding respiratory symptoms.
Response: We thank the commenter
for this specific suggestion.
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219
Comment: One commenter
recommended CMS to exclude other
potentially high cost drivers, such as
psychiatric readmissions and high cost
IV therapy, from future EPM bundles.
Response: We acknowledge this
suggestion and will consider if it is
applicable to specific future EPMs.
Comment: One commenter noted
other considerations specific to
identifying future models, specifically
that CMS update the claims
adjudication system and develop
contracting tools. The commenter
suggested that such changes would
encourage participant providers to
improve their care pathways and care
coordination.
Response: We acknowledge these
additional considerations and re-affirm
our commitment to continuously engage
stakeholders as we establish and
operationalize future policies.
Comment: A few commenters
requested a meeting with CMS to
discuss the specifics of a future
innovation model.
Response: We appreciate the interest
in meeting with CMS to discuss future
models. Commenters should note that
ideas can also be submitted through
https://innovation.cms.gov/Share-YourIdeas/Submit/.
Final Decision: After seeking
comments on future directions for
episode payment models, we thank the
public for these comments and will
evaluate the suggestions for future
consideration.
d. Health Information Technology
Readiness for Potential Future Episode
Payment Models
We are particularly interested in
issues related to readiness of providers
and suppliers that are not hospitals to
take on financial responsibility for
episode cost and quality in potential
future episode payment models. We
have some experience in BPCI Models 2
and 3 with non-hospital providers and
suppliers, specifically post-acute care
providers and physician group practices
(PGPs), who assume financial
responsibility for the cost of episode
care. In BPCI Model 2, PGPs may
directly bear financial responsibility for
episode cost for up to 48 clinical
conditions for the anchor inpatient
admission and up to 90 days posthospital discharge. In BPCI Model 3,
PGPs and post-acute care providers,
including skilled nursing facilities,
home health agencies, inpatient
rehabilitation facilities, and long-term
care hospitals, may directly bear
financial responsibility for episode cost
for up to 48 clinical conditions for a
duration that extends up to 90 days
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following initiation of post-acute care
following discharge from an inpatient
hospitalization.
Under these circumstances, PGPs and
post-acute care providers typically need
to use health IT to assist them in
effectively coordinating the care of BPCI
beneficiaries across settings throughout
the episodes. The risk-bearing entities
participating in BPCI have expressed
readiness to take on financial
responsibility for episode cost, and they
commonly rely upon health IT for
assistance in managing the care for BPCI
beneficiaries across settings for episodes
that extend for a substantial period of
time. However, a recent national survey
of IT in nursing homes showed common
use of IT for administrative activities
but less use for clinical care.37
Anecdotally, stakeholders have told us
that accountable non-hospital providers
and suppliers, especially those that are
not integrated with health systems, may
have less well-developed tools for
following patients throughout episodes,
potentially resulting in greater
challenges in reducing the cost and
improving the quality of episode care
under the BPCI models. Therefore, we
understand that limitations in the
availability of health IT that can be used
in beneficiary management across care
settings may pose a significant barrier to
the readiness of non-hospital providers
and suppliers to assume financial
responsibility for episodes in potential
future episode payment models.
In the CJR model, acute care hospitals
are financially responsible for cost and
quality during LEJR episodes-of-care.
CJR model participant hospitals may
form partnerships with post-acute care
providers such as skilled nursing
facilities and home health agencies, as
well as physicians and PGPs, to share
financial risk and collaborate on care
redesign strategies, as in BPCI. Although
hospitals are the financially responsible
entities under the CJR model, we
recognize that partnerships with postacute care providers could be a crucial
driver of episode spending and quality,
given that many beneficiaries in the CJR
model receive post-acute care services
after discharge from the hospital. We
also recognize that tools such as health
IT may be critical for certain care
management and quality strategies
targeted toward the goal of lower cost
and higher quality episode care.
Limitations in the availability of health
IT may pose a barrier to effective postacute care provider collaboration and
37 Alexander, Gregory L. ‘‘An Analysis of Nursing
Home Quality Measures and Staffing.’’ Quality
management in health care 17.3 (2008): 242–251.
PMC. Web. 16 July 2016.
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sharing of financial risk in episode
payment models even when hospitals
are the financially responsible entities
under such models, such as the CJR
model and the three new EPMs in this
rule.
We recognize that there is wide
variation in the readiness of other
providers and suppliers to bear financial
responsibility for episodes, either
directly or indirectly through sharing
arrangements with the directly
responsible entities where those
arrangements may include upside and
downside risk. For instance, adoption of
health IT among providers in the postacute care market, such as skilled
nursing facilities, continues to lag
behind hospitals and providers of
ambulatory care services. In addition to
facing significant resource constraints,
post-acute care providers were not
included as an eligible provider type
under the Medicare and Medicaid
Electronic Health Record (EHR)
Incentive Programs. The recent
extension of Medicaid 90/10 funding
offers new opportunities for states to
include post-acute care providers in
projects focused on infrastructure
development, but will not address the
cost of health IT adoption among postacute care providers.38
To ensure that post-acute care
providers and other types of providers
and suppliers can succeed under future
episode payment models, either as the
directly financially responsible entity or
as collaborators with other directly
financially responsible entities, we are
interested in opportunities to increase
provider readiness as part of the design
of potential future episode payment
models and the potential refinement of
current episode payment models.
Specifically, we would like to explore:
Incentives to encourage post-acute care
providers, as well as other providers
and suppliers that furnish services to
episode payment model beneficiaries, to
make necessary investments in health IT
infrastructure; payment mechanisms
that could leverage savings achieved
under episode payment models to
contribute to these investments; and any
other strategies to enhance the adoption,
implementation, and upgrading of
certified health IT. We sought comment
on these ideas, as well as the following
questions:
• What are key challenges associated
with the inclusion of post-acute care
providers as the financially responsible
entity or as collaborators with other
financially responsible entities in
episode payment models today?
38 https://www.medicaid.gov/federal-policyguidance/downloads/SMD16003.pdf.
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• What would be a sufficient
financial incentive or bonus to enhance
the adoption, implementation, and
upgrading of certified health IT in postacute care settings?
• How else can episode payment
models encourage the use of certified
health IT and information sharing
among providers and suppliers caring
for episode payment model beneficiaries
to improve care coordination and
patient outcomes?
• Within the existing CJR model, are
there additional opportunities to
encourage investment in adoption,
implementation, and upgrading of
certified health IT among post-acute
care providers to support improvements
in care coordination and patient
outcomes? What CJR model refinements
could enable direct investments to
support these improvements,
particularly among post-acute care
providers who are unaffiliated with CJR
model participant hospitals but who
provide services to CJR model
beneficiaries, including post-acute care
providers who may enter into financial
arrangements with CJR model
participant hospitals as CJR
collaborators?
The following is a summary of the
comments received and our responses.
Comment: Commenters recognized
the importance that health IT plays in
the modern health care landscape, and
overall supported the implementation of
a more robust health IT system, as such
a system may improve the ability to
convey quick, accurate information from
acute care hospitals related to the
discharge MS–DRG and identification of
patients who are under a bundled
payment program. Many commenters
expressed a need for future episode
payment models to align with EHR
incentive payments, and several
commenters expressed concern that
post-acute care providers were largely
disadvantaged for health IT readiness
relative to their inpatient counterparts.
For example, commenters stated that
post-acute care providers and
nonphysician clinicians were
marginalized by the Medicare and
Medicaid EHR Incentive Programs.
Some commenters believe this
population represents a significant
portion of the health care provider
community without the technical and
financial support necessary to adopt and
implement EHRs in a meaningful way.
As many of the measures used under
meaningful use, such as e-prescribing,
are not applicable to nonphysician
practitioners, commenters suggested
these and other clinicians have not had
the benefit of experience with EHRs at
the same rate as their peers who work
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in hospitals. As a result, one commenter
noted that small practices who may face
financial responsibility, such as
physical therapists, would face
considerable challenges implementing
health IT systems in their practices.
Several commenters recommended
that CMS to consider all possible
approaches to address this specific
concern. One commenter, for example,
recommended an approach similar to
the ACO Investment Model program
whereby participants could receive
supplemental payments to offset their
upfront investment. Other commenters
preferred not to provide specific
approaches as the sufficiency of
financial incentives or bonus payments
may differ for example among Skilled
Nursing Facilities (SNFs), Home Health
Agencies (HHAs), and institutional or
hospital-based post-acute care
providers, but highlighted the need for
CMS to otherwise incentivize health IT
adopters within future models. To
effectively implement any such
expansion, one commenter further
stressed the need for health IT
interoperability to be considered, while
another commenter stressed instead that
CMS should specifically cite the
availability of the safe harbors of the
Stark and Physician Self-Referral rules,
through which health care organizations
could choose to assist post-acute, or
other providers, in making available
EHRs meeting certain requirements in
any potential approach. One commenter
recommended that CMS continue to
engage the long-term and post-acute
care community to explore in more
detail potential strategies to help
overcome challenges providers face,
such as the high costs of participating in
health information exchange or the
operational investment of an EHR
system. Other comments on ways to
incentivize health IT investment by
post-acute care providers included:
quicker or premium reimbursement for
health IT adoption or upgrade, returning
savings to post-acute care providers to
offset health IT costs and incentive
grants for training staff in health IT.
Response: We will consider these and
other possible approaches to address the
concerns and challenges associated with
implementing health IT systems.
Final Decision: After consideration of
the public comments received, we
believe we have a better understanding
of the issues related to readiness of
providers and suppliers that are not
hospitals to take achieve
interoperability through CEHRT in
potential future episode payment
models.
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B. Definition of the Episode Initiator
and Selected Geographic Areas
1. Background
The new EPMs will complement the
current CJR model and continue efforts
to move Medicare towards paying
providers based on quality and value.
As discussed during rulemaking for the
CJR model and in the EPMs proposed
rule, CMS is interested in testing and
evaluating the impact of an episode
payment approach for a broad range of
episodes in a variety of other
circumstances. In addition to including
hospitals that have not chosen to
voluntarily participate in earlier models,
we also are interested in expanding the
range of episodes included beyond
elective surgical procedures such that
the impact on a broader range of
beneficiaries, hospitals, and
circumstances may be tested. We also
are interested in evaluating the impact
on hospitals when an increasing
percentage of care to Medicare
beneficiaries is paid for through
alternative payment models.
As with CJR, we proposed in
§ 512.105(c) that the hospital be the
accountable financial entity and that
these episode payment models be
implemented in all IPPS hospitals in the
geographic areas selected, subject to
exclusions as specified in §§ 512.230
and 512.240 of the proposed rule. While
these are considered new episode
payment models and do not reflect an
expansion or extension of any previous
models, they do intentionally build
significantly upon the work of BPCI
and, most significantly, the framework
established for CJR under 42 CFR part
510 published on November 24, 2015
(80 FR 73274). Given the extensive
consideration given to many of these
issues during the CJR model planning
and rulemaking periods, we believe this
is important as we seek to build a model
that is scalable across all providers and
episode types. We also seek to limit the
burden for hospitals and other providers
that may be participating across
multiple episode types. Therefore, to the
extent applicable and appropriate, we
have sought consistency with rules
established for the CJR model. We
sought comment on those areas where
alternative options were proposed or
should be considered that would not
add additional operational burden or
complexity. A summary of comments
received and CMS’ response to those
comments are included in the following
sections.
2. Definition of Episode Initiator
Under the proposed EPMs, consistent
with our episode initiator definition
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221
under the CJR model, we proposed that
episodes would begin with the
admission to an IPPS acute-care hospital
that triggers an AMI, CABG or SHFFT
episode as specified in section III.C.4.a.
of the proposed rule (81 FR 50834). As
with the CJR model, we proposed that
hospitals would be the only episode
initiators in these episode payment
models. For purposes of these episodes
payment models. The term ‘‘hospital’’
means a hospital as defined in section
1886(d)(1)(B) of the Act. This statutory
definition of hospital includes only
acute care hospitals paid under the
IPPS. Under this proposal, all acute care
hospitals in Maryland would be
excluded and payments to Maryland
hospitals would be excluded in the
regional pricing calculations as
described in section III.D.4. of the
proposed rule (81 FR 50847). This is the
same policy that is being followed with
the CJR model. In addition, we also
proposed to exclude other all-payer
state models which may be
implemented in the future. We
welcomed comments on this proposal
and sought comment on potential
approaches for including Maryland
acute-care hospitals or, potentially,
other hospitals in future all-payer state
models in these episode payment
models.
As implemented with the CJR model,
we proposed to designate IPPS hospitals
as the episode initiators to ensure that
all services covered under FFS Medicare
and furnished by EPM participant
hospitals in selected geographic areas to
beneficiaries who do not meet the
exclusion criteria specified in section
III.C.4. of the proposed rule (81 FR
50834) are included. In addition, the
episodes must not be BPCI episodes that
we are proposing to exclude as outlined
in this section and in section III.C.4. of
the proposed rule. We believe that
utilizing the hospital admission as the
episode initiator is a straightforward
approach for these models because
patients covered under these DRGs and
diagnoses require hospital admission for
these services, whether provided on an
emergent or planned basis. Under these
new models covering medical
admissions and services that are not
necessarily elective, as stated in the
proposed rule, we will be able to
expand our testing of a more generalized
bundled payment model. Finally, as
described in section III.B.4. of the
proposed rule (81 FR 50815) our
proposed geographic area selection
approach relied upon our definition of
hospitals as the entities that initiate
episodes.
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The following is a summary of the
comments received on our proposed
episode definition and our responses.
Comment: We received many
comments supporting our proposal to
initiate these EPM episodes of care with
the inpatient hospital admission.
However, we also received multiple
comments noting the important role that
physicians play in managing patient
care throughout the episode period
including after discharge from the
hospital. These same commenters
expressed support for more physician
based payment models so that
physicians can have a more substantial
role in managing episodes.
Response: We appreciate the support
commenters expressed for initiating the
EPM episodes with the inpatient
hospital admission. While we
acknowledge and understand that
inpatient initiated episodes represent
only one of many potential models for
improving the quality of care while
restraining the growth in costs, we
continue to believe that the appropriate
initiating point for the episodes in these
EPMs is the inpatient admission.
Hospitals play a central role in
coordinating episode-related care and
ensuring smooth transitions for
beneficiaries undergoing services
related to these episodes and a large
portion of a beneficiary’s recovery
trajectory from an AMI or CABG or
SHFFT begins during the hospital stay
which is why we are finalizing the
inpatient admission as the initiating
event in the episode definition. We also
note that CMS has supported and is
supporting other voluntary
demonstrations and models that focus
on providing financial support for care
coordination services as recommended
by these commenters. In addition, in
recent years, the range of services
eligible for payment under the Medicare
physician fee schedule has expanded to
include care transition and chronic care
management codes. For further
discussion of future models, we refer
the reader to section III.A.3. of this final
rule, ‘‘Future Directions for Episode
Payment Models.’’
We did not receive any comments
related to our exclusion of Maryland nor
on the potential inclusion or exclusion
of future all-payer state models.
Therefore we are finalizing our proposal
to exclude Maryland providers from this
model.
Subsequent to the publication of this
final rule CMS announced on October
26, 2016 the implementation of the
Vermont All Payer ACO Model which
will begin on January 1, 2017. Since this
new Vermont model is an all payer
model and since we proposed to
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exclude all of the all payer state models
from the EPM we are also finalizing the
exclusion of Vermont providers from
selection for participation in the EPMs.
We note that currently none of the
MSAs in Vermont are participating in
the CJR model and would, therefore, not
have been selected to participate in the
SHFFT EPM.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposed episode
definition, without modification, such
that these EPM episodes will be
initiated with the admission to an IPPS
acute-care hospital that triggers an AMI,
CABG or SHFFT episode as specified in
section III.C.4.a. of this final rule. We
are also finalizing the exclusion of
hospitals in Maryland and Vermont
from participation in the EPMs.
3. Financial Responsibility for the
Episode of Care
As with the CJR model, and as
discussed in the proposed rule, we
continue to believe it is most
appropriate to identify a single type of
provider to bear financial responsibility
for making repayment, if any, to CMS
under the model. Therefore, we
proposed to make hospitals, as the
episode initiators, financially
responsible for the episode of care for
the following several reasons:
• Hospitals play a central role in
coordinating episode-related care and
ensuring smooth transitions for
beneficiaries undergoing services
related to SHFFT, AMI and CABG
episodes. A large portion of a
beneficiary’s recovery trajectory from an
AMI, CABG, or SHFFT begins during
the hospital stay.
• Most hospitals already have some
infrastructure related to health IT,
patient and family education, and care
management and discharge planning.
This includes post-acute care
coordination infrastructure and
resources such as case managers, which
hospitals can build upon to achieve
efficiencies under these EPMs.
• By definition, these episodes
always begin with an acute care hospital
stay. While often preceded by an
emergency room visit and possible
transfer from another hospital’s
emergency room, or followed by postacute care, these parties are not
necessarily always present and would
not be appropriate to target as the
financially responsible party for this
purpose.
EPM episodes may be associated with
multiple hospitalizations through
transfers. When multiple
hospitalizations occur, we proposed that
the financial responsibility be given to
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the hospital to which the episode is
attributed, as described in section III.C.4
of the proposed rule. We recognize that,
particularly where the admission may
be preceded by an emergency room visit
and subsequent transfer to a tertiary or
other regional hospital facility, patients
often wish to return home to their local
area for post-acute care. Many hospitals
have recently heightened their focus on
aligning their efforts with those of
community providers, both those in the
immediate area as well as more outlying
areas from which they receive transfers
and referrals, to provide an improved
continuum of care. In many cases, this
is due to the incentives under other
CMS models and programs, including
ACO initiatives such as the Shared
Savings Program, the Hospital
Readmissions Reduction Program
(HRRP), and the CJR model. By focusing
on the hospital as the accountable or
financially responsible entity, we hope
to continue encouraging this
coordination across providers and
sought comment on ways we can best
encourage these relationships within the
scope of these EPMs.
In support of our proposal that
hospitals be the episode initiators under
these EPMs, we believe that hospitals
are more likely than other providers to
have an adequate number of episode
cases to justify an investment in episode
management for these EPMs. We also
believe that hospitals are most likely to
have access to resources that would
allow them to appropriately manage and
coordinate care throughout these
episodes. Finally, the hospital staff is
already involved in discharge planning
and placement recommendations for
Medicare beneficiaries, and more
efficient post-acute care service delivery
provides substantial opportunities for
improving quality and reducing costs
under EPMs. For those hospitals that are
already participating in CJR, we believe
the efforts that have been put in place
to support patients receiving LEJR will
be supportive of the new EPMs
proposed under this rule, particularly
for SHFFT episodes which we proposed
to implement in the same geographic
areas as the CJR model.
Finally, as noted when planning for
the CJR model, although the BPCI
initiative includes the possibility of a
physician group practice as a type of
episode initiating participant, the
physician groups electing to participate
in BPCI have done so because their
practice structure supports care redesign
and other infrastructure necessary to
bear financial responsibility for
episodes. These physician groups are
not necessarily representative of the
typical group practice. As with the CJR
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model, the infrastructure necessary to
accept financial responsibility for
episodes is not present across all
physician group practices, and thus, as
we stated in the proposed rule, we do
not believe it would be appropriate to
designate physician group practices to
bear the financial responsibility for
making repayments to CMS under the
proposed EPMs. We sought comment on
our proposal to establish financial
responsibility and accountability under
the AMI, CABG, and SHFFT EPMs
consistent with our implementation of
the CJR model.
Currently, there are SHFFT, AMI, and
CABG episodes being tested in BPCI
Models 2, 3 or 4. The last remaining
BPCI Model 1 hospital will end
December 31, 2016 and will, therefore,
not overlap with EPM. In addition,
under BPCI, there are episodes for PCI,
which, if an AMI were also involved,
would fall under the AMI model
proposed. We proposed that IPPS
hospitals located in an area selected for
any one of the episode payment models
proposed in the proposed rule (81 FR
50834) that also are episode initiators
for episodes in the risk-bearing phase of
BPCI Models 2 or 4 be excluded from
participating in the AMI, CABG, or
SHFFT EPMs if the applicable episode
otherwise would qualify to be covered
under BPCI. This exclusion would be in
effect only during the time that the
relevant qualifying episodes are
included in one of the BPCI models.
Likewise, we proposed that if the EPM
participant is not an episode initiator for
overlapping episodes under BPCI
Models 2 or 4, but these same episodes
are initiated during the anchor
hospitalization by a physician group
practice (PGP) under BPCI Model 2
(where the services are provided at the
episode initiating hospital) then the
episode also shall be covered under
BPCI and be excluded from the EPMs
proposed under the proposed rule (81
FR 50834). Otherwise qualifying EPM
episodes (that is, those that are not part
of an overlapping BPCI AMI, CABG, PCI
or SHFFT episode) at the participant
hospital would be included in these
new EPMs. However, because BPCI
participation is voluntary and
participating providers may select
which episodes to participate in, we
proposed that a BPCI participating
provider will participate in any of the
proposed AMI, CABG, or SHFFT EPMs
for any episodes not otherwise
preempted under their BPCI
participation. For example, a BPCI
Model 2 hospital in an AMI episode
model geographic area participating in
BPCI only for CABGs will be an EPM
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participant in the AMI model. Similarly,
an acute care hospital participating in
BPCI for LEJR but not SHFFT episodes
would be exempt from participation in
the CJR model in a CJR model
geographic area but would participate in
the SHFFT model for SHFFT episodes.
In addition, providers participating in
BPCI may also collaborate with an EPM
participant for episodes not covered
under BPCI. It should be noted that due
to differences in how the AMI episode
is defined under the AMI model versus
BPCI and the inclusion of PCI MS–DRGs
under the latter, a patient with the same
discharge MS–DRG and diagnoses may
qualify for a PCI episode under BPCI
and an AMI episode under the AMI
model. As stated in the proposed rule,
our intent is to give precedence to BPCI
regardless of which episode a patient
qualifies for if the patient would be
covered under BPCI.
In section III.D.6. of the proposed rule
we discussed in more detail how we
proposed to handle situations when a
beneficiary receives services that would
qualify for inclusion in more than one
CMS payment model during the same or
overlapping periods of time. We
welcomed input on how these overlaps
should be handled to best encourage
ongoing care coordination while
minimizing the impact on other models
and limiting confusion and operational
burden for providers.
While we proposed that the EPM
participant be financially responsible
for the episode of care under these
EPMs, we also stated that we believe
that effective care redesign requires
meaningful collaboration among acute
care hospitals, post-acute care
providers, physicians, and other
providers and suppliers within
communities to achieve the highest
value care for Medicare beneficiaries.
We continue to believe it is essential for
key providers to be aligned and
engaged, financially and otherwise, with
the EPM participants, with the potential
to share financial responsibility with
those EPM participants. We noted that
all relationships between and among
providers and suppliers must comply
with all relevant laws and regulations,
including the fraud and abuse laws and
all Medicare payment and coverage
requirements unless otherwise specified
further in this section and in sections
III.I. and III.J. of the proposed rule.
Depending on a hospital’s current
degree of clinical integration, new and
different contractual relationships
among hospitals and other health care
providers may be important, although
not necessarily required, for EPM
success in a community. We
acknowledge that financial incentives
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223
for other providers may be important
aspects of the model in order for EPM
participants to partner with these
providers and incentivize certain
strategies to improve episode efficiency.
While we acknowledged the
important role of conveners in the BPCI
model, and that AMI, CABG, and
SHFFT model participants may wish to
enter into relationships with EPM
collaborators and other entities in order
to manage the episode of care or
distribute risk, we proposed that the
ultimate financial responsibility of the
episode would remain with the EPM
participant. Exceptions to this general
rule for beneficiaries covered under
certain risk bearing ACO arrangements
are outlined in section III.D.6. of this
final rule. As with the CJR model, we
did not intend to restrict the ability of
EPM participants to enter into
administrative or risk sharing
arrangements related to these EPMs,
except to the extent that such
arrangements are already restricted or
prohibited by existing law. We referred
readers to section III.I. of the final rule
for further discussion of model design
elements that may outline financial
arrangements between EPM participants
and other providers and suppliers.
The following is a summary of the
comments received and our responses.
Comment: We received numerous
comments related to our proposal to
have the hospital be the single
accountable entity for the EPM
episodes. Many commenters were
supportive of this policy and, while not
ignoring the importance of other
providers, agreed that hospitals were
best positioned to assume risk for these
episodes. Other commenters were less
supportive of this proposal, noting that
hospitals could be disadvantaged if
physicians and post-acute care
providers were not also at risk or if
conflicting interests hindered their
willingness to collaborate. A few
commenters expressed concern that
while hospitals would bear the risk,
hospitals might be limited in their
ability to control that same risk. For
example, one commenter referenced the
penalty that hospitals already face for
readmissions which may not be
correlated to inpatient care. One
commenter stated that post-acute care
providers would be more motivated if
they were required to share in even a
small percentage of the incentives or
risk directly. Another commenter noted
that the current per-diem payment
system for SNFs put SNF providers at
particular risk. Although SNFs will
invest resources to reduce/shorten SNF
stays, which can create significant
savings for the EPM participant, the
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commenter stated SNF providers will be
disadvantaged/harmed as the proposed
regulations do not require proportional
sharing of reconciliation payments by
the EPM participant with post-acute
care providers and requested that we
amend the language to more clearly
outline how reconciliation payments
should be shared proportionally among
all EPM collaborators, noting that this
change would also likely require these
same providers to share in downside
risk as well.
Other commenters objected to the
hospital holding sole financial
accountability for the models as they
believe that physicians, including
hospitalists, surgeons, and internal
medicine subspecialists are best
positioned to impact the process of care.
These commenters stated that CMS
should be giving priority to physiciancentered alternative payment models.
One commenter believes that having the
hospital in charge of the bundle could
give the hospital inappropriate leverage
over other participants and or lead to
the exclusion of providers if they failed
to agree to the hospital’s terms. Other
commenters wanted the flexibility for
conveners to assume risk and organize
groups of providers, as is allowed under
BPCI.
One commenter specifically stated
that determination of the accountable
entity should be based not only on the
ability to accept risk but also the ability
to change care delivery patterns. While
one commenter explicitly stated that
‘‘only physicians can make the
determination as to what types of care
could effectively address patients’
needs,’’ that commenter also wanted
payment to physicians to be predictable
and physician financial accountability
limited to ‘‘costs that are within their
control.’’ The perspective that
physicians were best positioned to
manage the episode of care and desire
for them to have the opportunity to bear
risk, particularly as it might pertain to
eligibility for advanced alternative
payment model status, was expressed by
a number of commenters although the
focus in such comments was on
voluntary models.
Response: We appreciate the support
expressed by certain commenters for our
proposed policy to hold the initiating
hospital as the financially accountable
entity for the EPM episodes. While we
acknowledge the critical importance of
physicians and other providers, in
particular those providing post-acute
care, in managing episodes which
extend 90 days beyond discharge from
the anchor hospitalization, we continue
to believe the hospital should be the
financially accountable entity for these
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models. For hospitals to be successful in
managing EPMs, we firmly believe that
they will need to actively solicit the
support of physicians, post-acute care
providers, and other clinical care
providers in order to provide the best
quality of care in a cost effective
manner. In many, if not most situations,
this may involve establishing
collaborative agreements with a risk
sharing arrangement. We support other
types of providers assuming risk where
they are financially able to do so and
agree that providers that have a share in
the risk, both positive and negative, may
be more motivated to establish
collaborative agreements. However, we
do not believe that in a model with
required participation, any other
provider group is consistently as
financially positioned to assume risk as
is the hospital to which the episode is
attributed. We also do not want to
mandate a specific division of risk
between providers or to direct the
specific terms of any collaborator
agreements that may be established. We
disagree that the current proposal to
make hospitals the financially
accountable entity undermines the role
of the physician, and in providing for a
range of collaborator agreements, we
hope that EPM participants will actively
engage in gainsharing with others. We
refer readers to section III.I of this final
rule for a fuller discussion of allowable
collaborator relationships. We believe
that in order to be most successful,
hospitals will reach out to other
providers to establish agreements with
collaborators, although we acknowledge
that it may take time to negotiate and
establish such arrangements. While
some physician groups and post-acute
care providers are in a position to take
on risk, we continue to believe that
many, particularly those in smaller
groups and those in more rural areas,
are not and, in fact, no commenter
suggested that this was the case. Even
where the focus of a comment was on
providing more opportunities for
physicians to assume risk, it was in the
context of voluntary models such as
BPCI. We appreciate those comments
and, in fact, will give precedence to
BPCI participants where there is such
overlap. Readers are referred to section
III.D.6. of this final rule, ‘‘Adjustments
for Overlaps with Other Innovation
Center Models and CMS Programs,’’
which addresses in more detail how
situations where there is an overlap
between EPMs and other episode based
models will be handled. We address in
section III.D.6.b.(2). of this final rule,
how patients attributed to other
physician-centric episode models will
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be attributed. We also note in section
III.A.3 of this final rule opportunities for
future alternative payment models
which may be more physician-centric.
We are committed to testing a number
of alternative payment models, many of
which may be voluntary and more
appropriate for physicians or other
providers to assume risk.
Comment: We received a few
comments that not only advocated for
more flexibility in which entity would
be allowed to assume risk for the
episode but also suggested that CMS
more actively encourage collaboration
by providing more specific operational
guidance regarding how risk should be
shared among different providers. A few
commenters noted that financial
agreements may not always be feasible.
One commenter noted that in markets
where physicians, hospitals and postacute care providers already work well
together, the foundation for effective
gainsharing arrangements are more
likely to be in place. Others noted that
some organizations may be willing to
share in any savings but not be willing
to accept downside risk.
One commenter recommended that
CMS require that EPM participants
execute gainsharing arrangements with
providers to establish a third party
entity to receive and distribute
reconciliation payments in accordance
with the terms of such sharing
agreements.
Response: We acknowledge the
challenges that some EPM participants
may have in establishing effective
collaborative agreements. Similarly, we
acknowledge the potential challenges
that non-hospital providers such as
physicians and post-acute care
providers may have in getting EPM
participants to share risk in a manner
that is believed to be equitable to all.
However, we do not believe it is
appropriate for CMS to either require or
establish specific criteria for the terms
of such agreements nor to specify how
they should be operationalized. We
continue to believe, however, that the
most successful EPMs will be motivated
to engage other providers so that
interests and incentives are aligned. We
refer readers to section III.I. of this final
rule, ‘‘Financial Arrangements under
EPM,’’ for a full discussion of EPM
financial arrangements.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal, without
modification, to make hospitals the
episode initiators and financially
responsible for the episode of care.
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4. Geographic Unit of Selection and
Exclusion of Selected Hospitals
In order to determine the geographic
unit of selection for these episode
payment models, we conducted an
analysis similar to that used for the CJR
model. For the CJR model, we
considered using a stratified random
sampling methodology to select: (1)
Certain counties based on their CoreBased Statistical Area (CBSA) status; (2)
certain zip codes based on their
Hospital Referral Regions (HRR) status
or (3) certain states. We concluded that
selection based on MSAs provided the
best balance between choosing smaller
geographic units while still capturing
the impact of market patterns reflecting
the mobility of patients and providers
and limiting the potential risk for
patient shifting and steerage between
MSAs. HRRs are based on where
patients receive selected tertiary care
services, which do not include
orthopedic services. Therefore, HRRs
may not be representative of where
patients receive specialty orthopedic
care or more routine orthopedic services
such as hip and knee arthroplasty.
Selection of states rather than MSAs
would have greatly reduced the number
of independent geographic areas subject
to selection and, therefore, the statistical
power of the evaluation. For similar
reasons and to maintain consistency
with the CJR model, we proposed
implementation at the MSA level.
We also similarly considered whether
these new models should be limited to
hospitals where a high volume of these
episodes occur, which would result in
a more narrow test on the effects of an
episode-based payment, or whether to
include all hospitals in particular
geographic areas, which would result in
testing the effects of an episode-based
payment approach more broadly across
an accountable care community seeking
to coordinate care longitudinally across
settings. However, as with the CJR
model, if we were to limit participation
based on volume, there would be more
potential for behavioral changes that
could include patient shifting and
steering between hospitals in a given
geographic area that could impact the
test. Additionally, this approach would
provide less information on testing
payments for these episodes across a
wide variety of hospitals with different
characteristics. Selecting geographic
areas and including all IPPS hospitals in
those areas not otherwise excluded due
to BPCI overlap as previously described
and in section III.D.6. of the proposed
rule as model participants would help
to minimize the risk of participant
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hospitals shifting higher cost cases out
of the EPM.
In determining where to implement
these EPMs, we also considered whether
implementation of the CJR model in the
same geographic area should be a factor.
We realize that there is likely to be
considerable overlap in the selection
criteria between MSAs where the
SHFFT EPM might be appropriate and
those MSAs where the CJR model is
now being implemented. While limiting
burden on hospitals is an important
consideration, we also believe that the
infrastructure being put in place as a
result of the CJR model presents
significant advantages for
implementation of the SHFFT model.
For similar reasons, and in order to
minimize patient steerage and/or
transfer for reasons due solely to the
implementation of these new payment
models, we believe that it is appropriate
to implement the AMI model and CABG
model together in the same geographic
areas, albeit not necessarily in the same
areas as the CJR and SHFFT models.
Therefore, given the authority in
section 1115A(a)(5) of the Act, which
allows the Secretary to elect to limit
testing of a model to certain geographic
areas, we proposed that the SHFFT
model be implemented in those MSAs
where the CJR model is being
implemented.
We also proposed that the AMI and
CABG models be implemented in MSAs
selected independently based on the
criteria discussed in the proposed rule
(81 FR 50815). This would result in four
separate categories of MSAs: (1) MSAs
where only the CJR and SHFFT model
episodes are being implemented; (2)
MSAs where only the CABG model and
AMI model episodes are being
implemented; (3) MSAs where the CJR
as well as the AMI, CABG, and SHFFT
models are being implemented; and (4)
MSAs where neither CJR nor any of the
new episode payment models are being
implemented. We believe this will
provide an opportunity to test the
impact of implementing EPMs across
not only a greater diversity of episodes
but also as an increasing percentage of
hospital discharges. We sought
comment on our proposal to implement
the SHFFT model in the same
geographic region as the CJR model and
to implement both the AMI model and
the CABG model in the same MSAs,
some of which may overlap with MSAs
where the CJR and SHFFT models also
are being implemented.
The following is a summary of the
comments received and our responses.
Comment: While several commenters
explicitly noted concurrence with our
proposed method for selecting the
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MSAs where these models will be
implemented, we did receive a few
comments related to the selection of
areas based on MSAs vs. other
geographic units such as CBSAs as well
as other recommended criteria upon
which to base our selection. We address
some of the specific factors in the
comments located in this section.
Independent of the selection
methodology, several commenters
requested that CMS publish a list of the
hospitals CMS believed were in the
selected MSAs and allow hospitals 60
days to comment. Other commenters
requested that CMS publish the list of
MSAs selected as soon as possible to
allow those hospitals impacted
additional preparatory time prior to the
initial effective date of EPMs. Other
commenters emphasized the importance
of maintaining beneficiary freedom of
choice in selecting where and how to
receive care regardless of the
beneficiary’s geographic residence or
the MSAs selected for EPMs.
Response: With regard to MSAs as the
geographic unit of selection, we
continue to believe, consistent with CJR,
that MSAs allow us to observe the
impact of the model in a variety of
circumstances and provide the best
balance between choosing smaller
geographic units while still capturing
the impact of market patterns reflecting
the mobility of patients and providers.
We also believe that MSAs limit the
potential risk for patient shifting and
steerage. As such, we see no reason to
change the unit of selection or to be
inconsistent with what has already been
implemented with CJR. For an in depth
discussion of this, we refer the reader to
the final CJR rule (42 CFR part 510, 80
FR 73288). We concur that it is
important that all participants clearly
understand which hospitals will be
impacted. Prior to implementation and
in conjunction with the publication of
this final rule, CMS will publish a list
of hospitals that, based on the
geographic location associated with the
hospital’s CMS Certification Number
(CCN), we believe are located in the
selected MSAs and will be subject to
participation in these EPMs. Hospitals
identified using this method will have
the opportunity to correct any
information CMS has on file that may
impact whether they are or are not in a
selected MSA by contacting epm@
cms.hhs.gov within 45 days after the
publication of the Final Rule. Finally,
we concur that beneficiaries continue to
have the freedom to choose where they
will receive services, regardless of the
payment model in place in a particular
geographic area. We refer readers to
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section III.G. of this final rule,
‘‘Monitoring and Beneficiary
Protection,’’ for a discussion of these
issues.
Comment: A number of commenters
expressed concern about implementing
the SHFFT EPMs in those MSAs where
the CJR model is being implemented.
Some commenters expressed concern
that we were adding the SHFFT model
to the existing CJR model. Other
commenters expressed concern that
sufficient time had not elapsed to allow
hospitals or CMS to learn from their
experience. Many believe they needed
more time to be able to analyze the
results from at least the first year of CJR
as well as incorporating findings from
the BPCI experience before adding the
additional burden of implementing a
new model with required participation.
While both CJR and SHFFT involve
some of the same providers and
specialties, some commenters noted that
the SHFFT patient population was
distinctly different requiring different
care pathways and resources. Because of
the concern about additional burden on
those MSAs where the CJR model has
been implemented, some commenters
believe that those same MSAs should,
therefore, be exempt from implementing
the additional cardiac EPMs.
Response: To clarify for commenters,
the SHFFT model is separate and
distinct from the CJR model although it
is designed to run in the same MSAs in
which the CJR model is currently
operational. We acknowledge the
challenges that hospitals implementing
CJR may have in order to implement the
SHFFT EPM. While recognizing that the
patients covered under the SHFFT EPM
may be frailer and potentially require
different and/or a more intensive level
of care, we also continue to believe that
SHFFT is similar to CJR in that it
involves many of the same specialties
and provider types. While there may be
different care pathways, we hope that
much of the infrastructure and
collaborator agreements put in place
will provide a solid base upon which to
build for SHFFT. As CMS seeks to move
away from fee for service payment
systems to more value based
purchasing, we believe that SHFFT
represents a reasonable next step in this
transition.
We also acknowledge that in those
MSAs where the cardiac EPMs will be
alongside CJR and now SHFFT, EPM
participants will face additional
burdens and challenges. However, we
do not believe that it is appropriate to
exclude those MSAs where CJR and
SHFFT will be implemented from
eligibility for selection for the cardiac
EPMs. Exclusion of these MSAs would
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result in a comparative over
representation in the cardiac EPMs of
lower cost and lower population MSAs
due to the manner in which the CJR
MSAs were selected. For a full
discussion of the criteria for selecting
cardiac EPMs, we refer readers to
section III.B.5. of this final rule,
‘‘Overview and Options for Geographic
Area Selection for AMI and CABG
Episodes’’. As we move towards more
inpatient care being covered under these
types of models, we will monitor and
evaluate the impact on different types of
hospitals implementing multiple EPMs
so as to minimize operational burden
and improve outcomes.
Comment: Several commenters did
not disagree with the use of MSAs
specifically, but did note the potential
for negative impact on certain hospitals
in a model where all hospitals in the
MSA providing the covered services are
required to participate. This included
concern for both high performing
regional and national referral centers
which may already be providing high
quality care at a lower cost as well as
hospitals with more limited numbers of
eligible discharges and/or those serving
at risk populations which often have
lower operating margins and thus may
be at greater financial risk. These
commenters suggested that demographic
factors such as age, race, and poverty
levels could be used to limit which
MSAs were selected.
Response: We acknowledge that some
hospitals may face particular challenges
in implementing EPMs whether it be
due to demographic factors related to
their patient base, a lower number of
potential EPMs each year, or other
factors. A key reason for doing a model
with required participation is, in fact, to
examine and better understand the
impact of a model on a broader range of
facility types and communities than are
usually included in a voluntary model.
Although we do not believe that using
specific demographic factors in MSA
selection is appropriate, in response to
comments on other sections of this rule
around risk-adjustment, we are
finalizing a timeframe for the
implementation of downside risk that
allows us time to look carefully at
different approaches for recognizing and
adjusting for risk in these models which
we will discuss via notice and comment
rulemaking for FY 2019 and we believe
that these actions will help to resolve
concerns expressed regarding greater
financial risk for high performing
regional and national referral centers.
A key rationale for conducting a
model with required participation is the
ability to examine variations in the
impact of the model on a broad range of
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hospitals in a variety of different market
conditions in order to better understand
how the model operates in a variety of
circumstances. Although demographic
factors are not proposed to be part of the
selection process for MSAs, we do
consider, as noted in the proposed and
this final rule, these factors to be
important to the proper understanding
of the impact of the models and where
is more or less successful. The
evaluation will consider the suggested
demographic domains and other
measures in determining which MSAs
are appropriate comparison markets as
well as for possible subgroup analyses.
Comment: A few commenters
suggested eliminating those MSAs that
had a higher penetration of Medicare
Advantage plans or suggested that we
select MSAs that will minimize overlap
with BPCI and ACO participating
hospitals.
Response: We note in this rule the
reasons for aligning the MSAs where the
SHFFT EPM will be implemented with
those MSAs where the CJR model has
already been implemented. In doing so,
we accept the exclusion of those MSAs
that were excluded from the CJR model
due to the limited volume of LEJR
procedures performed there.
In the proposed rule we similarly
proposed elimination of some MSAs
from selection for the cardiac EPMs due
to having lower numbers of episodes
and having a higher number of episodes
covered under the BPCI models. We
refer readers to section III.B.5. of this
final rule for a full discussion of the
selection criteria for MSAs where the
cardiac episodes will be implemented.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal, without
modification, to implement the SHFFT
EPM in those MSAs where the CJR
model is being implemented. Further,
we are finalizing the proposal to
implement the cardiac EPMs in
randomly selected MSAs from among
all those in the country meeting the
criteria specified in section III.B.5. of
this final rule.
5. Overview and Options for Geographic
Area Selection for AMI and CABG
Episodes
We proposed that the AMI and CABG
EPMs be implemented together in the
same MSAs. These AMI/CABGparticipating MSAs may or may not also
be CJR/SHFFT–EPM participating
MSAs. The selection of MSAs for AMI/
CABG EPMs would occur through a
random selection of eligible MSAs.
We proposed to require participation
in the AMI and CABG models of all
hospitals, with limited exceptions as
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previously discussed in section III.B.4.
of the proposed rule, paid under the
IPPS that are physically located in a
county in an MSA selected through the
methodology outlined in section
III.B.5.b. of the proposed rule (81 FR
50815), to test and evaluate the effects
of an episode-based payment approach
for the proposed EPMs. We proposed to
determine that a hospital is located in
an area selected if the hospital is
physically located within the boundary
of any of the counties in that MSA as
of the date the selection is made.
Although MSAs are revised
periodically, with counties added or
removed from certain MSAs, we
proposed to maintain the same cohort of
selected hospitals throughout the 5-year
performance periods of the EPMs with
limited exceptions as described later in
this section. Thus, we proposed neither
to add hospitals to an EPM if after the
start of such EPM new counties are
added to one of the selected MSAs nor
to remove hospitals from an EPM if
counties are removed from one of the
selected MSAs. We believe that this
approach will best maintain the
consistency of the participants in the
EPMs, which is crucial for our ability to
evaluate their respective results.
However, we retain the possibility of
adding a hospital that is opened or
incorporated within one of the selected
counties after the selection is made and
during the period of performance. (See
section III.D. of this final rule for
discussion of how target prices will be
determined for such hospitals.)
The manner in which CMS tracks and
identifies hospitals is through the CMS
Certification Number (CCN). In keeping
with this approach, these EPMs will
administer model related activities at
the CCN level including the
determination of physical location. The
physical location associated with the
CCN at the time of an EPM’s start will
be used to determine whether that CCN
is located in a selected MSA. For
hospitals that share a CCN across
various locations, all hospitals under
that CCN would be required to
participate in the applicable EPM if the
physical address associated with the
CCN is in the MSA selected, unless
otherwise excluded. Similarly, all
hospitals under the same CCN, even if
some are physically located in the MSA
selected for participation, would not
participate in the applicable EPM if the
physical address associated with the
CCN is not in the MSA.
We considered including hospitals in
a given MSA based on whether the
hospitals were classified into the MSA
for IPPS wage index purposes. However,
such a process would be more
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complicated, and we could not find any
compelling reasons favoring such
approach. For example, we could assign
hospitals to metro divisions of MSAs
when those divisions exist. In addition,
there is the IPPS process of geographic
reclassification by which a hospital’s
payments can be based on a geographic
area other than the one where the
hospital is physically located. For the
purpose of the EPMs, it is simpler and
more straightforward to use a hospital’s
physical location as the basis of its
assignment to a geographic unit. This
decision would have no impact on a
hospital’s payment under the IPPS. We
sought comment on our proposal to
include a hospital as an EPM participant
based on the physical location
associated with the CCN of the hospital
in one of the counties included in a
selected MSA.
The following is a summary of the
comments received and our responses.
Comment: One commenter expressed
that implementing the two cardiac
EPMs, CABG and AMI, in the same
geographic areas would overburden
participant hospitals. They stated that
the two cardiac conditions are
characterized by clinically different
populations and require distinct care
teams and the opportunities for
common care redesign approaches are
limited.
Response: We understand the amount
of effort required to redesign care
processes and that often these are
specific to a condition and not always
immediately transferrable between
conditions. In regards to implementing
two cardiac episodes there is an
expectation that some economies of
scale will present themselves with the
cardiac episode-based approaches even
though the care teams and patient
populations are distinct.
As discussed in section III.C. of this
final rule, the AMI and CABG model
episodes primarily include beneficiaries
with cardiovascular disease, a chronic
condition which likely contributed to
the acute events or procedures that
initiate the episodes. Beneficiaries
experiencing an AMI can be treated by
different clinical modalities including
medical management and surgical
intervention such as PCI and CABG. The
decision as to which treatment is
medically appropriate for a given
beneficiary is both complex and subject
to evolving medical knowledge and
practice norms. Furthermore,
approximately 30 percent of CABGs are
performed during the care of AMIs.
Because of the close connection
between these two models, CMS
believes that testing the AMI and the
CABG EPMs in the same markets
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decreases the probability that clinical
decision making regarding the course of
treatments would be unduly influenced
by inclusion or exclusion in one of the
two cardiac EPMs. If the two cardiac
EPMs were in different areas, the AMI
EPM would be structured in such a way
as to include AMIs treated with CABG.
Thus, the separation of the two cardiac
EPMs into different MSAs would not
reduce the burdens associated with
hospitals who are simultaneously
needing to manage patients treated
under a variety of modalities. It would,
on the other hand, conceivably increase
the complexity of management for
participants who would be faced with
the situation of having only the 30
percent of CABGs done in conjunction
with an AMI included in a model.
Comment: One commenter requested
that if a health system had member
hospitals within MSAs selected for
inclusion in a cardiac EPM that they be
allowed to have their member hospitals
in non-selected areas also be included
in the model. They stated that the
ability to have all of their member
hospitals in one model would allow for
care to be provided under a unified
system and would result in increased
coordination.
Response: The cardiac EPMs are
structured as required models. As such,
they will require hospitals within
selected geographic areas to participate
(unless otherwise excluded as set forth
in this final rule). Hospitals who are not
in a selected MSA but are part of a
health system that includes selected
included hospitals will not subject to
the EPM rules and incentives structures.
However, if a health system wishes to
implement certain care coordination
activities across their entire spectrum of
hospitals they would not be precluded
from doing so as long as they comply
with current regulations and law. The
inclusion of additional hospitals outside
of these selected areas would constitute
a major change to the model that was
not considered in the proposed rule.
CMS previously offered solicited
participation in the BPCI initiative, a
bundled payment model. Please refer to
section III.A.3. of this final rule for a
discussion of the possibility of future
bundled payment models.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal, without
modification, to implement the CABG
and the AMI EPMs in the same areas,
and to administer model-related
activities at the CCN level including the
determination of physical location. The
physical location associated with the
CCN at the time of an EPM’s start will
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be used to determine whether that CCN
is located in a selected MSA.
a. Exclusion of Certain MSAs
We considered whether certain MSAs
should be exempt from the possibility of
selection for the AMI/CABG EPMs’
implementation. We considered
exclusions based on the anticipated
number of AMI episodes and CABG
episodes in the MSA. We also
considered exclusions based on the
degree to which such EPMs’ episodes
would be impacted by overlaps with
other payment initiatives, including
BPCI and ACOs.
First, we considered the advisability
of MSA exclusions based on the number
of episodes in a year. We identified
qualifying AMI and CABG episodes that
initiated between January 1, 2014, and
December 31, 2014. AMI and CABG
episodes were attributed to an MSA
based on the location of the CCN
associated with the initiating hospital
using the Provider of Service file. Due
to the smaller number of relevant AMI
and CABG episodes occurring in some
MSAs, an exclusion rule that required a
large number of episodes in each MSA
would result in fewer MSAs eligible for
selection than was necessary given the
desired number of MSAs and the
requirement to have 50 percent or more
of MSAs remain in a pool of possible
comparison MSAs. From the
perspective of evaluating changes to
utilization and spending under EPMs,
there is no analytic need to eliminate
MSAs with small numbers. In fact,
including smaller MSAs has the analytic
advantage of giving CMS more
experience operating EPMs in the
smaller-MSA contexts that will help us
generalize our EPM-evaluation findings.
We have a strong interest in being
able to observe how well EPMs operate
in areas with a lower volume of
episodes, and, in particular, the
consequences of the models for AMI
episodes where CABG is not commonly
performed or where standard practice is
to refer all CABGs outside of the MSA.
Given our desire to assess the operation
of the AMI EPM in areas with little or
no CABG episodes and the desire to
have the two cardiac EPMs be
administered together in the same
MSAs, we proposed that the MSA
exclusion rules be based on the number
of AMI episodes only. This will allow
for the inclusion of MSAs with no
CABGs.
There is no analytic requirement for a
minimum number of cases and there are
advantages to including smaller cities.
At the same time, we acknowledge that
areas with few AMI cases may believe
that they will face challenges under the
EPMs. Therefore, we proposed an
exclusion rule that MSAs with fewer
than 75 AMI episodes (determined as
discussed in section III.C. of this final
rule) will be removed from the
possibility of selection. Cases in
hospitals paid under either the CAH
methodology or the Maryland All-Payer
Model are not included in the count of
eligible episodes. We examined a
number of different minimum-episodenumber cutoffs. The use of the 75 AMIs
in a year was a designed to balance
limiting the impact of outlier cases on
the MSA average episode spending and
the desire to retain a non-negligible
representation of MSAs in the under
100,000 population and the 100,000 to
200,000 population ranges in our
selection pool. The application of
Exclusion Rule 1: ‘‘Less than 75
qualifying AMI episodes in the
reference year’’ resulted in the removal
of 49 MSAs from possible selection.
Second, we assessed exclusion rules
based on overlap with BPCI. We
proposed Exclusion Rule 2 such that
MSAs are removed from possible
selection if there were fewer than 75
non-BPCI AMI episodes in the MSA in
the reference year. For the purposes of
this exclusion, the number of non-BPCI
episodes was estimated by subtracting
BPCI cases from the total number of
cases used in Exclusion Rule 1. BPCI
cases for this purpose are ones during
the reference year associated with a
hospital or a PGP BPCI Model 2 or 4
episode initiator participating in an
AMI, PCI, or CABG episode as of
January 1, 2016. Such criterion removed
an additional 26 MSAs from potential
selection.
Third, we proposed to exclude MSAs
from possible selection based on
whether the number of non-BPCI AMI
episodes calculated under Exclusion
Rule 2 is less than 50 percent of the total
number of AMI episodes calculated
under Exclusion Rule 1. We anticipate
that some degree of overlap in the BPCI
and other EPMs will be mutually
helpful. However, we acknowledge that
some providers may have concerns that
a BPCI Model 2 AMI and PCI
participation rate of more than 50
percent may impair the ability of
participants in either the EPMs or the
BPCI models to succeed in the
objectives of their respective initiatives.
As a result of this third criterion, 13
additional MSAs were removed from
possible selection.
We considered whether there should
be an exclusion rule based on the
anticipated degree of overlap between
the AMI and CABG EPMs and patients
who are aligned prospectively to ACOs
that are taking two-sided risk, such as
ACOs participating in the Next
Generation ACO model or Track 3 of the
Shared Savings Program. We examined
numbers associated with ACOs meeting
this status as of May 1, 2016, and this
examination did not result in any
additional MSAs falling below the
threshold of 75 AMI episodes.
Consequently, we did not propose any
MSA exclusion rule based on the
presence of ACOs.
Please refer to Table 1 for the status
of each MSA based on these exclusion
criteria, available at https://
innovation.cms.gov/initiatives/epm.
After applying these three exclusions,
294 MSAs out of 384 total MSAs are
eligible for selection using our proposed
selection methodology.
TABLE 1—MSA EXCLUSION RULE STATUS AND ELIGIBILITY FOR SELECTION STATUS FOR INCLUSION IN AMI AND CABG
EPMS IN THE PROPOSED RULE
MSA name
Rule 1:
75+ AMIs
Rule 2:
75+ nonBPCI AMI
Rule 3:
<50% BPCI
AMI
Abilene, TX ..........................................................................
Aguadilla-Isabela, PR ..........................................................
Akron, OH ............................................................................
Albany, GA ...........................................................................
Albany, OR ..........................................................................
Albany-Schenectady-Troy, NY ............................................
Albuquerque, NM .................................................................
Alexandria, LA .....................................................................
Pass ..............
Fail ................
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Fail ................
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Pass ..............
asabaliauskas on DSK3SPTVN1PROD with RULES
CBSA_OMB
10180
10380
10420
10500
10540
10580
10740
10780
..............
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Exclude.
Exclude.
Include.
Include.
229
Federal Register / Vol. 82, No. 1 / Tuesday, January 3, 2017 / Rules and Regulations
TABLE 1—MSA EXCLUSION RULE STATUS AND ELIGIBILITY FOR SELECTION STATUS FOR INCLUSION IN AMI AND CABG
EPMS IN THE PROPOSED RULE—Continued
MSA name
Rule 1:
75+ AMIs
Rule 2:
75+ nonBPCI AMI
Rule 3:
<50% BPCI
AMI
Allentown-Bethlehem-Easton, PA-NJ ..................................
Altoona, PA ..........................................................................
Amarillo, TX .........................................................................
Ames, IA ..............................................................................
Anchorage, AK .....................................................................
Ann Arbor, MI ......................................................................
Anniston-Oxford-Jacksonville, AL ........................................
Appleton, WI ........................................................................
Arecibo, PR ..........................................................................
Asheville, NC .......................................................................
Athens-Clarke County, GA ..................................................
Atlanta-Sandy Springs-Roswell, GA ....................................
Atlantic City-Hammonton, NJ ..............................................
Auburn-Opelika, AL .............................................................
Augusta-Richmond County, GA-SC ....................................
Austin-Round Rock, TX .......................................................
Bakersfield, CA ....................................................................
Bangor, ME ..........................................................................
Barnstable Town, MA ..........................................................
Baton Rouge, LA .................................................................
Battle Creek, MI ...................................................................
Bay City, MI .........................................................................
Beaumont-Port Arthur, TX ...................................................
Beckley, WV ........................................................................
Bellingham, WA ...................................................................
Bend-Redmond, OR ............................................................
Billings, MT ..........................................................................
Binghamton, NY ...................................................................
Birmingham-Hoover, AL ......................................................
Bismarck, ND .......................................................................
Blacksburg-Christiansburg-Radford, VA ..............................
Bloomington, IL ....................................................................
Bloomington, IN ...................................................................
Bloomsburg-Berwick, PA .....................................................
Boise City, ID .......................................................................
Boston-Cambridge-Newton, MA-NH ....................................
Boulder, CO .........................................................................
Bowling Green, KY ..............................................................
Bremerton-Silverdale, WA ...................................................
Bridgeport-Stamford-Norwalk, CT .......................................
Brownsville-Harlingen, TX ...................................................
Brunswick, GA .....................................................................
Buffalo-Cheektowaga-Niagara Falls, NY .............................
Burlington, NC .....................................................................
Burlington-South Burlington, VT ..........................................
Canton-Massillon, OH ..........................................................
Cape Coral-Fort Myers, FL ..................................................
Cape Girardeau, MO-IL .......................................................
Carbondale-Marion, IL .........................................................
Carson City, NV ...................................................................
Casper, WY .........................................................................
Cedar Rapids, IA .................................................................
Chambersburg-Waynesboro, PA .........................................
Champaign-Urbana, IL ........................................................
Charleston, WV ....................................................................
Charleston-North Charleston, SC ........................................
Charlotte-Concord-Gastonia, NC-SC ..................................
Charlottesville, VA ...............................................................
Chattanooga, TN-GA ...........................................................
Cheyenne, WY .....................................................................
Chicago-Naperville-Elgin, IL-IN-WI ......................................
Chico, CA .............................................................................
Cincinnati, OH-KY-IN ...........................................................
Clarksville, TN-KY ................................................................
Cleveland, TN ......................................................................
Cleveland-Elyria, OH ...........................................................
Coeur d’Alene, ID ................................................................
College Station-Bryan, TX ...................................................
Pass ..............
Pass ..............
Pass ..............
Pass ..............
Pass ..............
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Pass ..............
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Fail ................
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Pass ..............
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Pass ..............
Pass ..............
Pass ..............
Pass ..............
Pass ..............
Fail ................
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Pass ..............
Pass ..............
Pass ..............
Pass ..............
Pass ..............
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Pass ..............
Pass ..............
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Fail ................
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Pass ..............
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Pass ..............
Pass ..............
Pass ..............
Pass ..............
Pass ..............
Pass ..............
Pass ..............
Fail ................
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Pass ..............
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Pass ..............
Pass ..............
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Pass ..............
Fail ................
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Fail ................
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asabaliauskas on DSK3SPTVN1PROD with RULES
CBSA_OMB
10900
11020
11100
11180
11260
11460
11500
11540
11640
11700
12020
12060
12100
12220
12260
12420
12540
12620
12700
12940
12980
13020
13140
13220
13380
13460
13740
13780
13820
13900
13980
14010
14020
14100
14260
14460
14500
14540
14740
14860
15180
15260
15380
15500
15540
15940
15980
16020
16060
16180
16220
16300
16540
16580
16620
16700
16740
16820
16860
16940
16980
17020
17140
17300
17420
17460
17660
17780
..............
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230
Federal Register / Vol. 82, No. 1 / Tuesday, January 3, 2017 / Rules and Regulations
TABLE 1—MSA EXCLUSION RULE STATUS AND ELIGIBILITY FOR SELECTION STATUS FOR INCLUSION IN AMI AND CABG
EPMS IN THE PROPOSED RULE—Continued
MSA name
Rule 1:
75+ AMIs
Rule 2:
75+ nonBPCI AMI
Rule 3:
<50% BPCI
AMI
Colorado Springs, CO .........................................................
Columbia, MO ......................................................................
Columbia, SC .......................................................................
Columbus, GA-AL ................................................................
Columbus, IN .......................................................................
Columbus, OH .....................................................................
Corpus Christi, TX ...............................................................
Corvallis, OR ........................................................................
Crestview-Fort Walton Beach-Destin, FL ............................
Dallas-Fort Worth-Arlington, TX ..........................................
Dalton, GA ...........................................................................
Danville, IL ...........................................................................
Daphne-Fairhope-Foley, AL ................................................
Davenport-Moline-Rock Island, IA-IL ...................................
Dayton, OH ..........................................................................
Decatur, AL ..........................................................................
Decatur, IL ...........................................................................
Deltona-Daytona Beach-Ormond Beach, FL .......................
Denver-Aurora-Lakewood, CO ............................................
Des Moines-West Des Moines, IA ......................................
Detroit-Warren-Dearborn, MI ...............................................
Dothan, AL ...........................................................................
Dover, DE ............................................................................
Dubuque, IA .........................................................................
Duluth, MN-WI .....................................................................
Durham-Chapel Hill, NC ......................................................
East Stroudsburg, PA ..........................................................
Eau Claire, WI .....................................................................
El Centro, CA .......................................................................
Elizabethtown-Fort Knox, KY ...............................................
Elkhart-Goshen, IN ..............................................................
Elmira, NY ............................................................................
El Paso, TX ..........................................................................
Erie, PA ................................................................................
Eugene, OR .........................................................................
Evansville, IN-KY .................................................................
Fairbanks, AK ......................................................................
Fargo, ND-MN .....................................................................
Farmington, NM ...................................................................
Fayetteville, NC ...................................................................
Fayetteville-Springdale-Rogers, AR-MO .............................
Flagstaff, AZ ........................................................................
Flint, MI ................................................................................
Florence, SC ........................................................................
Florence-Muscle Shoals, AL ................................................
Fond du Lac, WI ..................................................................
Fort Collins, CO ...................................................................
Fort Smith, AR-OK ...............................................................
Fort Wayne, IN ....................................................................
Fresno, CA ...........................................................................
Gadsden, AL ........................................................................
Gainesville, FL .....................................................................
Gainesville, GA ....................................................................
Gettysburg, PA ....................................................................
Glens Falls, NY ....................................................................
Goldsboro, NC .....................................................................
Grand Forks, ND-MN ...........................................................
Grand Island, NE .................................................................
Grand Junction, CO .............................................................
Grand Rapids-Wyoming, MI ................................................
Grants Pass, OR .................................................................
Great Falls, MT ....................................................................
Greeley, CO .........................................................................
Green Bay, WI .....................................................................
Greensboro-High Point, NC .................................................
Greenville, NC .....................................................................
Greenville-Anderson-Mauldin, SC .......................................
Guayama, PR ......................................................................
Pass ..............
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asabaliauskas on DSK3SPTVN1PROD with RULES
CBSA_OMB
17820
17860
17900
17980
18020
18140
18580
18700
18880
19100
19140
19180
19300
19340
19380
19460
19500
19660
19740
19780
19820
20020
20100
20220
20260
20500
20700
20740
20940
21060
21140
21300
21340
21500
21660
21780
21820
22020
22140
22180
22220
22380
22420
22500
22520
22540
22660
22900
23060
23420
23460
23540
23580
23900
24020
24140
24220
24260
24300
24340
24420
24500
24540
24580
24660
24780
24860
25020
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231
Federal Register / Vol. 82, No. 1 / Tuesday, January 3, 2017 / Rules and Regulations
TABLE 1—MSA EXCLUSION RULE STATUS AND ELIGIBILITY FOR SELECTION STATUS FOR INCLUSION IN AMI AND CABG
EPMS IN THE PROPOSED RULE—Continued
MSA name
Rule 1:
75+ AMIs
Rule 2:
75+ nonBPCI AMI
Rule 3:
<50% BPCI
AMI
Gulfport-Biloxi-Pascagoula, MS ...........................................
Hagerstown-Martinsburg, MD-WV .......................................
Hammond, LA ......................................................................
Hanford-Corcoran, CA .........................................................
Harrisburg-Carlisle, PA ........................................................
Harrisonburg, VA .................................................................
Hartford-West Hartford-East Hartford, CT ...........................
Hattiesburg, MS ...................................................................
Hickory-Lenoir-Morganton, NC ............................................
Hilton Head Island-Bluffton-Beaufort, SC ............................
Homosassa Springs, FL ......................................................
Hot Springs, AR ...................................................................
Houma-Thibodaux, LA .........................................................
Houston-The Woodlands-Sugar Land, TX ..........................
Huntington-Ashland, WV-KY-OH .........................................
Huntsville, AL .......................................................................
Idaho Falls, ID .....................................................................
Indianapolis-Carmel-Anderson, IN .......................................
Iowa City, IA ........................................................................
Ithaca, NY ............................................................................
Jackson, MI ..........................................................................
Jackson, MS ........................................................................
Jackson, TN .........................................................................
Jacksonville, FL ...................................................................
Jacksonville, NC ..................................................................
Janesville-Beloit, WI ............................................................
Jefferson City, MO ...............................................................
Johnson City, TN .................................................................
Johnstown, PA .....................................................................
Jonesboro, AR .....................................................................
Joplin, MO ............................................................................
Kahului-Wailuku-Lahaina, HI ...............................................
Kalamazoo-Portage, MI .......................................................
Kankakee, IL ........................................................................
Kansas City, MO-KS ............................................................
Kennewick-Richland, WA ....................................................
Killeen-Temple, TX ..............................................................
Kingsport-Bristol-Bristol, TN-VA ..........................................
Kingston, NY ........................................................................
Knoxville, TN ........................................................................
Kokomo, IN ..........................................................................
La Crosse-Onalaska, WI-MN ...............................................
Lafayette, LA ........................................................................
Lafayette-West Lafayette, IN ...............................................
Lake Charles, LA .................................................................
Lake Havasu City-Kingman, AZ ..........................................
Lakeland-Winter Haven, FL .................................................
Lancaster, PA ......................................................................
Lansing-East Lansing, MI ....................................................
Laredo, TX ...........................................................................
Las Cruces, NM ...................................................................
Las Vegas-Henderson-Paradise, NV ..................................
Lawrence, KS ......................................................................
Lawton, OK ..........................................................................
Lebanon, PA ........................................................................
Lewiston, ID-WA ..................................................................
Lewiston-Auburn, ME ..........................................................
Lexington-Fayette, KY .........................................................
Lima, OH ..............................................................................
Lincoln, NE ..........................................................................
Little Rock-North Little Rock-Conway, AR ..........................
Logan, UT-ID .......................................................................
Longview, TX .......................................................................
Longview, WA ......................................................................
Los Angeles-Long Beach-Anaheim, CA ..............................
Louisville/Jefferson County, KY-IN ......................................
Lubbock, TX .........................................................................
Lynchburg, VA .....................................................................
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asabaliauskas on DSK3SPTVN1PROD with RULES
CBSA_OMB
25060
25180
25220
25260
25420
25500
25540
25620
25860
25940
26140
26300
26380
26420
26580
26620
26820
26900
26980
27060
27100
27140
27180
27260
27340
27500
27620
27740
27780
27860
27900
27980
28020
28100
28140
28420
28660
28700
28740
28940
29020
29100
29180
29200
29340
29420
29460
29540
29620
29700
29740
29820
29940
30020
30140
30300
30340
30460
30620
30700
30780
30860
30980
31020
31080
31140
31180
31340
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232
Federal Register / Vol. 82, No. 1 / Tuesday, January 3, 2017 / Rules and Regulations
TABLE 1—MSA EXCLUSION RULE STATUS AND ELIGIBILITY FOR SELECTION STATUS FOR INCLUSION IN AMI AND CABG
EPMS IN THE PROPOSED RULE—Continued
MSA name
Rule 1:
75+ AMIs
Rule 2:
75+ nonBPCI AMI
Rule 3:
<50% BPCI
AMI
Macon, GA ...........................................................................
Madera, CA ..........................................................................
Madison, WI .........................................................................
Manchester-Nashua, NH .....................................................
Manhattan, KS .....................................................................
Mankato-North Mankato, MN ..............................................
Mansfield, OH ......................................................................
¨
Mayaguez, PR .....................................................................
McAllen-Edinburg-Mission, TX ............................................
Medford, OR ........................................................................
Memphis, TN-MS-AR ...........................................................
Merced, CA ..........................................................................
Miami-Fort Lauderdale-West Palm Beach, FL ....................
Michigan City-La Porte, IN ..................................................
Midland, MI ..........................................................................
Midland, TX ..........................................................................
Milwaukee-Waukesha-West Allis, WI ..................................
Minneapolis-St. Paul-Bloomington, MN-WI .........................
Missoula, MT .......................................................................
Mobile, AL ............................................................................
Modesto, CA ........................................................................
Monroe, LA ..........................................................................
Monroe, MI ...........................................................................
Montgomery, AL ..................................................................
Morgantown, WV .................................................................
Morristown, TN ....................................................................
Mount Vernon-Anacortes, WA .............................................
Muncie, IN ............................................................................
Muskegon, MI ......................................................................
Myrtle Beach-Conway-North Myrtle Beach, SC-NC ............
Napa, CA .............................................................................
Naples-Immokalee-Marco Island, FL ...................................
Nashville-Davidson—Murfreesboro—Franklin, TN ..............
New Bern, NC ......................................................................
New Haven-Milford, CT .......................................................
New Orleans-Metairie, LA ...................................................
New York-Newark-Jersey City, NY-NJ-PA ..........................
Niles-Benton Harbor, MI ......................................................
North Port-Sarasota-Bradenton, FL .....................................
Norwich-New London, CT ...................................................
Ocala, FL .............................................................................
Ocean City, NJ ....................................................................
Odessa, TX ..........................................................................
Ogden-Clearfield, UT ...........................................................
Oklahoma City, OK ..............................................................
Olympia-Tumwater, WA .......................................................
Omaha-Council Bluffs, NE-IA ..............................................
Orlando-Kissimmee-Sanford, FL .........................................
Oshkosh-Neenah, WI ..........................................................
Owensboro, KY ....................................................................
Oxnard-Thousand Oaks-Ventura, CA .................................
Palm Bay-Melbourne-Titusville, FL ......................................
Panama City, FL ..................................................................
Parkersburg-Vienna, WV .....................................................
Pensacola-Ferry Pass-Brent, FL .........................................
Peoria, IL .............................................................................
Philadelphia-Camden-Wilmington, PA-NJ-DE-MD ..............
Phoenix-Mesa-Scottsdale, AZ .............................................
Pine Bluff, AR ......................................................................
Pittsburgh, PA ......................................................................
Pittsfield, MA ........................................................................
Pocatello, ID ........................................................................
Ponce, PR ............................................................................
Portland-South Portland, ME ...............................................
Portland-Vancouver-Hillsboro, OR-WA ...............................
Port St. Lucie, FL .................................................................
Prescott, AZ .........................................................................
Providence-Warwick, RI-MA ................................................
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asabaliauskas on DSK3SPTVN1PROD with RULES
CBSA_OMB
31420
31460
31540
31700
31740
31860
31900
32420
32580
32780
32820
32900
33100
33140
33220
33260
33340
33460
33540
33660
33700
33740
33780
33860
34060
34100
34580
34620
34740
34820
34900
34940
34980
35100
35300
35380
35620
35660
35840
35980
36100
36140
36220
36260
36420
36500
36540
36740
36780
36980
37100
37340
37460
37620
37860
37900
37980
38060
38220
38300
38340
38540
38660
38860
38900
38940
39140
39300
..............
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233
Federal Register / Vol. 82, No. 1 / Tuesday, January 3, 2017 / Rules and Regulations
TABLE 1—MSA EXCLUSION RULE STATUS AND ELIGIBILITY FOR SELECTION STATUS FOR INCLUSION IN AMI AND CABG
EPMS IN THE PROPOSED RULE—Continued
MSA name
Rule 1:
75+ AMIs
Rule 2:
75+ nonBPCI AMI
Rule 3:
<50% BPCI
AMI
Provo-Orem, UT ..................................................................
Pueblo, CO ..........................................................................
Punta Gorda, FL ..................................................................
Racine, WI ...........................................................................
Raleigh, NC .........................................................................
Rapid City, SD .....................................................................
Reading, PA .........................................................................
Redding, CA ........................................................................
Reno, NV .............................................................................
Richmond, VA ......................................................................
Riverside-San Bernardino-Ontario, CA ...............................
Roanoke, VA ........................................................................
Rochester, MN .....................................................................
Rochester, NY .....................................................................
Rockford, IL .........................................................................
Rocky Mount, NC ................................................................
Rome, GA ............................................................................
Sacramento—Roseville—Arden-Arcade, CA ......................
Saginaw, MI .........................................................................
St. Cloud, MN ......................................................................
St. George, UT ....................................................................
St. Joseph, MO-KS ..............................................................
St. Louis, MO-IL ...................................................................
Salem, OR ...........................................................................
Salinas, CA ..........................................................................
Salisbury, MD-DE ................................................................
Salt Lake City, UT ...............................................................
San Angelo, TX ...................................................................
San Antonio-New Braunfels, TX ..........................................
San Diego-Carlsbad, CA .....................................................
San Francisco-Oakland-Hayward, CA .................................
´
San German, PR .................................................................
San Jose-Sunnyvale-Santa Clara, CA ................................
San Juan-Carolina-Caguas, PR ..........................................
San Luis Obispo-Paso Robles-Arroyo Grande, CA ............
Santa Cruz-Watsonville, CA ................................................
Santa Fe, NM ......................................................................
Santa Maria-Santa Barbara, CA ..........................................
Santa Rosa, CA ...................................................................
Savannah, GA .....................................................................
Scranton—Wilkes-Barre—Hazleton, PA ..............................
Seattle-Tacoma-Bellevue, WA .............................................
Sebastian-Vero Beach, FL ..................................................
Sebring, FL ..........................................................................
Sheboygan, WI ....................................................................
Sherman-Denison, TX .........................................................
Shreveport-Bossier City, LA ................................................
Sierra Vista-Douglas, AZ .....................................................
Sioux City, IA-NE-SD ...........................................................
Sioux Falls, SD ....................................................................
South Bend-Mishawaka, IN-MI ............................................
Spartanburg, SC ..................................................................
Spokane-Spokane Valley, WA ............................................
Springfield, IL .......................................................................
Springfield, MA ....................................................................
Springfield, MO ....................................................................
Springfield, OH ....................................................................
State College, PA ................................................................
Staunton-Waynesboro, VA ..................................................
Stockton-Lodi, CA ................................................................
Sumter, SC ..........................................................................
Syracuse, NY .......................................................................
Tallahassee, FL ...................................................................
Tampa-St. Petersburg-Clearwater, FL ................................
Terre Haute, IN ....................................................................
Texarkana, TX-AR ...............................................................
The Villages, FL ...................................................................
Toledo, OH ..........................................................................
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Fail ................
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Pass ..............
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Pass ..............
Fail ................
Pass ..............
Pass ..............
Fail ................
Pass ..............
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Pass ..............
Pass ..............
Pass ..............
Pass ..............
Pass ..............
Fail ................
Pass ..............
Pass ..............
Pass ..............
Pass ..............
Fail ................
Pass ..............
Pass ..............
asabaliauskas on DSK3SPTVN1PROD with RULES
CBSA_OMB
39340
39380
39460
39540
39580
39660
39740
39820
39900
40060
40140
40220
40340
40380
40420
40580
40660
40900
40980
41060
41100
41140
41180
41420
41500
41540
41620
41660
41700
41740
41860
41900
41940
41980
42020
42100
42140
42200
42220
42340
42540
42660
42680
42700
43100
43300
43340
43420
43580
43620
43780
43900
44060
44100
44140
44180
44220
44300
44420
44700
44940
45060
45220
45300
45460
45500
45540
45780
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
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22:30 Dec 30, 2016
Jkt 241001
PO 00000
Frm 00055
Fmt 4701
Sfmt 4700
E:\FR\FM\03JAR2.SGM
03JAR2
MSA
eligible
for
selection
Include.
Include.
Include.
Exclude.
Include.
Include.
Include.
Include.
Include.
Include.
Include.
Include.
Include.
Include.
Include.
Include.
Include.
Include.
Include.
Include.
Include.
Include.
Include.
Include.
Include.
Include.
Include.
Include.
Exclude.
Include.
Include.
Exclude.
Include.
Exclude.
Include.
Exclude.
Include.
Include.
Include.
Include.
Include.
Include.
Include.
Include.
Exclude.
Include.
Include.
Exclude.
Include.
Include.
Exclude.
Include.
Include.
Include.
Exclude.
Include.
Exclude.
Exclude.
Include.
Include.
Exclude.
Include.
Include.
Include.
Include.
Exclude.
Include.
Include.
234
Federal Register / Vol. 82, No. 1 / Tuesday, January 3, 2017 / Rules and Regulations
TABLE 1—MSA EXCLUSION RULE STATUS AND ELIGIBILITY FOR SELECTION STATUS FOR INCLUSION IN AMI AND CABG
EPMS IN THE PROPOSED RULE—Continued
MSA name
Rule 1:
75+ AMIs
Rule 2:
75+ nonBPCI AMI
Rule 3:
<50% BPCI
AMI
Topeka, KS ..........................................................................
Trenton, NJ ..........................................................................
Tucson, AZ ..........................................................................
Tulsa, OK .............................................................................
Tuscaloosa, AL ....................................................................
Tyler, TX ..............................................................................
Urban Honolulu, HI ..............................................................
Utica-Rome, NY ...................................................................
Valdosta, GA ........................................................................
Vallejo-Fairfield, CA .............................................................
Victoria, TX ..........................................................................
Vineland-Bridgeton, NJ ........................................................
Virginia Beach-Norfolk-Newport News, VA-NC ...................
Visalia-Porterville, CA ..........................................................
Waco, TX .............................................................................
Walla Walla, WA ..................................................................
Warner Robins, GA .............................................................
Washington-Arlington-Alexandria, DC-VA-MD-WV .............
Waterloo-Cedar Falls, IA .....................................................
Watertown-Fort Drum, NY ...................................................
Wausau, WI .........................................................................
Weirton-Steubenville, WV-OH .............................................
Wenatchee, WA ...................................................................
Wheeling, WV-OH ...............................................................
Wichita, KS ..........................................................................
Wichita Falls, TX ..................................................................
Williamsport, PA ..................................................................
Wilmington, NC ....................................................................
Winchester, VA-WV .............................................................
Winston-Salem, NC .............................................................
Worcester, MA-CT ...............................................................
Yakima, WA .........................................................................
York-Hanover, PA ................................................................
Youngstown-Warren-Boardman, OH-PA .............................
Yuba City, CA ......................................................................
Yuma, AZ .............................................................................
Pass ..............
Pass ..............
Pass ..............
Pass ..............
Pass ..............
Pass ..............
Pass ..............
Pass ..............
Pass ..............
Pass ..............
Pass ..............
Pass ..............
Pass ..............
Pass ..............
Pass ..............
Fail ................
Pass ..............
Pass ..............
Pass ..............
Fail ................
Pass ..............
Pass ..............
Pass ..............
Pass ..............
Pass ..............
Pass ..............
Pass ..............
Pass ..............
Pass ..............
Pass ..............
Pass ..............
Pass ..............
Pass ..............
Pass ..............
Pass ..............
Pass ..............
Pass ..............
Pass ..............
Pass ..............
Pass ..............
Pass ..............
Pass ..............
Pass ..............
Pass ..............
Fail ................
Fail ................
Pass ..............
Fail ................
Pass ..............
Pass ..............
Pass ..............
Fail ................
Pass ..............
Pass ..............
Pass ..............
Fail ................
Pass ..............
Pass ..............
Pass ..............
Pass ..............
Pass ..............
Fail ................
Pass ..............
Pass ..............
Pass ..............
Pass ..............
Pass ..............
Pass ..............
Pass ..............
Pass ..............
Pass ..............
Pass ..............
Pass ..............
Pass ..............
Pass ..............
Pass ..............
Pass ..............
Pass ..............
Pass ..............
Pass ..............
Pass ..............
Fail ................
Pass ..............
Pass ..............
Fail ................
Pass ..............
Pass ..............
Pass ..............
Pass ..............
Pass ..............
Pass ..............
Pass ..............
Pass ..............
Pass ..............
Pass ..............
Pass ..............
Pass ..............
Fail ................
Pass ..............
Pass ..............
Pass ..............
Pass ..............
Pass ..............
Pass ..............
Pass ..............
Pass ..............
Pass ..............
Pass ..............
CBSA_OMB
asabaliauskas on DSK3SPTVN1PROD with RULES
45820
45940
46060
46140
46220
46340
46520
46540
46660
46700
47020
47220
47260
47300
47380
47460
47580
47900
47940
48060
48140
48260
48300
48540
48620
48660
48700
48900
49020
49180
49340
49420
49620
49660
49700
49740
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
..............
The following is a summary of the
comments received and our responses.
Comment: The issue of MSA
exclusions was a subject raised by a
variety of commenters. Commenters
expressed concerns with the possibility
of the same MSAs being selected for
inclusion in both the cardiac EPMs and
in the CJR model. Commenters stated
that the introduction of 3 new required
models simultaneously in MSAs where
CJR is still in the early stages of
implementation would divert
participants’ focus from being able to
successfully implement CJR and would
pose resource allocation challenges.
Commenters stated that hospitals have a
limited capacity to successfully take on
new models and that hospitals could
best achieve success when they are
allowed to focus on specific projects.
Commenters stated that adding too
many required models will result in
diluted resources given to each model
and increased administrative costs to
the hospital. One commenter expressed
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concern that implementing too many
models can compromise both the
success of the models and patient care.
Commenters requested that CMS add an
exclusion rule that removes the CJR
MSAs from the possibility of selection
as a cardiac EPM area.
Response: We acknowledges the
concern of CJR participant hospitals
with respect to having the capacity and
ability to take on the new cardiac and
SHFFT episodes in addition to their
current model participation. While
recognizing the logistical and resource
challenges of implementing multiple
models simultaneously, CMS believes
that there are commonalities between
the models that would result in some
efficiencies. For example, experiences
in CJR with creating gainsharing
approaches, analyzing claims feeds, and
understanding reconciliation
methodologies will be directly
transferable to managing the cardiac
episodes.
PO 00000
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MSA
eligible
for
selection
Include.
Include.
Include.
Include.
Include.
Include.
Include.
Include.
Exclude.
Exclude.
Include.
Exclude.
Exclude.
Include.
Include.
Exclude.
Include.
Include.
Include.
Exclude.
Include.
Include.
Include.
Include.
Include.
Exclude.
Include.
Include.
Include.
Include.
Include.
Include.
Include.
Include.
Include.
Include.
CMS considered the exclusion of CJR
MSAs from the possibility of selection
as a cardiac EPM. The effect of removing
the CJR MSAs was considered relative
to a variety of other considerations
including the impact of this removal on
the remaining MSAs and whether it
would create a biased pool due to the
disproportionate removal of areas with
high episode payments as well as areas
with a larger population.
In determining which areas were
eligible for selection for CJR, MSAs were
required to have at least 400 LEJRs in
the reference year. In contrast, the
equivalent exclusion rule for the cardiac
EPMs requires at least 75 AMI episodes.
These two different rules means that the
pool of MSAs eligible for selection as a
cardiac EPM contains many smaller
MSAs who were not eligible for
selection in CJR. Removing the CJR
MSA would disproportionately remove
larger cities from the selection pool and
the pool would be artificially weighted
towards MSAs with lower numbers of
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cases. The resulting random selection in
this pool would similarly be overweighted to select smaller areas with
lower numbers of episodes.
MSAs were selected for inclusion in
CJR by dividing MSAs into quartiles
based on the MSA average LEJR episode
spending. The likelihood of being
selected as a CJR area differed between
the quartiles such that MSAs in the least
expensive quartile had a 30% chance of
selection and MSAs in the most
expensive quartile had a 45% chance of
selection. Thus, the removal of the CJR
MSAs from the cardiac EPM selection
pool would disproportionately leave
relatively more efficient MSAs eligible
for selection and remove relatively
inefficient areas. In order to quantify the
extent of this potential bias, the impact
of removing the CJR areas was examined
relative to the average MSA spending
for AMI episodes. CJR MSAs
represented just 12% of MSAs in the
least expensive quartile (9 of 74) but
represented 26% of the MSAs in the
most expensive quartile (19 of 74).
In summary, because the CJR MSAs
were proportionately underweighted for
more efficient MSAs, and over weighted
for more expensive MSAs with higher
LEJR episode payments, their removal
resulted in introducing bias which
would result in the selection of more
small cities as well as more efficient
cities. This bias to disproportionally
select relatively more efficient MSAs is
counter to the overall orientation that
these models are most likely to result in
cost savings in inefficient areas.
Furthermore, CMS anticipates that an
increase in the probability of selection
in smaller cities may also be
problematic to commenters, many of
whom expressed concern with the
ability of hospitals with few cases to
succeed under the model.
CMS further notes that a variety of
models and efforts are currently
underway with the goal of controlling
health care costs. While this presents an
operationally challenging situation,
CMS hopes to be able to assess the
extent to which these different models
interact and complement (or compete
with) one another. The evaluation of
CJR and the EPMs will include a
systematic look at hospital experiences
in regard to model uptake given their
range of prior experience, capabilities,
and circumstances.
Comment: One commenter
recommended the exclusion of MSAs
with less than 20 CABG episodes per
quarter rather than basing the
exclusionary criteria only on AMI
volume episode volume.
Response: We continue to have a
strong interest in being able to observe
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how well EPMs operate in areas with a
lower volume of episodes, and, in
particular, the consequences of the
model for AMI episodes where CABG is
not commonly performed or where
standard practice is to refer all CABGs
outside of the MSA, and consequently,
does not find it appropriate to exclude
MSAs on the basis of CABG volume.
Comment: One commenter suggested
that MSAs with significant penetration
of Medicare Advantage Plans and
considerable ACO activity be excluded
from the possibility of selection. They
stated that the models should be
implemented in markets with more
limited alternative payment and/or
managed care activity. They suggested
that the selection of MSAs believed to
be fully invested in care design efforts
would make it challenging to evaluate
whether improvements in efficiency
were related to the EPMs or associated
with these other efforts. The commenter
stated that restricting to MSAs with
minimal involvement with other APM
would ease both administrative burden
and allow for better results and more
accurate reconciliation.
Response: While including MSAs
with experience in APMs may pose
challenges to the evaluation in its effort
to assess causation, CMS believes that
the exclusion of MSAs who may be
relatively more experienced in care
redesign and thus more likely to be able
to achieve success in the models would
be undesirable. It would be considered
a positive if participant hospitals are
able to leverage the knowledge and
experience of experts in their areas in
order to successfully reduce episode
spending in eligible patients.
Experience with care management
under managed care or within APMs
might be one source of expertise from
which participant hospitals may wish to
draw. The evaluation of EPMs will
include an examination of market
characteristics and model activity, so as
to explore how the overlapping nature
of these two factors impacts
performance.
Comment: One commenter expressed
the concern that some hospitals act as
regional referral centers or may
otherwise have a large proportion of the
beneficiaries they treat who reside
outside of the MSA where the hospital
is located. They expressed concern that
it would be difficult to manage care for
these beneficiaries in the post hospital
episode period due to this distance.
They requested that MSAs with a
significant percent of cases coming from
out of the state be excluded from the
possibility of selection.
Response: We recognize that many
hospitals treat patients from a wide
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235
catchment area and that this catchment
area may possibly extend beyond the
MSA. This situation is particularly
relevant to the CABG EPM. The
management of the beneficiary’s
recovery in the post hospital period may
be a challenge for some providers.
Multiple patient characteristics,
including the physical distance between
the beneficiary and the hospital, will
influence both what type of care
redesign approach will be most
appropriate and the likelihood that the
approach taken will result in improved
efficiency and quality. While distance
may pose a challenge to improving
patient coordination, it is one that many
providers have successfully undertaken.
Many providers, including regional
referral centers, have been able to form
and maintain relationships with
providers outside their communities.
CMS holds that regional referral
centers are a critical component of how
CAGB episodes are treated and, as such,
are an important part of the cardiac EPM
and to gaining an understanding of the
ability of such participants to manage
patient episodes.
Comment: Commenters expressed
concern that low-volume hospitals are
included in the models and requested
that thresholds be added to remove lowvolume providers from the model.
Commenters stated that lower volume
providers are subject to issues of
random variation and that the cost and
quality experiences observed in these
hospitals may not be due to efficiencies
and care coordination. They stated that
smaller hospitals will be at a
disadvantage due to the inability to
achieve stability or predictability due to
this variation.
Finally, a commenter noted that they
believed that minimum number of
applicable cases is necessary for a
hospitals to perform internal analyses to
determine the appropriate strategies to
use to successfully re-engineer care.
They stated that having a minimum
number of cases is a key factor in
whether or not a facility can be ready for
undertaking bundled payments.
Minimal numbers are necessary for
generating adequate levels of
involvement in potential partners such
as physicians and post-acute care
providers. The commenter proposed
that the definitions of minimal volume
used in the payment methodology be
used instead as minimal requirements
for hospitals to be required to
participate in the cardiac EPMs.
Response: We acknowledge the fact
that hospitals, particularly low-volume
hospitals, may have limited resources to
fully engage in care re-design efforts
and, due to the low volume, they are
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Federal Register / Vol. 82, No. 1 / Tuesday, January 3, 2017 / Rules and Regulations
much more susceptible to wider episode
cost fluctuations. We refer readers to the
following sections of this final rule
III.D.4.b.(9). of this final rule for a
discussion of how target prices for
hospitals with low volume are
determined and to III.D.7.c.(1). of this
final rule for a discussion of low volume
hospital protections under the cardiac
EPMs.
The inclusion of low-volume
hospitals in the EPMs is consistent with
the goal of evaluating the impact of
bundled payment and care redesign
across a broad spectrum of hospitals
with varying levels of infrastructure,
care redesign experience, market
position, and other considerations, and
circumstances. We are interested in
evaluating the experience of these
hospitals in the models as part of our
overall desire to see the impact of an
episode payment model in providers
who would not otherwise choose to
participate in a model. We would be
concerned that setting a threshold for
low volume could result in hospital
gaming in order to be below that
threshold and thus be excluded from the
models.
Similar to the CJR model, the design
of the EPMs and the inclusion of lowvolume providers within the models
reflects our interest in testing and
evaluating the impact of a bundled
payment approach for these procedures
in a variety of circumstances, especially
among those hospitals that may not
otherwise participate in such a test. The
inclusion of these providers allows CMS
to better appreciate and understand how
the models operate as a general payment
approach and its impact across a wide
range of hospitals. The impact of EPMs
on low-volume hospitals is of great
interest to the evaluation of these
models.
We acknowledge that providers with
low volumes of AMI, CABG, or CJR
cases may not find it advantageous to
engage in an active way with the EPMs.
We expect that low volume providers
may decide that their resources are
better targeted to other efforts because
they do not find the financial incentive
present in the EPMs sufficiently strong
to cause them to shift their practice
patterns. We believe this choice is
similar in nature to that made as
hospitals decide their overall business
strategies and where to focus their
attentions.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal, without
modification, to exclude MSAs that fail
one or more of the following rules:
Exclusion Rule 1: Exclude MSAs with
fewer than 75 AMI episodes
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(determined as discussed in section
III.C. of this final rule).
Exclusion Rule 2: Exclude MSAs with
fewer than 75 non-BPCI AMI episodes
in the MSA in the reference year.
Exclusion Rule 3: Exclude MSAs if
the number of non-BPCI AMI episodes
calculated under Exclusion Rule 2 is
less than 50 percent of the total number
of AMI episodes calculated under
Exclusion Rule 1.
As discussed in section III.B.2. of this
final rule, the Burlington Vermont MSA
was found to no longer be eligible for
possible selection because of the
Vermont All-Payer ACO Model. Thus,
293 MSAs out of 384 total MSAs are
eligible for the possibility of selection as
a cardiac EPM area.
b. Selection Approach
We proposed the selection of 98
MSAs for the cardiac EPMs through the
use of simple random selection from the
294 (now 293) eligible MSAs.
Simple random selection is often
considered to be an appropriate default
approach to experimental design unless
there is a compelling reason to depart
from it. One common alternative
approach is to perform random selection
separately within subgroups. Selection
within subgroups can be a useful
approach to limiting differences
between intervention and control
groups to improve statistical power or
for facilitating over or under sampling to
allow the evaluation to examine effects
of the intervention on particular types of
MSAs or because those types of MSAs
are of particular interest for policy
reasons.
In CJR, we used a stratified random
assignment approach in which we
organized MSAs into strata based on
MSA population size and historic LEJR
episode payments. Under the CJR
model, we believed a stratified approach
was appropriate due to wide regional
variation in prices, primarily associated
with the use of post-acute services. The
stratified approach served as a means to
oversample in higher-expense MSAs as
these areas have both the most need for
and the most opportunity under the CJR
model.
In assessing whether stratification
would be proposed for the EPMs, we
assessed a variety of factors described
later in this section. Absent
stratification, the rate at which a
particular type of MSA will appear in
the sample will be proportional to how
often in appears among eligible MSAs.
If a particular type of MSA is relatively
common, it is likely to occur often
enough that we do not need to
deliberately over-sample for it. In the
end, our analyses did not provide
PO 00000
Frm 00058
Fmt 4701
Sfmt 4700
sufficient evidence that it is necessary to
create selection subgroups of MSAs to
guide the selection approach. As a
result, we are proposing to use simple
random selection from the entire pool of
eligible MSAs.
(1) Factors Considered but Not Used
We considered a variety of possible
MSA characteristics for possible use in
classifying sub-groups. Though we did
consider many of these variables
important, we believe that a simple
random selection, where warranted, is
preferable.
Some of the factors we considered
that we are not proposing to use in the
selection methodology include the
following:
• Measures associated with AMIepisode and CABG episode wageadjusted spending, respectively. In
considering how to operationalize such
measures, we considered a number of
alternatives including average total
episode spending payments in an MSA,
average episode spending associated
with the initial hospital stay(s) and
average episode spending occurring in
the period after discharge from the
initial hospital.
• Measures associated with variation
in practice patterns associated with AMI
and CABG episodes. In considering how
to operationalize this measure, we
considered a number of alternatives
including the extent to which both an
AMI and a CABG episode are associated
with having a transfer hospital stay at
the beginning of the episode, and the
extent to which CABG hospitalizations
occur following a hospital transfer from
either within or from outside the same
MSA.
• Measures associated with relative
market share of providers with respect
to AMI and/or CABG episodes,
including the presence or absence of
regional referral centers and the number
of providers with the capacity to
perform CABGs or otherwise treat
complex cardiac patients.
• Health care supply measures of
providers in the MSA including acute or
post-acute bed counts, and number of
relevant physician specialties such as
cardiologists and cardiothoracic
surgeons.
• MSA-level demographic measures
such as: (1) Average income; (2)
distributions of population by age,
gender or race; (3) percent dually
eligible; and (4) percent with specific
health conditions or other demographic
composition measures.
• Measures associated with the
degree to which a market might be more
capable or ready to implement careredesign activities. Examples of market-
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level characteristics that might be
associated with anticipated ease of
implementation include the MSA-level
EHR meaningful-use levels, managedcare penetration, ACO penetration, and
experience with other bundling efforts.
Though these measures were not
proposed to be part of the selection
process, we acknowledge that these and
other market-level factors may be
important to the proper understanding
of the evaluation of the impact of EPMs.
We intend to consider these and other
measures in determining which MSAs
are appropriate comparison markets for
the evaluation and for possible
subgroup analysis or risk-adjustment
purposes. The evaluations will include
beneficiary-, provider-, and market-level
characteristics in how they will examine
the performance of the proposed EPMs.
The following is a summary of the
comments received and our responses.
Comment: A few commenters
expressed general support for the
selection approach. Several commenters
identified considerations that they
believed would increase the likelihood
of success in these models and believed
that those factors should influence the
likelihood of selection.
One commenter believed that the
selection methodology used should
instead select MSAs where there is
unwanted clinical or fiscal variation in
care. They stated that the
implementation of the cardiac EPMs in
these MSAs would be most likely to
target patients who would benefit from
novel care delivery initiatives. In
contrast, another commenter noted that
the implementation of the cardiac EPMs
in a variety of markets, including those
who are relatively more efficient, could
help with improving care management/
coordination overall.
One commenter mentioned that CMS
did not incorporate any MSA-level
demographic measures in its selection
process, such as distributions of
population by age, gender, or race;
percent of population dually eligible for
Medicare and Medicaid; percent of
population with specific health
conditions; and other demographic
composition measures. They believed
these factors vary not only between
MSAs, but also by hospitals within an
MSA, and could affect a hospital’s
chances of success in the proposed
EPMs.
Response: We appreciate the
suggestions of alternative MSA selection
criteria and note that we considered
whether to disproportionately select
higher cost areas. As discussed above,
the range of average episode costs
between MSAs was relatively narrow
and even relatively efficient MSAs
VerDate Sep<11>2014
22:30 Dec 30, 2016
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would have opportunity for care
redesign and increased efficiency under
these models. The examination of the
distribution of expenses did not seem to
indicate that there are substantial
pattern of care differences between
MSAs that needed to be recognized in
the selection methodology.
We acknowledge that demographic
factors may indeed influence the ability
of hospitals to succeed under the
models. However, in creating the EPMs,
we are seeking to understand how the
models impact costs and quality under
a variety of circumstances. We seek to
understand if the models work in both
more and less challenging
circumstances in order to be able to gain
an understanding of successes and
failures of the episodic payment
approach in all types of initiating
participants. We did not choose to
incorporate MSA level demographics in
our selection methodology but instead
we are relying on random selection to
include MSAs with a variety of
circumstances. We did not believe it
was necessary to preemptively oversample areas with a larger percent of
vulnerable patients.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal, without
modification, to select MSAs for
inclusion in the cardiac EPMs by simple
random selection.
(2) Sample-Size Calculations and the
Number of Selected MSAs
Our analyses of the necessary sample
size led us to propose the selection of
98 MSAs, to participate in both the AMI
and CABG EPMs. At the time of the
proposed rule 294 MSAs were eligible
for selection out of a total of 384 MSAs.
In this section, we discuss the
assumptions and modeling that went
into our proposal to test these EPMs in
98 MSAs. The discussion of the method
of selection of these 98 MSAs is
addressed in the following section. In
coming to the decision to target 98
MSAs, we are proposing an approach
that limits the size of the intervention to
the greatest degree possible, while still
ensuring that we have sufficient
statistical power to reliably evaluate the
effects of the EPMs. Going below this
threshold would jeopardize our ability
to be confident in our results and to be
able to generalize from the EPMs to the
larger national context.
In calculating the necessary size of the
AMI and CABG EPMs, a key
consideration was to have sufficient
power to be able to detect the desired
size impact. The larger the anticipated
size of the impact, the fewer MSAs we
would have to sample in order to
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237
observe it. However, a model sized to be
able to only detect large impacts runs
the risk of not being able to draw
conclusions if the size of the change is
less than anticipated. The measure of
interest used in estimating sample size
requirements for the both the AMI and
the CABG EPMs was wage-adjusted total
episode spending. The data used for the
wage-adjusted total episode spending is
the 3-year data pull previously
described that covers AMI and CABG
episodes with admission dates from July
1, 2012, through December 31, 2014. For
the purposes of the sample-size
calculation, we aim to be able to reliably
identify between a 2-percent and 3percent reduction in wage-adjusted
episode spending after 1 year of
experience. We chose this range because
those numbers represent the anticipated
amount of the discount proposed to
apply under various conditions of the
AMI and CABG EPMs’ implementation.
The next consideration in calculating
the necessary sample size is the degree
of certainty we will need for the
statistical tests that will be performed.
In selecting the right sample size, there
are two types of errors that need to be
considered: ‘‘false positives’’ and ‘‘false
negatives.’’ A false positive occurs if a
statistical test concludes that a model
was successful (that is, saved money)
when it in fact was not. A false negative
occurs if a statistical test fails to find
statistically-significant evidence that the
model was successful, when it in fact
was successful. In considering the
minimum sample size needs of the AMI
and CABG EPMs, a standard guideline
in the statistical literature suggests
calibrating statistical tests to generate no
more than a 5-percent chance of a false
positive and selecting the sample size to
ensure no more than a 20-percent
chance of a false negative. In contrast,
the proposed sample size for this project
was based on a 10-percent chance of a
false positive and no more than a 30percent chance of a false negative in
order to minimize reduce sample size
requirements to the greatest degree
possible.
A third consideration in the samplesize calculation was the appropriate
unit of selection and whether it is
necessary to base the calculation on the
number of MSAs, the number of
hospitals, or the number of episodes.
We proposed to base the sample size
calculation at the MSA level. The
proposed EPMs are an example of what
is known as a ‘‘nested comparative
study.’’ Under a nested comparative
study, assignment to an intervention or
comparison arms of the study is based
on membership in a pre-existing,
identifiable group where the groups are
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not formed at random, but rather
through some physical, social,
geographic, or other connection among
their members. Because these groups are
not formed at random, individual
members of each group are likely to
share important commonalities. In the
context of the proposed EPMs, spending
and outcomes for patients cared for
within a given MSA are relatively
similar to one another due to such
factors as the existence of common
practice or referral patterns, the
underlying health in the population,
and the availability of providers in an
area.
In statistical terms, these
commonalities create a positive
correlation (called an intra-class
correlation) among hospitals or
beneficiaries in the same MSA. Due to
that intra-class correlation, the
variability of any aggregate statistic—
such as the estimated difference in
outcomes between the intervention and
comparison arms of the study—has two
components—(1) variability attributable
to variation among hospitals or
beneficiaries in a given MSA; and (2)
variability attributable to differences
between MSAs. An accurate power
analysis must account for both
components of variability.
In determining the necessary sample
size, we take into consideration the
degree to which commonalities within
MSAs exist and the number of
independent beneficiaries and hospitals
expected to be included in the EPMs
within each MSA. As part of this
process, we empirically examined the
number of beneficiaries, the number of
hospitals, and the number of MSAs, as
well as the level of correlation in
episode payments between each level.
Based on this empirical examination,
we determined that the correlation was
high enough that the degree of
variability would be primarily driven by
the number of MSAs in the model,
indicating that the MSA is the
appropriate unit of analysis for the
power calculations.
Using the previously mentioned
assumptions, a power calculation for
AMI was run which indicated that at 98
MSAs we would be able to reliably
detect a 3-percent reduction in wageadjusted episode spending after 1 year
with a false-positive rate of 10 percent
and a false-negative rate of between 20
percent and 40 percent. We are targeting
a false-negative rate of 30 percent. The
extent to which this rate can be lowered
will depend on the ability of evaluation
models to substantially reduce variation
through risk adjustment and modeling.
We believe it is prudent to choose a
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sample size where the targeted amount
is in the middle of this expected band.
We separately assessed the samplesize needs associated with CABG
episodes. At 98 MSAs, we anticipate
being able to detect a 2.25-percent
reduction in wage-adjusted episode
expenditures after 1 year with a falsepositive rate of 10 percent and a falsenegative rate of between 20–40 percent.
The effective number of MSAs where
the CABG EPM will be tested will be
reduced because approximately 6
percent of eligible MSAs had no CABG
episodes in the reference year. However,
our power calculations do not lead us to
believe we need to increase the sample
size based on this fact. The number of
CABG MSAs can experience this
reduction and maintain equivalent
levels of power to the AMI episodes.
The following is a summary of the
comments received and our responses.
Comment: One commenter expressed
the opinion that the models should be
tested in 5 to 10 MSAs rather than be
done as a large scale test.
Response: As stated in the proposed
rule, we believe that the evidence base
related to episode payments is sufficient
enough to justify a large scale test and
we believe that it is appropriate to size
the models so as to be able to generate
statistically reliable estimates of the
impact as well as to be able to
understand how well the models
operate in a variety of circumstances.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal, without
modification, to select 98 MSAs to
participate in the cardiac EPMs.
(3) Method of Selecting MSAs
As previously discussed, we are
sought to choose 98 MSAs from our
pool of eligible MSAs through simple
random selection. We proposed to make
the selection in the proposed rule using
SAS Enterprise Guide 7.1 software to
run a computer algorithm SAS
Enterprise Guide 7.1 and the computer
algorithm used to conduct selection
represents an industry-standard for
generating advanced analytics and
provides a rigorous, standardized tool
by which to satisfy the requirements of
randomized selection. The key SAS
commands employed include a ‘‘PROC
SURVEYSELECT’’ statement coupled
with the ‘‘METHOD=SRS’’ option used
to specify simple random sampling as
the sample selection method. A random
number seed will be generated using the
birthdate of the person executing the
program.39
39 For more information on this procedure and the
underlying statistical methodology, please reference
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We sought comment on our proposal
to implement the AMI and CABG
models in the selected MSAs, some of
which may overlap with MSAs where
the CJR and SHFFT models also are
being implemented.
The following is a summary of the
comments received and our responses.
Comment: Comments were received
from multiple sources that expressed
that the list of selected MSAs be
published as soon as possible to allow
for better preparation for the start of the
models. One commenter requested that
the list of hospitals in the selected areas
also be published and that hospitals be
given 60 days to comment on its
accuracy. Commenters expressed a
preference that, in future rule making of
a similar nature, the list of selected
MSAs be displayed in the proposed rule
rather than the final rule to allow for
comment by the impacted MSAs and
additional preparation time.
Response: We appreciate the
suggestion that MSAs and affected
providers be published at the time of
rulemaking, and will take it under
advisement in any future rule. One of
the reasons for not selecting MSAs at
the time of the proposed rule was to
encourage all potentially impacted
providers to comment. In addition, we
wished to be able to maintain flexibility
that would allow for the creation of new
exclusion rules to be suggested in the
comment period without necessitating
the need to re-select MSAs between the
proposed and final rules. In order to
accommodate the later announcement of
impacted MSAs, we proposed a July 1,
2017 model start. This represents a
similar amount of time between the CJR
MSA announcement and the start of that
model as for the announcement of the
cardiac EPM MSAs and the finalization
of the SHFFT MSAs and the start of
those models.
The list of MSAs selected for the
cardiac EPM is included in TABLE 2.
The list of hospitals identified as in the
MSAs selected for the cardiac EPMs can
be found at https://innovation.cms.gov/
initiatives/epm/. Hospitals believing
that they have erroneously been
identified as being in a selected area
should send an email to epm@
cms.hhs.gov within 45 days of the
publication of the final rule. Hospitals
should include identifying information
including the hospital CCN. CMS will
periodically review and revise the list of
hospitals that meet the requirements for
participation in the cardiac EPMs and
SAS support documentation at: https://
support.sas.com/documentation/cdl/en/statug/
63033/HTML/default/viewer.htm#statug_
surveyselect_sect003.htm/.
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will update this information on https://
innovation.cms.gov/initiatives/epm/.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal, without
modification. We selected the
participating MSAs for the CABG and
AMI EPMs through simple random
selection. SAS for Windows Version 9.4
software was used to run a computer
algorithm designed to randomly select
MSAs. SAS for Windows Version 9.4
and the computer algorithm used to
conduct selection represents an industry
standard for generating advanced
analytics and provides a rigorous,
standardized tool by which to satisfy the
requirements of randomized selection.
The key SAS commands employed
include a ‘‘PROC SURVEYSELECT’’
statement coupled with the
‘‘METHOD=SRS’’ option used to specify
simple random sampling as the sample
selection method. The random number
seed utilized was 19730609.
The MSAs selected for inclusion are
shown in TABLE 2.
TABLE 2—MSAS SELECTED TO PARTICIPATE IN THE CARDIAC EPMS
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CBSA_OMB
10180
10420
10780
10900
11260
12100
12220
12420
13380
13460
14020
14260
14460
15940
15980
16020
16300
16700
16860
16980
17020
17660
17860
17900
17980
18880
19100
19300
19740
19780
20100
20500
21060
21500
21660
22520
22660
23060
23580
24300
24860
25940
26580
26820
26900
26980
27620
27860
27900
28020
28140
28420
29100
29420
29460
29620
30460
30620
30780
.................
.................
.................
.................
.................
.................
.................
.................
.................
.................
.................
.................
.................
.................
.................
.................
.................
.................
.................
.................
.................
.................
.................
.................
.................
.................
.................
.................
.................
.................
.................
.................
.................
.................
.................
.................
.................
.................
.................
.................
.................
.................
.................
.................
.................
.................
.................
.................
.................
.................
.................
.................
.................
.................
.................
.................
.................
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.................
VerDate Sep<11>2014
CJR
selected
MSA?
MSA name
Abilene, TX.
Akron, OH ..............................................................................................................................................................
Alexandria, LA.
Allentown-Bethlehem-Easton, PA-NJ.
Anchorage, AK.
Atlantic City-Hammonton, NJ.
Auburn-Opelika, AL.
Austin-Round Rock, TX .........................................................................................................................................
Bellingham, WA.
Bend-Redmond, OR.
Bloomington, IN.
Boise City, ID.
Boston-Cambridge-Newton, MA-NH.
Canton-Massillon, OH.
Cape Coral-Fort Myers, FL.
Cape Girardeau, MO-IL .........................................................................................................................................
Cedar Rapids, IA.
Charleston-North Charleston, SC.
Chattanooga, TN-GA.
Chicago-Naperville-Elgin, IL-IN-WI.
Chico, CA.
Coeur d’Alene, ID.
Columbia, MO ........................................................................................................................................................
Columbia, SC.
Columbus, GA-AL.
Crestview-Fort Walton Beach-Destin, FL.
Dallas-Fort Worth-Arlington, TX.
Daphne-Fairhope-Foley, AL.
Denver-Aurora-Lakewood, CO ..............................................................................................................................
Des Moines-West Des Moines, IA.
Dover, DE.
Durham-Chapel Hill, NC ........................................................................................................................................
Elizabethtown-Fort Knox, KY.
Erie, PA.
Eugene, OR.
Florence-Muscle Shoals, AL.
Fort Collins, CO.
Fort Wayne, IN.
Gainesville, GA ......................................................................................................................................................
Grand Junction, CO.
Greenville-Anderson-Mauldin, SC.
Hilton Head Island-Bluffton-Beaufort, SC.
Huntington-Ashland, WV-KY-OH.
Idaho Falls, ID.
Indianapolis-Carmel-Anderson, IN ........................................................................................................................
Iowa City, IA.
Jefferson City, MO.
Jonesboro, AR.
Joplin, MO.
Kalamazoo-Portage, MI.
Kansas City, MO-KS .............................................................................................................................................
Kennewick-Richland, WA.
La Crosse-Onalaska, WI-MN.
Lake Havasu City-Kingman, AZ.
Lakeland-Winter Haven, FL.
Lansing-East Lansing, MI.
Lexington-Fayette, KY.
Lima, OH.
Little Rock-North Little Rock-Conway, AR.
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yes.
yes.
yes.
yes.
yes.
yes.
yes.
yes.
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TABLE 2—MSAS SELECTED TO PARTICIPATE IN THE CARDIAC EPMS—Continued
CBSA_OMB
31540
31700
32780
32820
33340
33540
34820
34980
35100
35660
36420
36540
39140
39380
39580
39660
39740
39900
40060
40220
41100
41140
41420
41500
42340
43300
44060
44100
46060
46140
46220
46540
47940
48300
48620
48900
49180
49660
49740
.................
.................
.................
.................
.................
.................
.................
.................
.................
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Madison, WI ...........................................................................................................................................................
Manchester-Nashua, NH.
Medford, OR.
Memphis, TN-MS-AR ............................................................................................................................................
Milwaukee-Waukesha-West Allis, WI ....................................................................................................................
Missoula, MT.
Myrtle Beach-Conway-North Myrtle Beach, SC-NC.
Nashville-Davidson-Murfreesboro-Franklin, TN ....................................................................................................
New Bern, NC.
Niles-Benton Harbor, MI.
Oklahoma City, OK ................................................................................................................................................
Omaha-Council Bluffs, NE-IA.
Prescott, AZ.
Pueblo, CO.
Raleigh, NC.
Rapid City, SD.
Reading, PA ..........................................................................................................................................................
Reno, NV.
Richmond, VA.
Roanoke, VA.
St. George, UT.
St. Joseph, MO-KS.
Salem, OR.
Salinas, CA.
Savannah, GA.
Sherman-Denison, TX.
Spokane-Spokane Valley, WA.
Springfield, IL.
Tucson, AZ.
Tulsa, OK.
Tuscaloosa, AL ......................................................................................................................................................
Utica-Rome, NY.
Waterloo-Cedar Falls, IA.
Wenatchee, WA.
Wichita, KS ............................................................................................................................................................
Wilmington, NC.
Winston-Salem, NC.
Youngstown-Warren-Boardman, OH-PA.
Yuma, AZ.
C. Episode Definition for the EPMs
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1. Background
Episode payment models incentivize
improvement in the coordination and
quality of care experienced by a
Medicare beneficiary, as well as episode
efficiency, by bundling payment for
services furnished to the beneficiary for
specific clinical conditions over a
defined period of time. A key model
design feature is the definition of the
episodes included in the model. The
definition of episodes has two
significant dimensions—(1) a clinical
dimension that describes which clinical
conditions and associated services are
included in the episode; and (2) a time
dimension that describes the beginning,
middle, and end of the episode.
2. Overview of Three Episode Payment
Models
We proposed three new EPMs—AMI,
CABG, and SHFFT—that each begin
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selected
MSA?
MSA name
22:30 Dec 30, 2016
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with a hospitalization and extend 90
days after hospital discharge. The
proposed AMI model includes
beneficiaries discharged under an AMI
MS–DRG (280–282), representing
admission to an IPPS hospital for AMI
that is treated with medical
management, or an IPPS admission for
a PCI MS–DRG (246–251) with an
International Classification of Diseases
(ICD)—Clinical Modification (CM) AMI
diagnosis code describing an initial AMI
diagnosis in the principal or a
secondary diagnosis code position.
The proposed CABG model includes
beneficiaries discharged under a CABG
MS–DRG (231–236), representing an
IPPS admission for this coronary
revascularization procedure irrespective
of AMI diagnosis.
The proposed SHFFT model includes
beneficiaries discharged under hip and
femur procedures except major joint
MS–DRG (480–482), representing an
IPPS admission for a hip fixation
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yes.
yes.
yes.
procedure in the setting of a hip
fracture.
One reason these particular episodes
were chosen for the proposed EPMs is
that the initiation of treatment for each
of the three clinical conditions included
in an episode occurs almost exclusively
during a hospitalization, which we
believe would minimize the possibility
of shifting beneficiaries in or out of the
EPM based on the site-of-service where
treatment is initiated. The majority of
evaluation and treatment for AMI is
performed in the inpatient hospital
setting, commonly beginning when
beneficiaries present with symptoms to
the emergency department of a hospital.
Patients experiencing an AMI are almost
uniformly admitted to the hospital for
further evaluation and management.40
Although PCIs can be performed and
40 Amsterdam et al. 2014 AHA/ACC Guideline for
the Management of Patients with Non-ST-Elevation
Acute Coronary Syndromes. Circulation. 2014;
130:e344–e426.
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asabaliauskas on DSK3SPTVN1PROD with RULES
may be paid by Medicare in the hospital
outpatient setting in addition to being
performed during a hospitalization, the
majority of patients experiencing an
AMI who are candidates for procedural
revascularization receive PCI
procedures during the initial
hospitalization for AMI where
evaluation also occurs.41 CABG
procedures are furnished exclusively in
the inpatient hospital setting. We note
that all of the Current Procedural
Terminology (CPT) codes that
physicians report for CABG are listed on
the hospital Outpatient Prospective
Payment System (OPPS) inpatient-only
list in Addendum E of the 2017 OPPS
final rule with comment period that is
posted on the CMS Web site.42 The hip
fixation procedures performed in the
SHFFT model also are predominantly
furnished in the inpatient hospital
setting, and we further note that almost
all of the CPT codes that describe these
procedures also are on the OPPS
inpatient-only list.
Hospitals’ ability to identify EPM
beneficiaries during the hospitalization
that begins the episode (hereinafter the
anchor hospitalization) also is an
important consideration in developing
episode payment models that, like the
CJR model, rely upon MS–DRG
assignment for IPPS claims following
their submission in order to identify
beneficiaries for model inclusion. This
is especially important for medical
management of conditions for which the
predictability of the ultimate MS–DRG
for the hospitalization is less certain
than for surgical or procedural MS–
DRGs. AMI represents a relative
exception among medical conditions as
it is associated with specific clinical and
laboratory features that enable hospitals
to identify beneficiaries with AMI
during the anchor hospitalization whom
would likely be included in an AMI
episode through their ultimate discharge
under an AMI MS–DRG. We note that
ICD–CM coding rules allow AMI
diagnosis codes in both the primary and
secondary position to map to AMI MS–
DRGs.43 In the case of procedural
episodes such as CABG, SHFFT, and
41 Episodes for beneficiaries with AMI initiated
by all U.S. IPPS hospitals not in Maryland and
constructed using standardized Medicare FFS Parts
A and B claims, as proposed in the proposed rule,
that end in CY 2014.
42 https://www.cms.gov/Medicare/Medicare-Feefor-Service-Payment/HospitalOutpatientPPS/
Hospital-Outpatient-Regulations-and-NoticesItems/CMS-1656-FC.html.
43 Medical Severity Diagnosis Related Groups
(MS–DRGs): Definitions Manual. Version 33.0A. 3M
Health Information Systems. (October 1, 2015).
https://www.cms.gov/Medicare/Medicare-Fee-forService-Payment/AcuteInpatientPPS/FY2016-IPPSFinal-Rule-Home-Page-Items/FY2016-IPPS-FinalRule-Data-Files.html.
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AMI episodes for beneficiaries treated
with PCI, the MS–DRG for the
procedure performed would determine
the ultimate MS–DRG assignment for
the hospitalization unless additional
surgeries higher in the MS–DRG
hierarchy also are reported.44 Therefore,
we proposed these three EPMs for
clinical conditions where MS–DRG
assignment is likely to be certain and
known during the anchor
hospitalization, even though treatment
for AMI may involve only medical
management. We believe hospitals
participating in the proposed EPMs
would be able to identify beneficiaries
in EPM episodes through their AMI,
CABG, and SHFFT episode MS–DRGs
during the anchor hospitalization,
allowing active coordination of EPM
beneficiary care during and after
hospitalization.
3. Clinical Dimensions of AMI, CABG,
and SHFFT Episodes
As we stated in the CJR Final Rule, we
believe that a straightforward approach
for hospitals and other providers to
identify Medicare beneficiaries in these
episode payment models would be
important for the care redesign that is
required for EPM success, as well as for
operationalization of the proposed
payment and other EPM policies (80 FR
73299). Therefore, as in the CJR model,
we proposed that an EPM episode
would be initiated by an admission to
an acute care hospital for an anchor
hospitalization paid under EPM-specific
MS–DRGs under the IPPS (80 FR
73300).
The following is a summary of the
comments received and our responses:
Comment: Many commenters
expressed support for CMS’ proposal to
use many of the BPCI Model 2 and CJR
episode parameters to define EPM
episodes because of the provider
experience to date with these design
features and their applicability to the
clinical conditions that are the basis of
the EPMs. Several commenters
specifically recommended that CMS
begin EPM episodes with emergency
department care because including
beneficiaries with emergency
department care and observation status
would include all beneficiaries with the
clinical conditions that were included
in the proposed EPMs. While the
commenters acknowledged that many
beneficiaries with the clinical
44 Medical Severity Diagnosis Related Groups
(MS–DRGs): Definitions Manual. Version 33.0A. 3M
Health Information Systems. (October 1, 2015).
https://www.cms.gov/Medicare/Medicare-Fee-forService-Payment/AcuteInpatientPPS/FY2016-IPPSFinal-Rule-Home-Page-Items/FY2016-IPPS-FinalRule-Data-Files.html.
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241
conditions in the EPMs would be
admitted to the hospital, they believe
there is a subset of beneficiaries for
whom care could solely be furnished
through emergency department and
observation care. Other commenters
requested clarification on how a
beneficiary treated in observation status
and then transferred to another hospital
would be handled under the EPMs
because the beneficiary would never be
assigned to an MS–DRG at the initial
treating hospital. The commenters
believe that a hospital could use this
strategy to avoid including high-cost
beneficiaries in the EPMs. The
commenters stated that patient
stabilization is critical and the resources
needed to care for the beneficiary
should not dictate observation status
versus inpatient status due to a hospital
participation in an EPM. Several
commenters encouraged CMS to provide
additional guidance on instances when
the beneficiary is never admitted at the
initial hospital, but rather transferred
from the emergency department or
observation status to another hospital
for AMI or CABG.
One commenter recommended that
CMS modify the Episode Grouper for
Medicare (EGM) which, to date, has
only been considered for resource-use
measurement, to implement advanced
APMs designed around EPMs to correct
problems the commenter believes would
be present in the proposed EPMs that
would rely on MS–DRGs, including
limited severity adjustment, the limits
on who can bear risk, and the
inadequate incentives against
complications. The commenter claimed
that an acute care bundle in the hospital
setting is important, but so is managing
chronic conditions in an outpatient
setting (which often lead to acute
inpatient episodes). While contracting
for condition episodes and procedure
episodes separately is feasible and
creates a different level of
accountability, the commenter stated
that it is even more desirable to consider
contracting for the whole patient; that
is, procedure episodes should be
considered downstream events deeply
tied to the effective management of
condition episodes. The commenter
stated that the nested construction logic
of the EGM was designed with this in
mind.
A commenter contended that the
proposed structure for the new EPM
episodes would continue to reward
providers for complications. Payments
would be based on the beneficiary’s
assigned MS–DRG, so a complication of
care could move a low risk patient from
a lower paying MS–DRG to a higher
paying MS–DRG that could result in a
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significant increase in revenue. The
commenter believes the problem is
further compounded because it
penalizes providers who invest in
quality improvement. Providers that
invest time and resources into care
redesign that successfully reduces
complications that influence MS–DRG
assignment do not share in the savings
that they generate through their efforts.
The commenter stated that the MS–DRG
payment categorization creates a
substantial financial incentive to avoid
quality improvement in favor of
focusing on improving the management
of adverse events after they occur. The
commenters stated that the benefit of
using MS–DRG assignment in the EPMs
could be preserved without the perverse
incentive if the payment group for the
episode were assigned based on an MS–
DRG assignment that depended only on
diagnosis codes that were present on
admission.
Another commenter claimed that MS–
DRGs do not map well to care delivered
in post-acute care settings, especially for
chronically ill beneficiaries. MS–DRGs,
in identifying diagnoses and procedures
delivered in the acute care hospital
setting, often do not relate to the skilled
nursing needs, functional limitations, or
therapy/rehabilitation focused on in
post-acute care settings after hospital
discharge. Additionally, the commenter
pointed out that MS–DRGs do not take
into account a patient’s functional
status, which is an important indicator
for determining a patient’s post-acute
care needs. The commenter
recommended CMS to develop a more
robust risk adjustment methodology
under the EPMs, because MS–DRGs
alone are not sufficient for medically
complex patients. For those providers
caring for the sickest beneficiaries, the
commenter recommended that CMS
create separate bundled payments for
seriously ill beneficiaries, as defined by
something other than MS–DRG.
Response: We appreciate the support
that many commenters expressed for
our proposal to identify Medicare
beneficiaries included in the proposed
EPMs by their admission to an acute
care hospital for a hospitalization paid
under EPM-specific MS–DRGs under
the IPPS. We and many stakeholders
have gained substantial experience with
bundled payment models of a similar
design under BPCI Model 2 and the CJR
model. We agree with the many
commenters who stressed the
importance of EPM participants being
able to identify EPM beneficiaries on a
timely basis as early as possible during
the episodes in order to maximize the
opportunities for care redesign to
improve EPM episode quality and
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reduce costs. As we discussed in the
proposed rule (81 FR 50813), we believe
that a straightforward approach to EPM
model design that would allow
hospitals and other providers to identify
Medicare beneficiaries in these episode
payment models would be important for
the care redesign that is required for
EPM success, as well as for
operationalization of the proposed
payment and other EPM policies, and
agree with many commenters that our
proposed design of the EPMs meets
these objectives.
While we acknowledge the
perspective of some commenters that a
small number of beneficiaries with
clinical conditions that are the focus of
the EPMs, especially AMI, may be
appropriately treated in the emergency
department with observation status
without hospital admission, we believe
it is infeasible to include these
beneficiaries in the EPMs due to
complex operational challenges for CMS
and EPM participants and model design
parameters, such as appropriate pricing
in the context of varied hospital cardiac
care capabilities. We refer to section
III.C.4.a.(1) of this final rule for further
discussion of comments on outpatient
treatment scenarios and our responses.
We refer to section III.C.4.a.(5) of this
final rule for discussion of outpatient-toinpatient (o–i) transfer scenarios for
beneficiaries with AMI, including when
AMI episodes would begin and to which
hospital the episode would be
attributed. We agree with the
commenters that patient stabilization of
serious conditions such as AMI in the
emergency department of a hospital is
critical and the resources needed to care
for the beneficiary should not dictate
observation status versus inpatient
status due to a hospital participation in
an EPM. We believe our final EPM
policies, including our AMI model
transfer policies, reflect our
commitment to ensuring that the initial
care of beneficiaries with urgent
conditions such as those targeted by the
EPMs is not influenced by hospital
participation in an EPM. We also refer
to sections III.G.4. through 6. of this
final rule for discussion of our
monitoring plans to detect changing
patterns of care under the EPMs,
including practices that could indicate
that medically complex beneficiaries
who otherwise would be expected to be
in high-cost EPM episodes do not
initiate EPM episodes.
While we have an interest in future
condition-specific episode payment
models and sought public comment on
this topic in the proposed rule (81 FR
50810 through 50811), we have not
identified long-term management of
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beneficiaries with chronic disease as the
focus of these EPMs, which are
proposed to extend 90 days posthospital discharge from an anchor
hospitalization for beneficiaries who
have cardiac or orthopedic surgery or a
cardiac event.
As one commenter pointed out, MS–
DRGs currently provide higher
payments for beneficiaries who
experience complications during the
inpatient hospitalization and we
appreciate the interest of the commenter
in EPMs that encourage improvement in
quality of care during the anchor
hospitalization for which hospitals
would be rewarded. However, given the
operational challenges that EPMs that
require participation present for EPM
participants and CMS, it would be
infeasible in models like the EPMs to
regroup beneficiaries to different MS–
DRGs for setting EPM episode prices
based only on their diagnoses that were
present on admission to address
underlying payment incentives under
the IPPS. Instead, the EPMs focus EPM
participants on care redesign to improve
the quality of care for EPM beneficiaries
that may achieve internal hospital cost
savings for the anchor hospitalization
and/or savings to Medicare in the posthospital discharge period. We expect
that some of those care redesign
strategies that improve care
coordination for EPM beneficiaries may
have spill-over effects that result in
reduced in-hospital complications as
well.
Finally, we refer to section
III.D.4.b.(2) of this final rule for a
discussion of risk adjustment under the
EPMs. Because all EPM participants
care for some seriously ill beneficiaries,
some hospitals may disproportionately
care for such beneficiaries due to their
service area, referral patterns, and/or
specialized hospital capacity. We
believe appropriate risk adjustment of
EPM episode prices, particularly by
performance year 3 when the pricing
blend shifts to reflect predominantly
regional pricing, addresses the
commenter’s concern that led them to
recommend that CMS create separate
bundled payments for seriously ill
beneficiaries as defined by something
other than MS–DRG for those providers
caring for the sickest patients. While we
agree with the commenter that MS–
DRGs only reflect the resources for the
anchor hospitalization and, therefore,
do not necessarily reflect the post-acute
care resources required by a beneficiary,
we note that the IPPS payment for the
anchor hospitalization is included in
the EPM episode and constitutes, on
average, a significant percentage of the
EPM episode spending, specifically 33
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percent of AMI episode spending for
episodes anchored by AMI MS–DRGs;
58 percent of AMI episode spending for
episodes anchored by PCI MS–DRGs; 63
percent of CABG episode spending; and
27 percent of SHFFT episode
spending.45 Thus, we do not believe it
is necessary or appropriate to create
separate bundled payments for seriously
ill beneficiaries defined by a grouping
other than MS–DRG, because the
specific MS–DRG of the anchor
hospitalization determines a significant
percentage of spending for the episode
for EPM beneficiaries, including
seriously ill beneficiaries.
Comment: Several commenters
expressed concern about EPM
participants’ ability to identify EPM
beneficiaries on a timely basis. The
commenters explained that the final
MS–DRGs assigned to the beneficiary’s
hospitalization is not generated until
several days post-discharge, thus
impacting the EPM participant’s ability
to predict whether a beneficiary is in or
out of an EPM episode at the time the
beneficiary is in the hospital. One
commenter added that because the MS–
DRG is assigned to a patient’s case upon
discharge, it may not be predictable
during a patient’s treatment prior to
discharge, making it difficult for
providers to implement care redesign
targeted to a patient population
identified by MS–DRGs. This
commenter believes that the MS–DRGs
assigned to a patient’s stay are often
inaccurate or otherwise inappropriate
for the patient’s diagnosis, making the
classification an inappropriate basis for
episode triggers, budgets, quality
measurement and adjusting for
underlying patient illnesses. Another
commenter reported on their BPCI
Model 2 experience where 70 percent of
model beneficiaries were elective
admissions, and 30 percent presented to
the hospital through the emergency
department. Given that the proposed
EPMs would be more similar to the
commenter’s experience with
emergency department admissions, the
commenter expressed concern that the
EPMs would limit an EPM participant’s
ability to intervene with the beneficiary
prior to admission and skepticism that
the participant could even identify the
beneficiary as being eligible for the EPM
prior to hospital discharge. The
commenter added that with very sick
patients, hospitals often must wait for
the appropriate coding to confirm which
45 Episodes for AMI, CABG, and SHFFT
beneficiaries initiated by all U.S. IPPS hospitals not
in Maryland and constructed using standardized
Medicare FFS Parts A and B claims, as proposed in
the proposed rule that began in CYs 2012–2014.
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MS–DRG the patient ultimately is
assigned to prior to billing.
Several commenters further stated
that precedence rules among different
models and programs can touch the
same beneficiary, and stated that
hospital case managers, nurses, and
administrators cannot know at
admission or even before discharge
which model the beneficiary may
already be enrolled in or attributed to
based on prior utilization.
Response: We appreciate the interest
of the commenters in the timely
identification of EPM beneficiaries that
would allow EPM participants the most
significant opportunity to influence the
care of these beneficiaries to improve
the quality and reduce the cost of EPM
episodes. While we appreciate that
many EPM beneficiaries would be
admitted to the hospital on an
emergency basis for treatment of hip
fracture, AMI, or CABG surgery under
circumstances that would not allow
EPM participants to engage these
beneficiaries prior to hospital
admission, we believe that our
proposals for the clinical conditions in
the EPMs make identification of most
EPM beneficiaries unambiguous while
they are still in the hospital, without a
need for hospitals to wait for coding
following discharge to confirm which
MS–DRG the patient ultimately is
assigned to for the hospitalization.
As we stated in the proposed rule (81
FR 50829), we agree with the
commenters that hospitals’ ability to
identify EPM beneficiaries during the
anchor hospitalization is an important
consideration in developing episode
payment models that rely upon MS–
DRG assignment for IPPS claims
following their submission in order to
identify beneficiaries for model
inclusion. We believe the identification
of SHFFT and CABG model
beneficiaries should be straightforward
for EPM participants because the
relevant MS–DRG assignments directly
result from the surgical procedure
performed during the hospitalization
and would, therefore, be accurate.
However, identification of beneficiaries
for a model focused on medical
management of conditions may be more
challenging because the predictability of
the ultimate MS–DRG for the
hospitalization is less certain than for
surgical or procedural MS–DRGs. We
believe that AMI represents a relative
exception among medical conditions as
it is associated with specific clinical and
laboratory features that should enable
hospitals to identify beneficiaries with
AMI during the anchor hospitalization
who are treated medically or with PCI
and who would likely be included in an
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243
AMI episode through their ultimate
discharge under an AMI MS–DRG.
Therefore, we proposed these three
EPMs for clinical conditions where MS–
DRG assignment is likely to be certain
and known during the anchor
hospitalization, even though treatment
for AMI may involve only medical
management. We believe hospitals
participating in the proposed EPMs
would generally be able to identify
beneficiaries in EPM episodes through
their AMI, CABG, and SHFFT episode
MS–DRGs during the anchor
hospitalization, allowing active
coordination of EPM beneficiary care
during and after hospitalization.
We refer to section III.D.6.c. of this
final rule for discussion of issues related
to beneficiaries whose care could be
included in the EPMs as well as other
CMS models and programs.
Comment: One commenter expressed
appreciation for CMS’ intent to not have
overlap between the same care for a
beneficiary in episodes under more than
one EPM. The commenter sought
clarification about how CMS would
attribute episodes that originate with
one EPM and then cross over into
another EPM. The commenter provided
an example of a beneficiary with a
surgical hip fracture who has an AMI
during the hospitalization that is coded
in a secondary position, yet the
precipitating event for the hip fracture
was through syncope and a fall.
Response: When an IPPS claim is
submitted to Medicare for payment of a
beneficiary’s hospitalization, the claim
is grouped to an MS–DRG using the
MS–DRG grouper, a software that uses
ICD–10–CM diagnosis and procedures
codes submitted on the hospital claim to
assign an acute hospital stay to a
particular MS–DRG. Claims are assigned
to an MS–DRG using the grouper
effective for the discharge date of the
claim. Under the EPMs, regardless of the
chronology and causality of events that
led to the diagnoses and treatment
during the hospitalization, we would
rely upon the MS–DRG (and the
presence of an ICD–10–CM AMI
diagnosis code on the claim in the case
of a PCI MS–DRG) assigned to the claim
following hospital discharge to initiate
an EPM episode and define the EPM to
which the beneficiary’s care would be
attributed. In the commenter’s example
in which a patient is admitted to a
hospital for surgical hip fracture fixation
and has an AMI during the
hospitalization, the MS–DRG grouper
would assign a SHFFT MS–DRG to that
hospitalization. Therefore, the
beneficiary would initiate a SHFFT
episode if the hospital is a SHFFT
model participant. Regardless of
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whether or not the hospital is an AMI
model participant, no AMI episode
would be initiated.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal to initiate EPM
episodes by an admission to an acute
care hospital for an anchor
hospitalization paid under EPM-specific
MS–DRGs under the IPPS, without
modification. We refer to section
III.D.4.a.(5) of this final rule for a
discussion of outpatient-to-inpatient
and inpatient-to-inpatient transfers
between hospitals under the AMI
model. We refer to section III.D.6.c of
this final rule for further discussion of
issues related to overlap of beneficiaries
in other Innovation Center models and
CMS programs.
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a. Definition of the Clinical Conditions
Included in AMI, CABG, and SHFFT
Episodes
(1) AMI (Medical Management and PCI)
Model
We proposed the AMI model to
incentivize improvements in the
coordination and quality of care, as well
as episode efficiency, for beneficiaries
treated for AMI with either medical
management or coronary artery
revascularization with PCI. We
proposed to define beneficiary inclusion
in the AMI model by discharge under an
AMI MS–DRG (280–282), representing
those individuals admitted with AMI
who receive medical therapy but no
revascularization, and discharge under a
PCI MS–DRG (246–251) with an ICD–
10–CM diagnosis code of AMI on the
IPPS claim for the anchor
hospitalization in the principal or
secondary diagnosis code position. We
note that we would use AMI
International Classification of Diseases,
9th revision clinical modification (ICD–
9–CM) diagnosis codes to identify
historical episodes for setting AMI
model-episode benchmark prices in the
early performance years of the AMI
model. The Uniform Hospital Discharge
Data Set (UHDDS) defines the principal
diagnosis for hospitalization as ‘‘that
condition established after study to be
chiefly responsible for occasioning the
admission of the patient to the hospital
for care’’ and other (secondary)
diagnoses as ‘‘all conditions that coexist
at the time of admission, that develop
subsequently, or that affect the
treatment received and/or the length of
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stay. Diagnoses that relate to an earlier
episode which have no bearing on the
current hospital stay are to be
excluded.’’ 46 We proposed to include
those beneficiaries discharged under
PCI MS–DRGs with an AMI ICD–10–CM
diagnosis code in the principal or
secondary diagnosis code position to
ensure that beneficiaries with an AMI
that is not chiefly responsible for
occasioning the hospitalization are
included in the AMI model because the
AMI itself is likely to substantially
influence the hospitalization and postdischarge recovery (and be responsible
for leading to the PCI) even if an AMI
ICD–10–CM diagnosis code is reported
in a secondary diagnosis code position.
For example, a beneficiary receiving a
PCI with an ICD–10–CM diagnosis code
of pneumonia in the principal position
and an AMI ICD–10–CM diagnosis code
in a secondary position would be
included in the AMI model, which
would be appropriate because the
course of the beneficiary’s recovery and
management during the AMI episode
would be primarily associated with the
AMI and PCI. While pneumonia is
typically an acute illness that may
sometimes result in hospitalization,
underlying chronic conditions may
increase the likelihood that a
beneficiary would be hospitalized for
pneumonia, a condition that is more
commonly treated on an outpatient
basis. AMI in association with a
hospitalization for pneumonia would
represent a sentinel event for the
beneficiary resulting from underlying
CAD that signals a need for a heightened
focus on medical management of CAD
and other beneficiary risk factors for
future cardiac events that may
themselves have increased the
beneficiary’s risk for pneumonia. Thus,
care coordination and management in
the 90 days post-hospital discharge for
these beneficiaries would be focused on
managing CAD and the beneficiary’s
cardiac function after the AMI.
In the proposed rule (81 FR 50830),
we acknowledged that this proposal to
identify beneficiaries included in the
AMI model through a combination of
MS–DRGs and AMI ICD–CM diagnosis
codes represented a modification of the
CJR episode definition methodology.
The CJR model defined episodes based
46 https://www.cdc.gov/nchs/data/icd/icd10cm_
guidelines_2014.pdf.
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on MS–DRGs alone, specifically MS–
DRG 469 (Major joint replacement or
reattachment of lower extremity with
Major Complications or Comorbidities
(MCC)) and MS–DRG 470 (Major joint
replacement or reattachment of lower
extremity without MCC), because the
anchor hospitalization for the CJR
model was defined by admission for a
surgical procedure alone (80 FR 73280).
However, the proposed AMI episodes
would be defined by admission for a
medical condition that includes a range
of treatment options, including medical
treatment and PCI. Therefore, to identify
beneficiaries admitted for AMI and
treated with PCI requires ICD–CM
diagnosis codes paired with MS–DRGs
to identify the subset of PCI MS–DRG
cases associated with AMI that would
otherwise be excluded from an AMI
model based solely on AMI MS–DRGs.
For the purposes of defining historical
AMI episodes, we proposed to exclude
beneficiaries discharged under PCI MS–
DRGs with an AMI ICD–9–CM diagnosis
code in the principal or secondary
position if there was an intracardiac
ICD–9–CM procedure code in any
procedure code field. Intracardiac
procedure codes do not represent PCI
procedures indicated for the treatment
of the coronary artery obstruction that
results in AMI, but instead represent a
group of procedures indicated for
treating congenital cardiac
malformations, cardiac valve disease,
and cardiac arrhythmias. These
intracardiac procedures are performed
within the heart chambers rather than
PCI procedures for AMI that are
performed within the coronary blood
vessels. To reflect this clinical
distinction, the FY 2016 IPPS update
removed intracardiac procedures from
MS–DRGs 246–251 and assigned them
to new MS–DRGs 273 and 274 (80 FR
49367). Therefore, to be consistent with
our proposed definition of AMI
episodes that initiate with PCI MS–
DRGs 246–251 (not with MS–DRGs 273
and 274) and an AMI ICD–9–CM
diagnosis code in the principal or
secondary position, we proposed to
define historical AMI episodes for
beneficiaries discharged under PCI MS–
DRGS 246–251 as those that do not
include the ICD–9–CM procedure codes
in Table 3. These codes were also
posted on the CMS Web site at https://
innovation.cms.gov/initiatives/epm.
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245
TABLE 3—PROPOSED ICD–9–CM PROCEDURE CODES IN ANY POSITION ON THE IPPS CLAIM FOR PCI MS–DRGS (246–
251) THAT DO NOT DEFINE HISTORICAL AMI EPISODES
ICD–9–CM procedure code
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35.52
35.96
35.97
37.26
37.27
37.34
37.36
37.90
ICD–9–CM procedure code description
..................................................................................
..................................................................................
..................................................................................
..................................................................................
..................................................................................
..................................................................................
..................................................................................
..................................................................................
In FY 2014, there were approximately
395,000 beneficiaries discharged from a
short-term acute care hospitalization
(excluding Maryland) with an AMI ICD–
9–CM diagnosis code in the principal or
secondary position on the IPPS claim.
Of these beneficiaries, 58 percent were
discharged under MS–DRGs that would
initiate an AMI episode, specifically an
AMI MS–DRG (33 percent) and PCI MS–
DRG (25 percent). Five percent of
beneficiaries were discharged from
CABG MS–DRGs and 3 percent were
discharged from AMI MS–DRGs
representing death during the
hospitalization. The remaining 34
percent of beneficiaries with an AMI
ICD–CM diagnosis code in the principal
or secondary position were distributed
across over approximately 300 other
MS–DRGs, with the septicemia MS–
DRGs accounting for 8 percent and the
remainder accounting for 3 percent or
less of beneficiaries with an AMI ICD–
CM diagnosis code on the IPPS claim.47
We note that the AMI ICD–9–CM
diagnosis code was most commonly in
a secondary position for discharges from
these other MS–DRGs, likely
representing beneficiaries hospitalized
for another condition who experienced
an AMI during that hospitalization. We
further note that CMS’ AMI quality
measures used in the Hospital Inpatient
Quality Reporting (HIQR) Program are
based on all beneficiaries discharged
under any MS–DRG who have an AMI
ICD–CM diagnosis code only in the
principal position, reflecting the
measures’ focus on the most
homogeneous beneficiary population
with AMI as the condition responsible
for occasioning the hospital admission.
This is in contrast with our proposed
use of an AMI ICD–10–CM diagnosis
code in the principal or a secondary
position for the AMI model in order to
identify those beneficiaries receiving a
PCI whose hospitalization and postdischarge recovery and management
47 Inpatient
claims from all U.S. IPPS hospitals
not in Maryland were derived from the October
2013—September 2014 Inpatient Claims File
located in the Chronic Conditions Warehouse.
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Repair of atrial septal defect with prosthesis, closed technique.
Percutaneous balloon valvuloplasty.
Percutaneous mitral valve repair with implant.
Catheter based invasive electrophysiologic testing.
Cardiac mapping.
Excision or destruction of other lesion or tissue of heart, endovascular approach.
Excision, destruction, or exclusion of left atrial appendage.
Insertion of left atrial appendage device.
would primarily be associated with the
PCI and AMI.
The proposed specifications for AMI
episodes, including ICD–9–CM AMI
diagnosis codes for historical episodes
used to set the initial AMI modelepisode benchmark prices and ICD–10–
CM AMI diagnosis codes for the
performance years of the model, are
displayed in Table 5. The proposed
ICD–9–CM intracardiac procedure codes
used to exclude inpatient claims with
PCI MS–DRGs 246–251 from anchoring
AMI model historical episodes used to
set initial AMI model-episode
benchmark prices are displayed in Table
3.
Based on Medicare claims data for
historical AMI episodes ending in CYs
2012–2014, the annual number of
potentially eligible beneficiary
discharges for the AMI model nationally
was approximately 168,000.48 This
number was less than the approximately
229,000 discharges for beneficiaries
with AMI discharged from AMI MS–
DRGs 280–282 and PCI MS–DRGs 246–
251 that could be expected to be
included in the AMI model for several
reasons. Discharges did not result in
historical episodes when a beneficiary
did not meet the beneficiary care
inclusion criteria discussed in section
III.C.4.a.(1) of the proposed rule (81 FR
50834); was not discharged alive from
PCI MS–DRGs 246–251; was discharged
from a transfer hospital during a
chained anchor hospitalization; or was
discharged from a readmission during
an AMI episode that did not initiate
new model episodes.
The list of ICD–9–CM and ICD–10–
CM AMI diagnosis codes used to
identify beneficiaries discharged under
a PCI MS–DRG (MS–DRGs 246–251) in
historical episodes and during the
performance years of the model that
would be included in the AMI episodes
were discussed in section III.C.4.a.(2) of
48 Episodes for AMI beneficiaries initiated by all
U.S. IPPS hospitals not in Maryland and
constructed using standardized Medicare FFS Parts
A and B claims, as proposed in the proposed rule
that began in CYs 2012–2014.
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the proposed rule (81 FR 50834 through
50835). To make changes to this list as
necessary based on annual ICD–10–CM
coding changes or to address issues
raised by the public throughout the EPM
performance years, we proposed
implementing the following subregulatory process, which mirrors the
sub-regulatory process as described in
the CJR Final Rule for updating hip
fracture ICD–9–CM and ICD–10–CM
diagnosis codes (80 FR 73340) and for
updating the exclusion list (80 FR 73305
and 73315). We proposed to use this
process on an annual, or more frequent,
basis to update the AMI ICD–10–CM
diagnosis code list and to address issues
raised by the public. As part of this
process, we proposed the following
standard when revising the list of ICD–
10–CM diagnosis codes representing
AMI: The ICD–10–CM diagnosis code is
sufficiently specific that it represents an
AMI. We proposed to then post a list of
potential AMI ICD–10–CM diagnosis
codes to the CMS Web site at https://
innovation.cms.gov/initiatives/epm to
allow for public input on our planned
application of these standards, and then
adopt the AMI ICD–10–CM diagnosis
code list with posting to the CMS Web
site of the final AMI ICD–CM diagnosis
code list after our consideration of the
public input. We would provide
sufficient time for public input based on
the complexity of potential revisions
under consideration, typically at least
30 days, and, while we would not
respond to individual comments as
would be required in a regulatory
process, we could discuss the reasons
for our decisions about changes in
response to public input with interested
stakeholders.
The proposals for identifying the
beneficiaries included in the AMI model
and the sub-regulatory process for
updating the AMI ICD–10–CM diagnosis
code list were included in proposed
§ 512.100(c)(1) and (d), respectively. We
sought comment on our proposals to
identify beneficiaries included in the
AMI model and the sub-regulatory
process for updating the AMI ICD–10–
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CM diagnosis code list. The proposal to
exclude inpatient claims with PCI MS–
DRGS 246–251 from anchoring AMI
model historical episodes used to set
initial AMI model-episode benchmark
prices when there was an ICD–9–CM
intracardiac procedure code on the
claim was included in proposed
§ 512.100(d)(4). We sought comment on
our proposal to exclude inpatient claims
with PCI MS–DRGS 246–251 from
anchoring AMI model historical
episodes used to set initial AMI modelepisode benchmark prices when there
was an ICD–9–CM intracardiac
procedure code on the claim.
We received no comments on the
proposed sub-regulatory process for
updating the AMI ICD–10–CM diagnosis
code list. The following is a summary of
the comments received on the other
AMI model proposals to define the
included clinical conditions and our
responses.
Comment: Several commenters
expressed concern that the AMI model
would be so heavily reliant upon coding
that creates an artificial clinical
population which is so heterogeneous as
to make clinical care redesign efforts
nonspecific and likely ineffective. They
contended that while EPMs based on
surgical MS–DRGs streamline patient
identification and inclusion, the AMI
model would depend on multiple levels
of coding, both ICD–10–CM and MS–
DRGs. One commenter explained that
an important distinction between
medical diagnosis and procedural-based
episode-of-care models is that medical
diagnosis models tend to involve a
patient population of greater
complexity, often with life-threating
conditions. The commenter believes
that, where appropriate, this awareness
should be reflected in the design of the
EPMs. The commenters were concerned
that the proposed AMI model would put
a greater emphasis on coding
methodologies and increase the chance
of disparities between cases identified
by each responsible hospital for
inclusion in the AMI model versus cases
identified by CMS from historical
claims data upon which qualityadjusted target prices would be based.
The commenters stressed the need for
CMS to establish clinical homogeneity
in the AMI model, limiting ambiguity as
much as possible.
Several commenters recommended
CMS to use ICD–10–CM coding
strategies to limit inclusion of AMI
model beneficiaries to the most
clinically similar subset of beneficiaries
in order to allow for meaningful
comparisons and ultimately provide
CMS the opportunity to clearly evaluate
the impact of the AMI model on patient
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care and outcomes. The commenters
stated that with the move from ICD–9–
CM to ICD–10–CM, the coding stages
associated with AMI have changed,
warranting additional considerations.
Specifically, a number of commenters
recommended that CMS limit the AMI
model to beneficiaries with ST-elevation
myocardial infarction (STEMI)
discharged under AMI MS–DRGs and
PCI MS–DRGs with an AMI ICD–10–CM
code only in the principal diagnosis
code position on the inpatient claim.
The commenters claimed that while
STEMIs occur due to an acute coronary
artery occlusion, many non-ST elevation
(NSTEMI) beneficiaries with AMI
experience open coronary arteries but
there is an imbalance between the
oxygen demands of the heart and the
coronary arteries’ ability to meet them.
The commenters added that due to these
substantial differences in the underlying
pathophysiology of STEMI and NSTEMI
AMI patients that lead to more variation
in clinical presentation in NSTEMI
patients, in addition to the different
approaches to their evaluation and
management, the AMI model should
only include STEMI beneficiaries
which, when risk adjustment is applied,
represent a more homogenous
population compared to NSTEMI
patients.
These commenters presented the most
current consensus driven definition of
AMI, the third universal definition, as:
‘‘Evidence of myocardial necrosis
consistent with acute myocardial
ischemia. Under these conditions, any
one of the following criteria meets the
diagnosis for MI:
• Detection of a rise and/or fall of
cardiac biomarker values, preferably
cardiac troponin with at least one value
above the 99th percentile upper
reference limit; and at least one of the
following:
• Symptoms of new ischemia;
• New or presumed new significant
ST-segment-T wave (ST–T) changes or
new left bundled branch block (LBBB);
• Development of pathological Q
waves in the ECG;
• Imaging evidence of new loss of
viable myocardium or new regional wall
motion abnormality; and
• Identification of an intracoronary
thrombus by angiography or
autopsy.’’ 49
The commenters recommended CMS
to clearly define AMI for the EPM
because they claimed that currently
what is coded as AMI often only meets
49 Thygesen K., Alpert J.S., Jaffe A.S., et al and the
Writing Group on behalf of the Joint ESC/ACCF/
AHA/WHF Task Force for the Universal Definition
of Myocardial Infarction. Circulation.
2012;126:2020–2035.
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this definition in part and may be
limited to abnormal biomarkers that can
be detected without an acute occlusion
of a coronary artery. Aligning coding
with clinical reality is necessary for
establishing clinical homogeneity in the
AMI model. The commenters believe
that including in the AMI model
beneficiaries not only with a principal
but a secondary diagnosis of AMI would
make it difficult to establish a clearly
defined clinically homogeneous
population for the following reasons:
• Critically ill patients often receive a
secondary diagnosis of AMI for what is
more correctly characterized as supplydemand ischemia due to the routine and
inaccurate coding of any troponin leak
or elevation as an AMI, despite the
absence of a clinical event suggestive of
infarction. The commenters provided
examples such as a beneficiary with
metastatic breast cancer and internal
bleeding who exhibits a slight cardiac
troponin leak or a beneficiary with
multi-organ failure, stating that the root
cause of small elevation of troponin in
these cases would be the underlying
condition, not CAD. They also claimed
that elderly patients with heart failure
or rapid atrial fibrillation may have a
secondary AMI ICD–CM diagnosis, yet
the heart failure or atrial fibrillation
would drive decisions about care, not
the AMI.
• Outcomes and cost-of-care for
critically ill patients with a secondary
AMI diagnosis are likely driven more by
the primary condition than by AMI
resulting from possible CAD.
• Patterns of care are very different
for patients with a secondary, as
compared to a principal, diagnosis of
AMI; and
• Including patients with a secondary
diagnosis of AMI increases the
variability within the AMI model,
limiting opportunity to draw clear
conclusions when testing the model.
One commenter requested that CMS
account for beneficiaries with AMI who
do not have a traditional AMI but
coding results in discharge under an
AMI MS–DRG by specifying a concrete
list of ICD–10–CM codes that, if
included on a claim for a beneficiary
discharged under an AMI MS–DRG from
an AMI model participant, would
exclude the beneficiary from the AMI
model.
Response: We appreciate the
suggestions of the commenters that we
include a more homogeneous group of
beneficiaries in the AMI model by
limiting the model to those beneficiaries
with a STEMI ICD–CM diagnosis code
in the principal position on the claim
for the anchor hospitalization. Under
our proposal to include all beneficiaries
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in the AMI model discharged from AMI
MS–DRGs and beneficiaries discharged
from PCI MS–DRGs with an AMI ICD–
CM diagnosis code listed in Table 3 (the
codes we are finalizing are listed in
Table 4) in the principal or a secondary
position on the inpatient claim for the
anchor hospitalization, all of the
diagnosis codes except 410.71
(Subendocardial infarction, initial
episode of care) in ICD–9–CM and 121.4
(Non-ST elevation (NSTEMI)
myocardial infarction) and 122.2
(Subsequent non-ST elevation
(NSTEMI) myocardial infarction) are for
STEMI diagnoses. We analyzed
historical AMI episodes from 2012–2014
and found that about 78 percent of
episodes were for NSTEMI, while 22
percent were for STEMI.50 There are
well-established clinical guidelines for
the management of beneficiaries with
both NSTEMI and STEMI, and the
clinical care pathways generally differ
for these beneficiaries.51 52 However, to
limit the AMI model to beneficiaries
with STEMI only, the minority of
beneficiaries with AMI whose care is
less varied, and exclude beneficiaries
with NSTEMI, the majority of
beneficiaries with AMI whose care is
more varied and highly dependent on
the beneficiary’s risk factors for adverse
outcomes, would miss a substantial
opportunity to test an EPM for a large
proportion of Medicare beneficiaries
with AMI. We believe there are
substantial opportunities for care
redesign under the AMI model to
improve the quality and efficiency of
episode care for both NSTEMI and
STEMI patients so we will not limit the
model to one subgroup of beneficiaries
hospitalized for treatment of AMI. In
response to the commenters who were
concerned that including beneficiaries
with NSTEMI and STEMI in the AMI
50 Episodes for AMI beneficiaries initiated by all
U.S. IPPS hospitals not in Maryland and
constructed using standardized Medicare FFS Parts
A and B claims, as proposed in this rule that began
in CYs 2012–2014.
51 Amsterdam EA, Wenger NK, Brindis RG, Casey
DE Jr, Ganiats TG, Holmes DR Jr, Jaffe AS, Jneid H,
Kelly RF, Kontos MC, Levine GN, Liebson PR,
Mukherjee D, Peterson ED, Sabatine MS, Smalling
RW, Zieman SJ. 2014 ACC/AHA guideline for the
management of patients with non–ST-elevation
acute coronary syndromes: a report of the American
College of Cardiology/American Heart Association
Task Force on Practice Guidelines. Circulation.
2014;130:e344–e426.
52 O’Gara PT, Kushner FG, Ascheim DD, Casey DE
Jr, Chung MK, de Lemos JA, Ettinger SM, Fang JC,
Fesmire FM, Franklin BA, Granger CB, Krumholz
HM, Linderbaum JA, Morrow DA, Newby LK,
Ornato JP, Ou N, Radford MJ, Tamis-Holland JE,
Tommaso CL, Tracy CM, Woo YJ, Zhao DX. 2013
ACCF/AHA guideline for the management of STelevation myocardial infarction: a report of the
American College of Cardiology Foundation/
American Heart Association Task Force on Practice
Guidelines. Circulation. 2013;127.
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model could interfere with CMS’ ability
to evaluate the impact of the AMI model
on patient care and outcomes, we note
that as discussed in section IV. of this
final rule, we will examine the impact
of the AMI model on subgroups of
beneficiaries to better understand
variations in payments and outcomes
within and between hospitals. The
identification of subgroups to be
examined will include a variety of key
clinical and demographic factors.
We also analyzed the distribution of
AMI ICD–9–CM diagnosis codes for FY
2014 discharges from AMI and PCI MS–
DRGs (ICD–10–CM was not in use in
that year) in the principal versus
secondary position for beneficiaries who
would be included in the AMI model
under our proposal because of their
assignment to an AMI MS–DRG or to a
PCI MS–DRG.53 We found that 94
percent of historical episodes assigned
to PCI MS–DRGs had an AMI ICD–9–
CM diagnosis code in the principal
position. Of those episodes with an AMI
ICD–9–CM diagnosis code in the
secondary position, the most common
principal diagnoses were 996.72 (Other
complications due to other cardiac
device, implant, and graft) and 414.01
(Coronary atherosclerosis of native
coronary artery), which constituted 53
percent of cases with an AMI ICD–9–CM
diagnosis code only in a secondary
position, while the remaining episodes
had one of over 200 different ICD–9–CM
diagnoses codes in the principal
position. In addition, we found that 86
percent of episodes assigned to AMI
MS–DRGs had an AMI ICD–9–CM
diagnosis code in the principal position.
Of those cases with an AMI ICD–9–CM
diagnosis code in the secondary
position, the most common principal
diagnoses in descending order of
frequency were 428.23 (Acute on
chronic systolic heart failure); 427.31
(Atrial fibrillation); 428.33 (Acute on
chronic diastolic heart failure); 428.43
(Acute on chronic combined systolic
and diastolic heart failure); 428.0
(Congestive heart failure, unspecified);
and 428.21 (Acute systolic heart failure).
These diagnoses constituted 62 percent
of cases with an AMI ICD–9–CM code
only in a secondary position, while the
remaining episodes had one of over 200
different, but primarily cardiac, ICD–9–
CM diagnoses codes in the principal
position. We note that the diagnosis
code patterns we observed did not
confirm the views of some commenters
that beneficiaries with underlying non53 Inpatient claims from all U.S. IPPS hospitals
not in Maryland were derived from the October
2013–September 2014 Inpatient Claims File located
in the Chronic Conditions Warehouse.
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247
cardiac disease and a troponin leak,
such as a metastatic breast cancer with
internal bleeding, would be included in
the AMI model based on our proposal.
However, the AMI model would include
some beneficiaries discharged from AMI
MS–DRGs with significant underlying
cardiac conditions such as heart failure
and atrial fibrillation in the principal
diagnosis code position, another
example provided by some commenters.
ICD–CM diagnosis coding does not
rely on clinical definitions; it is the
physician who is responsible for
documenting the patient’s diagnosis. In
other words, coders cannot determine if
a patient suffered an AMI based on
cardiac biomarkers. If the physician
documents an AMI, then the coder is
required to report the ICD–10–CM code
describing the type of AMI. The coder
does not interpret the troponin levels of
a beneficiary.
Based on our analysis of historical
claims and the established rules for
medical coding, we believe that it is
appropriate to include the small
percentage of beneficiaries with an ICD–
CM AMI diagnosis code only in the
secondary position upon discharge from
AMI and PCI MS–DRGs in the AMI
model because the principal diagnoses
on these claims generally represent
beneficiaries with coronary obstruction.
The secondary AMI diagnosis on the
claim would have resulted from a
physician diagnosis of AMI which, as
the commenters stated, should be
represented by changes in cardiac
biomarker values and at least one other
characteristic of a specified list. In
addition to representing a reasonably
homogeneous population, we believe
this approach provides an unambiguous
definition for AMI model participants to
use to identify beneficiaries discharged
from PCI MS–DRGs who would be in
the AMI model. Because the model is
focused on a condition, AMI, rather
than a procedure, and some
beneficiaries admitted for PCI will not
have an AMI, it is necessary for PCI
MS–DRGs to pair ICD–CM diagnosis
codes with the MS–DRG to identify AMI
model beneficiaries.
While we observed that 14 percent of
beneficiaries assigned to AMI MS–DRGs
only had an AMI ICD–9–CM diagnosis
code in the secondary position and most
commonly another cardiac diagnosis in
the principal position, this group is a
small minority of beneficiaries
discharged from AMI MS–DRGs. We do
not believe that it is necessary to
exclude these beneficiaries from the
AMI model for purposes of clinical
homogeneity because the beneficiaries
should have had an AMI documented
by a physician for an AMI diagnosis
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code to be included in a secondary
position on the hospital claim. We
further observed from our analysis of FY
2014 claims for discharges from AMI
MS–DRGs that those beneficiaries with
an AMI ICD–9–CM code in the principal
position commonly had similar cardiac
diagnoses (for example, atrial
fibrillation and heart failure) as those
beneficiaries where the order of
diagnosis coding was reversed.54 Care
coordination and management of other
cardiac conditions which would be
included in the AMI episode definition
as discussed in section III.C.3.b. of this
final rule would be common for
beneficiaries discharged from AMI MS–
DRGs, regardless of whether AMI is the
principal or a secondary diagnosis on
the hospital claim that led to the
beneficiary’s discharge from an AMI
MS–DRG. Therefore, limiting the AMI
model beneficiaries only to those
assigned to AMI MS–DRGs based on a
principal diagnosis code of AMI would
not significantly increase clinical
homogeneity of those AMI model
beneficiaries discharged after medical
treatment for AMI. Moreover, to exclude
beneficiaries discharged from AMI MS–
DRGs with an AMI ICD–9–CM diagnosis
code only in a secondary position on the
hospital claim from the model could
substantially complicate timely EPM
participant identification of the
beneficiaries in the model by including
only a subset of beneficiaries assigned to
AMI MS–DRGs upon discharge. Thus,
we do not believe it is necessary for
AMI MS–DRGs to pair AMI ICD–CM
diagnosis codes with the MS–DRG to
identify AMI model beneficiaries.
Comment: In addition to the
commenters who recommended that
CMS apply specific coding strategies to
increase clinical homogeneity of
beneficiaries in AMI episodes, other
commenters recommended that CMS
exclude a variety of beneficiaries who
would otherwise meet the proposed
AMI model criteria for inclusion. Some
commenters further recommended CMS
to make a pricing adjustment for AMI
episodes for these beneficiaries if CMS
does not exclude them from the model
altogether. Suggestions included
excluding beneficiaries who are in the
following clinical scenarios:
• Cardiogenic shock or, at a
minimum, the subset of beneficiaries
with cardiogenic shock who are
transferred from an AMI model
participant or who are transferred to an
AMI model participant, as the impact of
54 Inpatient claims from all U.S. IPPS hospitals
not in Maryland were derived from the October
2013–September 2014 Inpatient Claims File located
in the Chronic Conditions Warehouse.
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the AMI model on transfer decisions
could delay access to life-saving
therapies at specialized centers.
• Sepsis who do not have clinically
traditional AMI and would not be
expected to follow a typical clinical
pathway for AMI.
• Experiencing a second or greater
AMI, who are more likely to have
complex cardiac needs beyond
immediate management of the AMI.
• Undergoing organ transplantation
or ventricular assist device (VAD)
implantation during the episode,
because regional pricing could limit
access to life-saving therapies only
available at those few centers capable of
caring for advanced heart failure
patients and organ transplant
candidates.
• Receiving outpatient inotropes for
advanced heart failure during AMI
episodes, because these therapies allow
beneficiaries to avoid a surgical bridge
to transplant with VAD implantation
but are used in a group of beneficiaries
who might otherwise receive a VAD.
The commenters believes this would be
consistent with excluding beneficiaries
who receive VAD during AMI episodes
from the AMI model.
• Undergoing CABG or other cardiac
surgery within 90 days following
discharge from the hospitalization for
AMI because they must be medically
optimized prior to surgery to ensure safe
outcomes. This percentage of
beneficiaries is higher for certain
hospitals with complex patient
populations, and the proposed payment
methodology would not adequately
account for these high-cost cases.
Response: We appreciate the
recommendations of the commenters
regarding the exclusion of certain
complex, potentially high-cost
beneficiaries from the AMI model. We
do not believe it would be appropriate
to exclude beneficiaries experiencing
cardiogenic shock or a second or
subsequent AMI from the AMI model
because there are significant
opportunities for improving the quality
and efficiency of care for these
beneficiaries during episodes, despite
their greater complexity and medical
needs, and we believe it is important to
include these beneficiaries in the test of
the AMI model. In response to the
commenters who recommended that we
exclude beneficiaries with sepsis and
atypical AMI from the AMI model,
based on our proposed definition of the
beneficiaries to be included in the AMI
model and the ICD–CM diagnosis code
analysis discussed in the response to the
previous comment, we do not believe
that beneficiaries with sepsis and
clinically atypical AMI would generally
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be included in the AMI model because
they would not be assigned to AMI or
PCI MS–DRGs.
While readmission for cardiac
transplantation or VAD implantation
would be excluded from AMI episodes
based on our proposed AMI model
exclusion list, these beneficiaries would
otherwise initiate and remain in AMI
episodes throughout the 90-day postdischarge period both before and
following cardiac transplantation or
VAD implantation that occurs during
the 90-day period. Other readmissions
and Part B services furnished to these
beneficiaries would be included in the
episodes based on the proposed
exclusion list. We believe it is important
to include in the AMI model these
beneficiaries with complex care needs
following hospitalization for AMI,
including those receiving outpatient
inotropes during AMI episodes, because
there are opportunities to improve the
quality and efficiency of their care,
despite their experiencing severe
sequelae following AMI.
Finally, we note that we also do not
believe it would be appropriate to
exclude from the AMI model those
beneficiaries receiving CABG or other
cardiac surgery during AMI episodes
after a period of medical optimization
following discharge from the anchor
hospitalization. As discussed in section
III.D.4.b.(2)(c) of this final rule, we are
providing a pricing adjustment for AMI
episodes with a CABG readmission for
beneficiaries who follow this medically
appropriate clinical pathway. We refer
to section III.D.4.b.(2) of this final rule
for further discussion of risk adjustment
in the context of the AMI model’s
implementation of downside risk and
progression to regional pricing for AMI
episodes.
Comment: Several commenters
supported excluding intracardiac
valvular and ablation procedures from
historical AMI episodes for clinical
consistency between historical AMI
episodes and those during the AMI
model performance years. They
explained that intracardiac valvular and
ablation procedures are typically
unrelated to management of an AMI but
would historically have substantially
impacted the total spending in historical
AMI episodes for beneficiaries
discharged from MS–DRGs 246 through
251 in centers that performed those
procedures.
Response: We appreciate the support
from the commenters. We continue to
believe it is appropriate to define
historical AMI episodes for beneficiaries
discharged under PCI MS–DRGS 246–
251 as those that do not include the
ICD–9–CM procedure codes in Table 4.
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Final Decision: After consideration of
the public comments received, we are
finalizing the proposals in
§ 512.100(c)(1) to include the care of
beneficiaries in the AMI model who
meet the general beneficiary care
inclusion criteria as discussed in section
III.C.4.a.(1) of this final rule and who are
discharged under an AMI MS–DRG
(280–282), representing those
individuals admitted with AMI who
receive medical therapy but no
revascularization, or discharged under a
PCI MS–DRG (246–251) with an ICD–
10–CM diagnosis code of AMI as
displayed in Table 6 on the IPPS claim
for the anchor hospitalization in the
249
principal or secondary diagnosis code
position, without modification.
We are also finalizing the proposals in
§ 512.100(d)(4) to define historical AMI
episodes for beneficiaries discharged
under PCI MS–DRGS 246–251 as those
that do not include the ICD–9–CM
procedure codes in Table 4, without
modification.
TABLE 4—FINAL ICD–9–CM PROCEDURE CODES IN ANY POSITION ON THE IPPS CLAIM FOR PCI MS–DRGS (246–251)
THAT DO NOT DEFINE HISTORICAL AMI EPISODES
ICD–9–CM procedure code
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35.52
35.96
35.97
37.26
37.27
37.34
37.36
37.90
ICD–9–CM procedure code description
..................................................................................
..................................................................................
..................................................................................
..................................................................................
..................................................................................
..................................................................................
..................................................................................
..................................................................................
Finally, we are finalizing the
proposals in § 512.100(d)(1)–(3) for the
sub-regulatory process to be used on an
annual, or more frequent, basis to
update the AMI ICD–10–CM diagnosis
code list and to address issues related to
AMI diagnosis codes raised by the
public, without modification. As part of
this process, we will use the following
standard when revising the list of ICD–
10–CM diagnosis codes representing
AMI: The ICD–10–CM diagnosis code is
sufficiently specific that it represents an
AMI. We will post a list of potential
AMI ICD–10–CM diagnosis codes to the
CMS Web site at https://
innovation.cms.gov/initiatives/epm to
allow for public input on our planned
application of the standard, and then
adopt the AMI ICD–10–CM diagnosis
code list with posting to the CMS Web
site of the final AMI ICD–CM diagnosis
code list after our consideration of the
public input. We will provide sufficient
time for public input based on the
complexity of potential revisions under
consideration, typically at least 30 days,
and, while we will not respond to
individual comments as would be
required in a regulatory process, we can
discuss the reasons for our decisions
about changes in response to public
input with interested stakeholders.
We note that we reviewed the FY
2017 ICD–10–CM diagnosis code
changes that became available after
publication of the EPM proposed rule in
the Federal Register on August 2, 2016.
There are no changes or additions to the
ICD–10–CM diagnosis codes reporting
AMI for FY 2017 so we are not
suggesting modifications for FY 2017 to
the final list displayed in Table 6 of
ICD–10–CM AMI diagnosis codes in the
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Repair of atrial septal defect with prosthesis, closed technique.
Percutaneous balloon valvuloplasty.
Percutaneous mitral valve repair with implant.
Catheter based invasive electrophysiologic testing.
Cardiac mapping.
Excision or destruction of other lesion or tissue of heart, endovascular approach.
Excision, destruction, or exclusion of left atrial appendage.
Insertion of left atrial appendage device.
principal or secondary position on the
IPPS claim for PCI MS–DRGs (246–251)
that initiate AMI episodes. Thus, we are
not initiating a sub-regulatory update
process for FY 2017 AMI ICD–10–CM
diagnosis code updates at this time.
(2) CABG Model
We proposed the CABG model to
incentivize improvements in the
coordination and quality of care, as well
as episode efficiency, for beneficiaries
treated with CABG irrespective of AMI
during the CABG hospitalization,
thereby including beneficiaries
undergoing elective CABG in the CABG
model as well as beneficiaries with AMI
who have a CABG during their initial
AMI treatment. The CABG model would
be similar to the CJR model in that the
anchor hospitalization would be defined
by admission for a surgical procedure,
which would be defined by the MS–
DRGs for that procedure alone (80 FR
73280). All CABG procedures are
performed in the inpatient hospital
setting. Thus, we proposed to include
beneficiaries admitted and discharged
from an anchor hospitalization paid
under CABG MS–DRGs (231–236) under
the IPPS in the CABG model. Based on
Medicare claims data for historical
CABG episodes beginning in CYs 2012–
2014, the annual number of potentially
eligible beneficiary discharges for the
CABG model nationally was
approximately 48,000.55
The proposal for identifying
beneficiaries included in the CABG
55 Episodes for CABG beneficiaries initiated by all
U.S. IPPS hospitals not in Maryland and
constructed using standardized Medicare FFS Parts
A and B claims, as proposed in the proposed rule,
that began in CYs 2012–2014.
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model was included in proposed
§ 512.100(c)(2). We sought comment on
our proposal to identify beneficiaries
included in the CABG model.
The following is a summary of the
comments received and our responses.
Comment: Similar to the suggestions
of commenters recommending that CMS
exclude certain beneficiaries discharged
from AMI MS–DRGs or PCI MS–DRGs
with an AMI ICD–10–CM diagnosis
code from the AMI model, several
commenters recommended that CMS
exclude a variety of beneficiaries from
the CABG model who would otherwise
meet the proposed CABG model criteria
for inclusion. Recommendations
include excluding beneficiaries who are
in the following clinical scenarios:
• Cardiogenic shock or, at a
minimum, the subset of beneficiaries
with cardiogenic shock who are
transferred from a model participant or
who are transferred to a model
participant, as the impact of the CABG
model on transfer decisions could delay
access to life-saving therapies at
specialized centers;
• Undergoing organ transplantation
or VAD implantation during the CABG
episode, as regional pricing could limit
access to life-saving therapies only
available at those few centers capable of
caring for advanced heart failure
patients and organ transplant
candidates.
• Receiving outpatient inotropes for
advanced heart failure during CABG
episodes, because these therapies allow
beneficiaries to avoid a surgical bridge
to transplant with ventricular assist
device (VAD) implantation but are used
in a group of beneficiaries who might
otherwise receive a VAD. The
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commenters state that this would be
consistent with excluding beneficiaries
who receive VAD during CABG
episodes from the CABG model.
• Undergoing a second or greater
CABG, given the increase in complexity
and comorbidities associated with this
population.
• Undergoing a salvage CABG due to
a failed or aborted PCI, either during a
single admission or a readmission, due
to the clinically frail beneficiaries that
result in high-cost episodes.
Response: We appreciate the
recommendations of the commenters
regarding the exclusion of certain
complex, potentially high-cost
beneficiaries from the CABG model, and
note that in some cases
recommendations for exclusion were
the same as for the AMI model. We do
not believe it would be appropriate to
exclude beneficiaries experiencing
cardiogenic shock, undergoing a second
or subsequent CABG, or undergoing
salvage CABG from the CABG model
because there are significant
opportunities for improving the quality
and efficiency of care for these
beneficiaries during episodes, despite
their greater complexity and medical
needs, and we believe it is important to
include these beneficiaries in the test of
the CABG model.
While readmission for cardiac
transplantation or VAD implantation
would be excluded from CABG episodes
based on our proposed CABG model
exclusion list, these beneficiaries would
otherwise initiate and remain in CABG
episodes throughout the 90-day postdischarge period both before and
following cardiac transplantation or
VAD implantation that occurs during
the 90-day period. Other readmissions
and Part B services furnished to these
beneficiaries would be included in the
episodes based on the proposed
exclusion list. We believe it is important
to include in the CABG model these
beneficiaries with complex care needs
following CABG surgery, including
those receiving outpatient inotropes
during CABG episodes, because there
are opportunities to improve the quality
and efficiency of their care, despite their
experiencing severe sequelae following
CABG. We refer to section III.D.4.b.(2) of
this final rule for further discussion of
risk adjustment in the context of the
CABG model’s implementation of
downside risk and progression to
regional pricing for CABG episodes.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposals in
§ 512.100(c)(2) to include the care of
beneficiaries in the CABG model who
meet the general beneficiary care
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inclusion criteria as discussed in section
III.C.4.a.(1) of this final rule and are
discharged under a CABG MS–DRG
(231–236) paid under the IPPS, without
modification.
(3) SHFFT (Excludes Lower Extremity
Joint Replacement) Model
We proposed the SHFFT model to
incentivize improvements in the
coordination and quality of care, as well
as episode efficiency, for beneficiaries
treated surgically for hip and femur
fractures, other than hip arthroplasty.
Together, the CJR and SHFFT models
would cover all surgical treatment
options (that is, hip arthroplasty and
fixation) for Medicare beneficiaries with
hip fracture.
The SHFFT model would be similar
to the CJR model in that the anchor
hospitalization would be defined by
admission for a surgical procedure,
which would be defined by the MS–
DRGs for that procedure alone (80 FR
73280). Additionally, most SHFFT
procedures are furnished in the
inpatient hospital setting, consisting
primarily of hip fixation procedures,
with or without reduction of the
fracture, as well as open and closed
surgical approaches. Thus, we proposed
to include beneficiaries admitted and
discharged from an anchor
hospitalization paid under SHFFT MS–
DRGs (480–482) under the IPPS in the
SHFFT model. Based on Medicare
claims data for historical SHFFT
episodes beginning in CYs 2012–2014,
the annual number of potentially
eligible beneficiary discharges for the
SHFFT model nationally was
approximately 109,000.56
The proposal for identifying
beneficiaries included in the SHFFT
model was included in proposed
§ 512.100(c)(3). We sought comment on
our proposal to identify beneficiaries
included in the SHFFT model.
The following is a summary of the
comments received and our responses.
Comment: A number of commenters
expressed support for the proposal to
define the clinical conditions included
in the SHFFT model as beneficiaries
who are admitted and discharged under
SHFFT MS–DRGs. Other commenters
recommended that CMS apply
additional episode-specific criteria to
exclude beneficiaries from the SHFFT
model who would be discharged from
the SHFFT MS–DRGs.
Recommendations of beneficiaries from
56 Episodes for SHFFT beneficiaries initiated by
all U.S. IPPS hospitals not in Maryland and
constructed using standardized Medicare FFS Parts
A and B claims, as proposed in the proposed rule,
that began in CYs 2012–2014.
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some commenters to be excluded
include:
• Beneficiaries with fracture due to
falls or trauma in association with acute
myocardial infarction; cardiac
arrhythmia; syncope; cerebrovascular
accident; seizure; head injury; or
polytrauma to reduce the large risk of
increases in patient transfers from EPM
participants seeking to reduce their
financial responsibility for high-cost
beneficiaries;
• Beneficiaries with dementia or
Alzheimer’s disease due to ethical
issues around withholding surgery that
could arise in the case of EPM
participants attempting to reduce their
financial risk;
• Beneficiaries already residing in a
SNF at the time of fracture, who would
necessitate an unavoidable SNF stay
after discharge from the anchor
hospitalization that would increase the
episode cost attributable to the EPM
participant;
• Beneficiaries with fractures related
to cancer, who would be expected to be
high-cost cases;
• Beneficiaries with a history of
previous hip fracture; previous surgery
in the region; retained hardware; open
fracture; periprosthetic fractures; and
congenital deformities who would be
expected to have atypical and
potentially costly hip fracture care
pathways; and
• Beneficiaries who smoke or have
diabetes, which are risk factors for
fracture nonunion and infection,
respectively, because these behaviorally
mediated risk factors for costly care
cannot be managed prior to hip surgery,
unless the SHFFT model adjusts prices
for the higher financial risk attributable
to these beneficiaries.
Response: We appreciate the
recommendations of the commenters to
exclude certain beneficiaries receiving
SHFFT from the SHFFT model due their
personal circumstances, other clinical
conditions, or circumstances that led to
the hip fracture. We agree with the
commenters that beneficiaries in this
group may be more likely to require
complex care during the anchor
hospitalization and significant,
intensive health services during the 90
day post-hospital discharge period,
which could result in high-cost SHFFT
episodes. However, we do not believe it
would be appropriate to exclude
beneficiaries with complex social or
clinical circumstances from the SHFFT
model because there are significant
opportunities for improving the quality
and efficiency of care for these
beneficiaries during episodes, despite
their greater complexity and medical
needs, and we believe it is important to
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include these beneficiaries in the test of
the SHFFT model. As discussed in
section III.G.4. of this final rule, we will
be monitoring for issues related to
access to care. We expect that all
Medicare beneficiaries with hip fracture
are offered clinically appropriate
treatments for their fracture and that all
transfers of beneficiaries with hip
fracture to other hospitals are medically
necessary and not determined by the
SHFFT model participant’s assessment
of the beneficiary’s risk of a high-cost
SHFFT episode. We also refer to section
III.D.4.b.(2) of this final rule for further
discussion of risk adjustment in the
context of the SHFFT model’s
implementation of downside risk and
progression to regional pricing for
SHFFT episodes.
Comment: Some commenters stated
that there is a sizeable minority of
beneficiaries with hip fracture who
should not and do not get hospitalized
or if hospitalized are not treated with
surgery for fracture so would not be
included in the SHFFT or CJR models.
These commenters observed that these
beneficiaries were not discussed in the
proposed rule and, therefore, no
discussion was included about the
decisions related to the appropriate
treatment of hip fracture in the case of
serious disability, frailty, and
concurrent illness. The commenters
contended that EPM participants that
have historically served a substantial
frail population could be seriously
disadvantaged under the SHFFT model
due to the significant care needs for
these beneficiaries following hip
fracture surgery and might seek to
reduce their traditional commitment to
this population in various ways, which
were contrary to the interests of this
highly vulnerable population. Some
commenters further speculated that
beneficiaries with hip fracture could be
shifted to no surgery or to joint
replacement if SHFFT model
participants seek to reduce high-cost
cases that present the most financial risk
under the SHFFT model. The
commenters further stated that the
SHFFT model may drive SHFFT model
participants to provide more expensive
hip replacement to beneficiaries due to
their desire to avoid SNF admission
because of the longer need for protected
weight-bearing post-internal fixation
after SHFFT in comparison with total
joint replacement where immediate
weight-bearing may be possible.
Response: While we agree with the
commenters that surgical fracture repair
may not be appropriate for some
beneficiaries with hip fracture, the
proposed SHFFT model was designed to
include only those beneficiaries with
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surgical fracture repair other than joint
replacement and not those for which
surgical fracture repair was not
performed. We believe the decision
about fracture treatment should remain
that of the beneficiary in consultation
with any caregivers and his or her
treating physicians. We did not propose
to define the SHFFT model by hip
fracture alone because we believe the
primary opportunities for care redesign
under an EPM that seeks to improve
episode quality and efficiency are in the
surgical treatment of hip fracture, rather
than in the primary non-surgical
management of hip fracture for
beneficiaries who may or may not be
hospitalized.
We do not believe that EPM
participants would direct Medicare
beneficiaries to other treatments that
would result in their not being included
in the SHFFT model simply on the basis
of the beneficiary’s potential for being a
high-cost hip fracture surgical episode.
We refer to section III.D.4.b.(2) for
discussion of risk adjustment for
complex beneficiaries under the SHFFT
model. In addition, we note that
beneficiaries with hip fracture who are
treated with joint replacement, a care
pattern that some commenters believe
could result from SHFFT model
participants’ efforts to avoid of high-cost
cases under the SHFFT model, would be
included in the CJR model for most
SHFFT model participants who are also
CJR participant hospitals as discussed in
section III.B.3. of this final rule. Thus,
it is unlikely that a shift from a SHFFT
procedure to joint replacement would
financially benefit the SHFFT model
participant. As discussed in sections
III.G.4. through 6. of this final rule, we
will be closely monitoring for access to
care, quality of care, and delayed care
under the SHFFT model.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposals in
§ 512.100(c)(3) to include the care of
beneficiaries in the SHFFT model who
meet the general beneficiary care
inclusion criteria as discussed in section
III.C.4.a.(1) of this final rule and are
discharged under a SHFFT MS–DRG
(480–482) under the IPPS, without
modification.
b. Definition of the Related Services
Included in EPM Episodes
The general principles for the
definition of related services are the
same for the AMI, CABG, and SHFFT
models, so we address them in a single
discussion in this section. Like the CJR
model, we are interested in testing
inclusive AMI, CABG, and SHFFT
episodes to incentivize comprehensive,
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251
coordinated, patient-centered care for
the beneficiary throughout the episode
(80 FR 73303). Therefore, we proposed
to exclude Medicare items and services
furnished during the EPM episodes only
when unrelated to the EPM episode
diagnosis and procedures based on
clinical rationale that would result in
standard exclusions from all of the
episodes in a single EPM. Thus, we
proposed to include all items and
services paid under Medicare Part A
and Part B unless they fall under an
exclusion because they are unrelated to
the EPM episodes.
Also like the CJR model, we proposed
that the items and services ultimately
included in the EPM episodes after the
exclusions are applied are called related
items and services, and that Medicare
spending for related items and services
be included in the historical data used
to set EPM-episode benchmark prices
and in the calculation of actual EPM
episode payments that would be
compared against the quality-adjusted
target price to assess the performance of
EPM participants (80 FR 73303 and
73315). Additionally, we proposed that
Medicare spending for unrelated items
and services (excluded from the EPMs’
episode definitions) would not be
included in the historical data used to
set EPM-episode benchmark prices or in
the calculation of actual EPM episode
payments. We proposed that related
items and services for EPM episodes
would include the following items and
services paid under Medicare Part A
and Part B, after the EPM-specific
exclusions are applied:
• Physicians’ services.
• Inpatient hospital services.
• Inpatient psychiatric facility (IPF)
services.
• Long-Term Care Hospital (LTCH)
services.
• Inpatient Rehabilitation Facility
(IRF) services.
• Skilled Nursing Facility (SNF)
services.
• Home Health Agency (HHA)
services.
• Hospital outpatient services.
• Independent outpatient therapy
services.
• Clinical laboratory services.
• Durable medical equipment.
• Part B drugs.
• Hospice.
We note that inpatient hospital
services would include services paid
through IPPS operating and capital
payments. The AMI, CABG, and SHFFT
episodes also could include certain permember-per-month model payments as
discussed in section III.D.6.d. of the
proposed rule (81 FR 50871 through
50872). These items and services for the
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EPMs are the same items and services
included in CJR episodes (80 FR 73303
and 73315).
Similar to the CJR model and for the
reasons explained in the CJR Final Rule,
we proposed to exclude drugs that are
paid outside of the MS–DRGs included
in the EPM episode definitions,
specifically hemophilia clotting factors,
identified by CPT code, diagnosis code,
and revenue center on IPPS claims, from
the EPM episodes (80 FR 73303 and
73315). Hemophilia clotting factors, in
contrast to other drugs that are
administered during a hospitalization
and paid through the MS–DRG, are paid
separately by Medicare in recognition
that clotting factors are costly and
essential to appropriate care of certain
beneficiaries. Therefore, we believe
there are no EPM episode efficiencies to
be gained in the variable use of these
high cost drugs.
We also proposed to exclude IPPS
new technology add-on payments for
drugs, technologies, and services from
these EPM episodes, excluding them
from both the actual historical episode
data used to set EPM-episode
benchmark prices and from actual EPM
episode payments that are reconciled to
the quality-adjusted target prices like
the CJR model (80 FR 73303–73304 and
73315). This would apply to both the
anchor hospitalization and any related
readmissions during the EPM episodes.
New technology add-on payments are
made separately and in addition to the
MS–DRG payment under the IPPS for
specific new drugs, technologies, and
services that substantially improve the
diagnosis or treatment of Medicare
beneficiaries and would be inadequately
paid under the MS–DRG system. We
believe it would not be appropriate for
the EPM to potentially diminish
beneficiaries’ access to new
technologies or to burden hospitals who
choose to use these new drugs,
technologies, or services with concern
about these payments counting toward
EPM participants’ actual EPM episode
payment. Additionally, new drugs,
technologies, or services approved for
the add-on payments vary unpredictably
over time in their application to specific
clinical conditions.
Finally, we proposed to exclude OPPS
transitional pass-through payments for
medical devices as defined in § 419.66
from the EPM episodes because, through
the established OPPS review process,
we have determined that these
technologies have a substantial cost but
also lead to substantial clinical
improvement for Medicare beneficiaries.
This proposal also is consistent with the
CJR model final exclusions policy (80
FR 73308 and 73315).
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We proposed to follow the same
general principles in determining other
proposed excluded Part A and Part B
services from the EPM episodes that we
use in the CJR model in order to
promote coordinated, high-quality,
patient-centered care (80 FR 73304).
These include identifying excluded
(unrelated) services rather than
included (related) services based on
clinical review. We would
operationalize these principles for the
new EPMs, as we do for the CJR model,
by excluding unrelated inpatient
hospital admissions during the EPM
episode by identifying MS–DRGs for
exclusion on an EPM-specific basis (80
FR 73304 through 73312 and 73315).
We would further exclude unrelated
Part B services during the EPM episode
based on the diagnosis code on the
claim by identifying categories of ICD–
CM codes for exclusion (identified by
code ranges) on an EPM-specific basis.
ICD–9–CM diagnosis code exclusions
would apply to historical episodes used
to construct EPM-episode benchmark
prices, while ICD–10–CM diagnosis
code exclusions would apply to EPM
episodes during the EPMs’ performance
years. We proposed to identify
unrelated Part B services and
readmissions based on the BPCI Model
2 Part B exclusion lists that apply to the
anchor MS–DRG that initiates the EPM
episode, or to the price MS–DRG if it is
different than the anchor MS–DRG as
described further in section
III.D.4.b.(2)(a) of this final rule. This
proposal is consistent with our use of
the BPCI Model 2 LEJR ICD–9–CM, ICD–
10–CM, and MS–DRG exclusion lists in
the CJR model (80 FR 73304 and 73315).
The BPCI episode-specific exclusion
lists were initially developed more than
3 years ago for the BPCI initiative
through a collaborative effort of CMS
staff, including physicians from medical
and surgical specialties, coding experts,
claims processing experts, and health
services researchers. The lists have been
shared with thousands of entities and
individuals participating in episodes in
one or more phases of the BPCI
initiative, and have undergone
refinement in response to stakeholder
input about specific diagnoses for
exclusion, resulting in only minimal
changes over the last 3 years. Thus, the
BPCI exclusion lists have been vetted
broadly in the health care community;
refined based on input from a wide
variety of providers, researchers and
other stakeholders; and successfully
operationalized in the BPCI models. We
proposed their use in the AMI, CABG,
and SHFFT models based on our
confidence related to our several years
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of experience that these definitions are
reasonable and workable for AMI,
CABG, and SHFFT episodes, for both
providers and CMS, and based on our
rulemaking for the CJR model. We note
that the BPCI Model 2 exclusion lists for
the 48 clinical conditions being tested
in the BPCI models include lists that
apply to every MS–DRG that could be
an anchor MS–DRG (or price MS–DRG,
if applicable) for the AMI, CABG, and
SHFFT episodes.
Similar to the CJR model, we
proposed to include in EPM episodes all
Part A services furnished post-hospital
discharge during the EPM episode, as
these services are typically intended to
be comprehensive in nature (80 FR
73304 and 73315). We specifically
proposed to exclude unrelated hospital
readmissions for MS–DRGs that group
to the following categories of diagnoses:
Oncology, trauma medical admissions,
surgery for chronic conditions unrelated
to a condition likely to have been
affected by care furnished during the
EPM episode, and surgery for acute
conditions unrelated to a condition
resulting from or likely to have been
affected by care during the EPM
episode. The rationale for these
exclusions is the same as the rationale
for their exclusion in the CJR model (80
FR 73304).
Specifically with respect to Part B
services, similar to the CJR model, we
proposed to exclude acute disease
diagnoses unrelated to a condition
resulting from or likely to have been
affected by care during the EPM
episode, and certain chronic disease
diagnoses, as specified by CMS on a
diagnosis-by-diagnosis basis, depending
on whether the condition was likely to
have been affected by care during the
EPM episode or whether substantial
services were likely to be provided for
the chronic condition during the EPM
episode (80 FR 73305 and 73315). Thus,
we would include all Part B services
with principal diagnosis codes on the
associated Part B claims that are directly
related (clinically and per coding
conventions) to EPM episodes, claims
for diagnoses that are related to the
quality and safety of care furnished
during EPM episodes, and claims for
services for diagnoses that are related to
preexisting chronic conditions such as
diabetes, which may be affected by care
furnished during EPM episodes.
In general, the anchor MS–DRG that
initiates the AMI, CABG, or SHFFT
episode would determine the exclusion
list that applies to the EPM episode. For
example, AMI episodes may have
different exclusion lists applied based
on whether the AMI episode is initiated
by admission to the participant hospital
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that results in discharge from an AMI
anchor MS–DRG or a PCI anchor MS–
DRG with AMI ICD–10–CM diagnosis
code. If a price MS–DRG applies to the
AMI episode that includes a chained
anchor hospitalization as described in
section III.D.4.b.(2)(a) of this final rule,
the exclusion list that applies to the
price MS–DRG would apply to the AMI
episode. Complete lists of excluded
MS–DRGs for readmissions and
excluded ICD–CM codes for Part B
services furnished during EPM episodes
after EPM beneficiary discharge from an
anchor or chained anchor
hospitalization in the AMI, CABG, and
SHFFT models are posted on the CMS
Web site at https://innovation.cms.gov/
initiatives/epm.
Like the CJR model policy, we
proposed that these exclusion lists
would be updated by sub-regulatory
guidance on an annual basis, at a
minimum, to reflect annual changes to
ICD–10–CM coding and annual changes
to the MS–DRGs under the IPPS, as well
as to address any other issues that are
brought to our attention throughout the
course of the EPMs’ performance period
(80 FR 73304 through 73305 and 73315).
The standards for this updating process
reflect the previously discussed general
principles for determining excluded
services. That is, we proposed to not
exclude any items or services that are
directly related to the EPM episode
diagnosis or procedure (for example, a
subsequent admission for heart failure
or repeat revascularization) or the
quality or safety of care (for example,
sternal wound infection following
CABG); or to chronic conditions that
may be affected by the EPM diagnosis or
procedure and the post-discharge care
(for example, diabetes). We proposed to
exclude items and services for chronic
conditions that are generally not
affected by the EPM diagnosis or
procedure and the post-discharge care
(for example, prostate removal for
cancer), and for acute clinical
conditions not arising from existing
EPM episode-related chronic clinical
conditions or complications from the
EPM episode (for example,
appendectomy).
Similar to the CJR model, we
proposed that the potential revised
exclusions, which could include
additions to or deletions from the
exclusion lists, would be posted to the
CMS Web site to allow for public input
(80 FR 73305 and 73315). Through the
process for public input on potential
revised exclusions and then posting of
the final revised exclusions, we
proposed to provide information to the
public about when the revisions would
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take effect and to which episodes they
would apply.
The proposal for included services for
an EPM was included in proposed
§ 512.210(a). The proposal for excluded
services from the EPM episode was
included in proposed § 512.210(b). The
proposal for updating the lists of
excluded services for EPMs was
included in proposed § 512.210(c). We
sought comment on our proposals for
included and excluded services for the
AMI, CABG, and SHFFT models and
updating the lists of excluded services.
The following is a summary of the
comments received and our responses.
Comment: Most commenters
expressed general support for CMS’
proposed episode definition strategy
that would include Part A and Part B
items and services and exclude certain
unrelated readmissions based on a list
of MS–DRGs, as well as certain
unrelated Part B services based on the
principal diagnosis on the claim,
consistent with the episode definition
approach for LEJR under the CJR model
and the approach used in the BPCI
initiative for several years for BPCI,
SHFFT, AMI, PCI, and CABG episodes.
The commenters acknowledged that
most items and services would be
included in the episode definition
under the proposal, thus creating
broadly defined SHFFT, AMI, and
CABG episodes. In some cases, while
commenters agreed with the proposed
general strategy for identifying EPM
episode exclusions, they made specific
recommendations for additional
exclusions based on a different
exclusions standard, and these
commenters are summarized later in
this section, where responses are also
provided. In other cases, commenters
who agreed with the strategy for
identifying EPM episode exclusions
stated that if CMS finalizes broad EPM
episode definitions, risk adjustment
would be necessary in order to ensure
fair payment to EPM participants.
Several commenters recommended
CMS to provide greater clarity about the
services included in and excluded from
EPM episodes. One commenter stated
that it is hard to differentiate included
versus excluded services, and further
added that people are ‘‘irreducible
bundles’’ and someone needs to be
responsible for all of the issues for
people when they are very sick. The
commenter recommended that the
longer-term value of patient-centered
medical homes, comprehensive ACOs,
and primary care geriatricians should be
considered for beneficiaries completing
EPM episodes and recommended that
moving people with complex illness
into such arrangements should be a
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253
feature of all CMS innovations as part of
moving fee-for-service payment toward
quality and value. A few commenters
recommended that CMS provide a clear
definition and methodology for the term
‘‘related services’’ which would be
applied consistently throughout various
payment models so providers could
verify how their services would be
identified and paid. Finally, several
commenters requested that CMS utilize
an inclusions list rather than an
exclusion list to avoid including
inappropriate services by default. One
commenter presented analysis that
showed AMI model readmission for
seizures and other for organic
disturbance and mental retardation
would be included in AMI episodes,
and the commenter believes that
neurological and mental health
conditions are not related to cardiac
care for AMI.
Response: We appreciate the support
of many commenters for our proposed
general approach to identifying
excluded items and services for the
EPMs. As we stated in the proposed rule
(81 FR 50832), we are interested in
testing inclusive AMI, CABG, and
SHFFT episodes to incentivize
comprehensive, coordinated, patientcentered care for the beneficiary
throughout the episode. We agree with
the commenter that it can be hard to
distinguish included versus excluded
services because sick people have many
complex and interrelated clinical
conditions and corresponding health
care needs. The proposed EPM episode
definitions are broad in part for this
reason. Additionally, while we also
agree with the commenter that the
ongoing and acute health care needs of
medically complex beneficiaries may be
addressed through a patient-centered
medical home or ACO, many of these
vulnerable beneficiaries currently are
not included in such models or
programs. In the case of other
beneficiaries who are included in
medical home or ACO models or
programs, they may have specific, new
care management needs arising from an
acute cardiac event, CABG, or hip
fracture surgery that may be best
managed by the EPM participant that
has substantial expertise in coordinating
and managing care throughout AMI,
CABG, or SHFFT episodes because of its
participation in the EPM, while the
ACO or patient-centered medical home
may have less specific expertise in
managing beneficiaries recovering from
major orthopedic or cardiac surgery or
an AMI. We expect that EPM
participants, accountable for EPM
episode quality and cost performance
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under the EPMs, will work closely with
all providers and other organizations
with which a model beneficiary has
established relationships, toward the
mutual goal of high quality, wellcoordinated care that maximizes the rate
of a beneficiary’s return of function and
improvements in health following
surgery or AMI. We further expect that
the medical management and care
coordination during EPM episodes will
continue to be provided as beneficiaries’
transition out of EPM episodes,
potentially into a primary care medical
home or other model or program with
accountability for population health,
such as an ACO.
Because our proposed inclusive
approach to EPM episode definitions
results in many more items and services
that are included in EPM episodes than
excluded, we believe it is most efficient
to identify excluded items and services
as we proposed. With regard to the
commenters who were concerned that
an exclusion list could include
inappropriate services by default, we
note that we posted to the CMS Web site
the proposed exclusion lists for the
AMI, CABG, and SHFFT models for
comment in association with the
proposed rule and are finalizing the
initial exclusion lists through this
rulemaking where we have considered
and responded to all the comments we
received on our proposed exclusions.
Thus, no items and services would be
included in EPM episodes by default
because the exclusion lists have been
established through notice and
comment rulemaking. In addition, as
discussed later in this section, we
proposed a sub-regulatory process for
updating the exclusion lists to reflect
ICD–10–CM coding and annual changes
to the MS–DRGs under the IPPS, as well
as to address any other issues that are
brought to our attention throughout the
course of the EPMs’ performance
periods. The standards for the process
reflect the proposed general principles
for excluded services and the process
itself allows opportunity for public
input. Thus, we believe that all items
and services included in EPM episodes
are intentionally included, after
consideration of public input, rather
than included by default.
We note that in the example raised by
the commenter of ‘‘default inclusion,’’
we disagree with the commenter that
readmissions for neurological and
mental health conditions are unrelated
to cardiac care for AMI. For example, an
AHRQ Evidence Report on postmyocardial infarction found that the
evidence is consistent that in patients
with AMI, depression is common at the
time of the hospitalization and persists
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for at least several months after hospital
discharge without treatment.57 Further,
the report found that depression is
associated with a significantly increased
risk of subsequent death, and of cardiac
readmission and poor quality of life
during the first year. Thus, we would
not exclude readmission for treatment of
depression from AMI episodes because
we believe that depression would
generally be a chronic condition that
was likely to have been affected care
during the AMI model episode. Under
our proposal, readmissions for
neurological and mental health
conditions would not be excluded from
AMI episodes because they are not MS–
DRGs that we proposed to exclude from
the AMI episodes, specifically oncology;
trauma medical; chronic disease
surgical unrelated to a condition likely
to have been affected by care during the
EPM episode; or acute disease surgical
unrelated to a condition resulting from
or likely to have been affected by care
during the AMI episode. Thus, we
consider those readmissions related to
AMI episodes as they are medical MS–
DRGs for conditions that are likely to
have resulted from or been affected by
care during the AMI anchor
hospitalization or during the 90 days
post-hospital discharge.
By posting to the CMS Web site the
lists of excluded services for the EPMS,
we believe we are providing the clarity
and detail needed for any provider to
understand whether his or her services
furnished to a beneficiary in an EPM
episode are included in the EPM
episode definition because they are
related to the episode or excluded from
the EPM episode because they are
unrelated. To date, we have applied the
same general approach to identifying
exclusions in the BPCI initiative, the
CJR model, and the proposed EPMs,
which should facilitate provider
understanding about exclusions under
these different episode payment models.
We note, however, that the exclusion
list differs based on the clinical
condition that is the focus of the
episode so a provider that is paid under
Part B or a hospital would not be able
to have a uniform determination of
whether services furnished were
included or excluded from an episode
without knowledge of the beneficiary’s
specific episode in an episode payment
model as well as the clinical condition
for which the provider furnished
services. All of the Innovation Center
57 Bush DE, Ziegelstein RC, Patel UV, et al. PostMyocardial Infarction Depression. Rockville (MD):
Agency for Healthcare Research and Quality (US);
2005 May. (Evidence Reports/Technology
Assessments, No. 123.) Available from: https://
www.ncbi.nlm.nih.gov/books/NBK37817/.
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episode payment models except Model
4 of BPCI use retrospective payment, so
all providers would be paid according to
the usual fee-for-service systems that
apply, regardless of whether the items
or services furnished by the provider are
included in or excluded from a
beneficiary’s episode.
Comment: While some commenters
expressed full support for CMS’
proposed definition of related services,
other commenters recommended CMS
to exclude specific additional groups of
services from EPM episodes. The
commenters requested that CMS further
exclude:
• Readmissions that were already
planned for the beneficiary prior to the
anchor hospitalization because their
occurrence would be unrelated to
episode care;
• Readmissions that were part of the
planned post-discharge care for the
beneficiary after the anchor
hospitalization, because these provide
no opportunity for efficiency yet could
lead to high-cost episodes:
• Medical readmissions for unrelated
acute and chronic conditions;
• Part B services that are not directly
related to the episode;
• Cardiac rehabilitation, intensive
cardiac rehabilitation, and chronic care
management services where appropriate
utilization under the EPMs in the
context of historical low utilization
would lead to increased episode costs
during the EPM performance period;
• Behavioral and substance abuse
services because these are not always
integral or of strong relevance to the
clinical definitions of the EPMs, and
CMS does not provide claims data to
model participants for these services so
no participants can predict, model, or
calculate episode spending; and
• Outpatient chemotherapy,
psychiatric readmissions, and high cost
intravenous therapy administered
through DME that are unrelated to the
episode and could lead to increased
episode costs.
Response: We believe that it is not
necessary to exclude from EPM episodes
planned readmissions and outpatient
services, regardless of whether those
plans were made prior to the anchor
hospitalization or during the anchor
hospitalization but prior to discharge,
solely because the readmissions or
outpatient services are planned in
advance. While we understand that
certain other CMS programs account
differently for planned readmissions by
excluding them from readmission
calculations, such as the HRRP which
reduces payments to hospitals with
excess readmissions, we do not believe
that planned readmissions should be
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excluded from EPM episodes, where the
goals of the EPMs are to improve the
quality and efficiency of episode care
and where we do not make a specific
assessment about excess readmissions.
Just like unplanned readmissions, we
believe that planned readmissions
should be excluded from EPM episodes
only if they are unrelated to the EPM
episodes based on the proposed
standards for exclusion of inpatient
readmissions that group to the following
categories of diagnoses: Oncology;
trauma medical; chronic disease
surgical unrelated to a condition likely
to have been affected by care during the
EPM episode; and acute disease surgical
unrelated to a condition resulting from
or likely to have been affected by care
during the EPM episode. We continue to
believe these standards are appropriate
to identify excluded readmissions from
EPM episodes given our design of the
EPMs to test comprehensive,
coordinated patient-centered care for
the beneficiary throughout broadly
defined EPM episodes. Unless a
readmission is excluded from the EPM
episode based on these standards, any
readmission, whether planned or
unplanned, would be related to the EPM
episode and be affected by the clinical
condition that is the basis for that
episode. We appreciate the concerns of
the commenters about ensuring
appropriate EPM episode prices in the
case of planned readmissions. While we
are not adopting any specific
methodologies for identifying and
making episode payment adjustments
for such planned, related readmissions
now except in the case of a CABG
readmission during an AMI episode as
discussed in section III.D.4.b.(2)(c), we
will study this issue in more detail
especially as it relates to the cardiac
models. Should we determine a change
to our policies regarding planned,
related readmission could be
appropriate, we will make proposals
through future rulemaking.
To the extent that planned
readmissions reflect certain clinically
appropriate care patterns for
beneficiaries in EPM episodes based on
plans made during the anchor
hospitalization, we expect that such
readmissions would be included in the
historical EPM episodes used to
establish EPM-episode payments and
thus hospitals would be appropriately
paid, on average, for EPM episode care.
To the extent that efficiencies in EPM
episode care are possible and medically
appropriate, reducing planned
readmissions may provide an
opportunity for increased EPM episode
efficiencies. However, we would not
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expect EPM participants to reduce EPMepisode spending by shifting the
utilization of medically necessary
services, such as planned readmissions,
until after the EPM episode ends. We
refer to section III.D.4.b.(2)(c) of this
final rule for discussion of the pricing
adjustment for CABG readmissions
during AMI episodes due to this costly,
clinically-appropriate care pattern of
delayed CABG for some beneficiaries
with AMI.
Furthermore, while we expect that
certain elective admissions considered
related under the EPMs may be planned
prior to the anchor hospitalization for
the EPM episode and could, therefore,
occur during the 90-day post-discharge
period, we believe that such actual
readmissions after CABG, SHFFT or
AMI treatment are uncommon during
the post-surgical recovery or post-AMI
recovery period for EPM beneficiaries
that extends 90 days following
discharge from the anchor
hospitalization. If such readmissions
were planned, they would often be
canceled due to the intervening surgery
or AMI until the beneficiary has fully
recovered. We will not exclude them all
as unrelated because any readmission
not on the EPM exclusion list may be
related care furnished during the postsurgical or post-AMI recovery period.
Our exclusion methodology does not
allow us to identify those readmissions
that are truly elective; that is, the
condition was present and the
readmission was planned prior to the
hospitalization that anchored the EPM
episode and scheduled during the 90day post-hospital discharge period.
For readmissions to medical MS–
DRGs, the selection of the principal
diagnosis code is not clear-cut so we
believe they should all be included in
the EPM episode definition so providers
focus on comprehensive care to
beneficiaries in episodes. We believe
that readmissions to medical MS–DRGs
are generally linked to the
hospitalization or event as a
complication of the illness that led to
the procedure or event, a complication
of treatment or interactions with the
health care system, or a chronic illness
that may have been affected by the
course of care. Therefore, we believe it
is infeasible under the EPMs to identify
medical readmissions for unrelated
acute and chronic medical conditions,
other than our proposal to exclude
readmissions for oncology and trauma
medical diagnoses.
Similarly, our proposal identified
those Part B services unrelated to the
episode as acute disease diagnoses
unrelated to a condition resulting from
or likely to have been affected by care
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255
during the EPM episode and certain
chronic disease diagnoses depending on
whether the condition was likely to
have been affected by care during the
EPM episode or whether substantial
services were likely to be provided for
the chronic condition during the EPM
episode. We do not believe that
requiring a direct relationship between
the diagnosis for the Part B services and
the clinical condition that is the basis
for the EPM episode is appropriate
under the broadly defined episodes of
the EPMs. Most medical conditions are
likely to be affected by care during the
EPM episode, yet they may not have a
direct relationship to the clinical
condition that is the reason for the
anchor hospitalization.
We also do not believe that it would
be appropriate to exclude other specific
Part B services that are related to the
clinical conditions that are the basis for
EPM episodes, such as cardiac
rehabilitation, intensive cardiac
rehabilitation, and chronic care
management services, just because they
are underrepresented in the baseline
period upon which benchmark episode
prices are set. As discussed in section
III.D.4.b.(3) of this final rule, to the
extent that care redesign under the
EPMs increases utilization of these
services to improve episode quality and
efficiency, periodic updates to the 3
years of historical data used to establish
EPM-episode benchmark prices would
result in greater representation of these
services that reflect more recent care
patterns.
Additionally, we do not believe that
it would be appropriate to exclude
behavioral health and substance abuse
services, including psychiatric
readmissions, from EPM episodes
because these services are for conditions
that are likely to affect EPM episode
care. We note that these services are not
common in episodes and, while we
acknowledge that the episode claims
data provided to EPM participants will
not include these data, our proposal to
exclude this information but include the
costs of the services in EPM episodes is
consistent with our usual treatment of
these services in other similar CMS
programs and models where providers
must take on risk in managing the care
of their beneficiaries, such as the Shared
Savings Program and BPCI initiative.
Based on our experience to date with
bundled payment models and the
Shared Savings Program, this policy has
not been a significant impediment to the
operations of these efforts. For example,
in the most recent episodes in BPCI
Models 2 and 3, the claims for
behavioral health and substance abuse
services included in episodes that we
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did not share with BPCI participants
accounted for less than 0.1 percent of
total episode spending. We refer to
section III.K. of this final rule for further
discussion of issues related to sharing
beneficiary-identifiable data for
behavioral health and substance abuse
services with EPM participants.
With regard to the commenters
requesting that we exclude outpatient
chemotherapy services from the EPM
episode definitions, we agree that these
should be excluded from EPM episodes
in accordance with our proposal that
excludes services based on ICD–9–CM
and ICD–10–CM cancer diagnosis codes
on the proposed EPM exclusion lists
from historical and actual EPM
episodes. In the case of high-cost
intravenous therapy administered
through DME, we would only exclude
such treatments if the claims reported
ICD–10–CM diagnosis codes that would
identify these services as unrelated to
the EPM episodes. Otherwise, despite
the cost of this therapy, these services
would be included in EPM episodes
because they are related.
Comment: Several commenters
recommended CMS to exclude
readmissions for PCI from AMI
episodes, stating that current STEMI
clinical guidelines for the culprit artery
lesion in addition to other multi-vessel
stenosis states, ‘‘Approximately 50% of
patients with STEMI have multivessel
disease. PCI options for patients with
STEMI and multivessel disease include:
(1) Culprit artery-only primary PCI, with
PCI of non-culprit arteries only for
spontaneous ischemia or intermediate
or high-risk findings on pre-discharge
noninvasive testing; (2) multi-vessel PCI
at the time of primary PCI; or (3) culprit
artery-only primary PCI followed by
staged PCI of non-culprit arteries.’’ 58
Another commenter quoted on the topic
from the most recent update to the
guidelines published in 2016,
‘‘Although several observational studies
and a network meta-analysis have
suggested that multivessel staged PCI
may be associated with better outcome
than multivessel primary PCI, there are
insufficient observational data and no
randomized data at this time to inform
a recommendation with regard to the
optimal timing of nonculprit vessel
PCI.’’
58 Levine GN, Bates ER, Blankenship JC, et al.
2015 ACC/AHA/SCAI Focused Update on Primary
Percutaneous Coronary Intervention for Patients
With ST-Elevation Myocardial Infarction: An
Update of the 2011 ACCF/AHA/SCAI Guideline for
Percutaneous Coronary Intervention and the 2013
ACCF/AHA Guideline for the Management of STElevation Myocardial Infarction. J Am Coll Cardiol.
2016;67(10):1235–1250. doi:10.1016/
j.jacc.2015.10.005.
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The commenters recommended CMS
to exclude planned readmissions for PCI
from the AMI episode definition
because the AMI model as proposed
would discourage the recommended
course of care of a secondary PCI
procedure for AMI patients with
multivessel disease. The commenters
believe that the AMI episode definition
could encourage the treatment of
secondary lesions during the initial
angioplasty and in other cases could
provide an incentive to delay treatment
of the secondary lesions until after the
90-day post-hospital discharge duration
of the AMI episode has concluded. The
commenters added that another strategy
of EPM participants to deal with limited
AMI episode payments might be to
inappropriately refer multivessel
disease patients into the separate CABG
model.
Alternatively if CMS does not
excluded planned PCI readmissions, the
commenters recommended CMS to
exclude STEMI beneficiaries with
multivessel disease from the AMI model
and/or make accommodations in the
pricing methodology for the extra cost of
treating such beneficiaries
appropriately. As another alternative,
the commenters requested that CMS
shorten the AMI episode duration to 30
days post-discharge so that secondary
PCI could be performed for multivessel
disease without the financial constraints
of an ongoing AMI episode. Finally, the
commenters recommended that if the
AMI episodes cannot be revised to avoid
these potentially harmful incentives,
CMS should monitor and evaluate
whether these shifts in pattern of care
are occurring and whether they have
affected patient outcomes.
Response: While we appreciate the
concerns of the commenters, as we
stated in the proposed rule (81 FR
50852), fewer than 3 percent of those
AMI model beneficiaries who receive
inpatient or outpatient PCIs during AMI
episodes receive the PCIs between 2 and
90 days post-discharge from an anchor
or chained anchor hospitalization. Since
a PCI for an AMI typically is provided
during the anchor hospitalization and
most PCIs later in an episode occur in
the context of a beneficiary presenting
through the emergency department, we
believe that in most cases of PCI
following discharge from the anchor
hospitalization, the beneficiary likely
has experienced a complication of care
resulting in a PCI that may potentially
be avoided through care management
during the AMI episode. This PCI would
clearly be related to the AMI episode
and should not be excluded from the
AMI episode.
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It would also be inappropriate to
exclude beneficiaries with STEMI and
multivessel disease from the AMI model
simply because their plan of care could
include a secondary PCI procedure as
these beneficiaries would represent
nearly 50 percent of STEMI patients,
who themselves make up a significant
percent of beneficiaries in the AMI
model. While we expect that few
beneficiaries would follow this care
pattern based on our analysis of
historical AMI episodes, in this scenario
the PCI would clearly be related to the
AMI and, therefore, be appropriately
included in the AMI episode definition.
Given that our intention is to offer
appropriate incentives for care quality
and efficiency by holding AMI model
participants accountable for
readmissions that could be related to the
quality of care provided prior to the
readmission, we believe that a pricing
adjustment for a PCI readmission or
outpatient PCI would not be
appropriate.
We note that the recently updated
treatment guidelines cited by the
commenters state there is insufficient
observation data and no randomized
data to inform a recommendation
regarding the optimal timing of nonculprit vessel PCI. The guidelines
contain no specific recommendation for
the timing of delayed treatment of
secondary lesions, while specifically
stating that the ‘‘recommendation with
regard to multivessel primary PCI in
hemodynamically stable patients with
STEMI has been upgraded and modified
. . . to include consideration of
multivessel PCI, either at the time of
primary PCI or as a planned, staged
procedure.’’ Given that there is no
specific recommendation regarding the
routine performance of multivessel PCI
for patients with STEMI and multivessel
disease, nor a recommendation on the
timing for multivessel PCI if it is
performed, we do not believe the AMI
model definition discourages patterns of
care that are recommended for AMI
patients with multivessel disease. We
also do not see any reason why the care
patterns related to performing PCI for
multivessel disease following STEMI
should lead us to shorten the AMI
episode duration from 90 days postdischarge to 30 days or to make a
pricing adjustment for AMI episodes
that include this pattern of care. We
refer to section III.C.4.c.(2) of this final
rule for further discussion of the AMI
episode duration.
As recommended by the commenters,
we will evaluate care patterns under the
AMI model for secondary PCI following
an initial PCI for treatment of AMI to
determine whether shifts in care are
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occurring and whether changes in
beneficiary outcomes are observed. We
refer to section IV. of this final rule for
further discussion of our plans for
evaluation of the AMI model.
Comment: One commenter requested
confirmation of their understanding of
CMS’ proposal to exclude MS–DRGs for
inpatient hospital readmissions that
group to the ‘‘Trauma medical’’ category
of diagnoses. The commenter
interpreted this provision as trauma
diagnoses unrelated to the initial MS–
DRG triggering an episode.
Response: By trauma medical
diagnoses, we mean that those MS–
DRGs that represent a readmission for
medical treatment of trauma during an
EPM episode are excluded. For
example, we would exclude MS–DRGs
082–087 in the Traumatic Stupor &
Coma series and MS–DRGs 088–090 in
the Concussion series.
Comment: Several commenters
recommended CMS to exclude hospice
services from the EPM episode
definition as they generally would be
unrelated to the EPM episodes. The
commenters stated that including
hospice services in EPM episodes could
result in incentives for underutilization
of the hospice benefit. They encouraged
CMS to exclude all hospice services in
order to ensure timely access to hospice
for EPM beneficiaries. One commenter
pointed out that exclusion of hospice
services from the EPM episode
definitions would be consistent with
their exclusion from BPCI episodes.
Response: We appreciate the interest
of the commenters in ensuring
continued beneficiary access to hospice
services under the EPMs. We note that
although we exclude hospice services
from BPCI episodes, we include them in
LEJR episodes in the CJR model (80 FR
73307). We understand that EPM
beneficiaries could receive hospice
services during an episode under
several different types of clinical
circumstances. For example, the
beneficiary could be enrolled in hospice
prior to a SHFFT episode, experience a
pathologic hip fracture, and require a
SHFFT procedure to stabilize his or her
hip. Alternatively, the beneficiary could
have a CABG and enter into hospice at
some point during the episode in the 90
days following discharge from the
anchor hospitalization, either after
experiencing a surgical complication
leading to a terminal prognosis,
progressive severe heart failure despite
the CABG, or based on a new diagnosis
of a terminal stage of an illness.
As we explained in the CJR Final Rule
(80 FR 73307), Medicare hospice care is
palliative care for individuals with a
prognosis of living 6 months or less if
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the terminal illness runs its normal
course. As referenced in § 418.22(b)(1),
to be eligible for Medicare hospice
services, the patient’s attending
physician (if any) and the hospice
medical director must certify that the
individual is ‘‘terminally ill,’’ as defined
in section 1861(dd)(3)(A) of the Act and
our regulations at § 418.3; that is, the
individual’s prognosis is for a life
expectancy of 6 months or less if the
terminal illness runs its normal course.
When an individual is terminally ill,
many health problems are brought on by
underlying condition(s), as bodily
systems are interdependent. Section
1861(dd)(1) of the Act establishes the
services that are to be rendered by a
Medicare certified hospice program and
those services include: Nursing care;
physical therapy; occupational therapy;
speech-language pathology therapy;
medical social services; home health
aide services (now called hospice aide
services); physician services;
homemaker services; medical supplies
(including drugs and biologics); medical
appliances; counseling services
(including dietary counseling); shortterm inpatient care (including both
respite care and care necessary for pain
control and acute or chronic symptom
management) in a hospital, nursing
facility, or hospice inpatient facility;
continuous home care during periods of
crisis and only as necessary to maintain
the terminally ill individual at home;
and any other item or service which is
specified in the plan of care and for
which payment may otherwise be made
under Medicare, in accordance with
Title XVIII of the Act. The services
offered under the Medicare hospice
benefit must be available, as needed, to
beneficiaries 24 hours a day, 7 days a
week (section 1861(dd)(2)(A)(i)of the
Act).
The regulations at § 418.54(c)
stipulate that the comprehensive
hospice assessment must identify the
patient’s physical, psychosocial,
emotional, and spiritual needs related to
the terminal illness and related
conditions, and address those needs in
order to promote the hospice patient’s
well-being, comfort, and dignity. The
comprehensive assessment must take
into consideration the following factors:
The nature and condition causing
admission (including the presence or
lack of objective data and subjective
complaints); complications and risk
factors that affect care planning;
functional status; imminence of death;
and severity of symptoms (§ 418.54(c)).
Additionally, the hospice Conditions of
Participation (CoPs) at § 418.56(c)
require that the hospice must provide
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257
all reasonable and necessary services for
the palliation and management of the
terminal illness, related conditions and
interventions to manage pain and
symptoms. Therapy and interventions
must be assessed and managed in terms
of providing palliation and comfort
without undue symptom burden for the
hospice patient or family. In the
December 16, 1983, Hospice final rule
(48 FR 56010 through 56011), regarding
what is related versus unrelated to the
terminal illness, we stated: ‘‘We believe
that the unique physical condition of
each terminally ill individual makes it
necessary for these decisions to be made
on a case–by-case basis. It is our general
view that hospices are required to
provide virtually all the care that is
needed by terminally ill patients.’’
Thus, we believe that hospice services
furnished to EPM beneficiaries should
be included in the episode definition for
the EPMs, regardless of the specific
diagnosis of the beneficiary, because
hospices are to provide virtually all care
that is needed by terminally ill patients.
This is consistent with our conclusion
when we considered hospice services in
the LEJR episode definition under the
CJR model (80 FR 73307). If an EPM
beneficiary was receiving hospice
services during an episode, either
because the beneficiary was enrolled in
hospice prior to surgery or a cardiac
event and continued in hospice
following surgery or the cardiac event or
the beneficiary enrolled in hospice
following the surgery or cardiac event
that initiated the EPM episode, we
believe that hospice services would
encompass care related to the EPM
episode and should, therefore, be
included in the episode definition. As
previously noted, given the
comprehensive nature of the hospice
benefit and the fact that body systems
are interdependent at end of life,
virtually all care needed by the
terminally-ill individual would be
related to the terminal prognosis and
thus the responsibility of the hospice.
As previously noted, hospices are
required, per the Hospice CoPs at
§ 418.56(c), to provide all reasonable
and necessary services for the palliation
and management of the terminal illness,
related conditions, and interventions to
manage pain and symptoms. For
patients that underwent surgery or
cardiac care under the EPMs that have
also elected the Medicare hospice
benefit, hospice services would need to
respond to the care needs of the EPM
beneficiary following surgery or
hospitalization for cardiac care. As in
the case of other medically necessary
services that would improve a
beneficiary’s quality of care and quality
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of life, we expect that EPM beneficiaries
will receive clinically appropriate
referrals to hospice in a timely manner.
Furthermore, we also believe hospice
services could contribute to episode
efficiency through improved
comprehensive care coordination and
management for EPM beneficiaries that
have a terminal prognosis. As
previously stated, hospices are required
to provide comprehensive care
coordination and management per the
hospice CoPs at 418.56. As discussed in
sections III.G.4. through 6. of this final
rule, we will be monitoring for access to
care, quality of care, and delayed care
and will take actions as described if
problems are found.
Comment: One commenter
recommended that CMS exclude
Inpatient Psychiatric Facility (IPF)
services from the EPM episode
definition as not being related to or
resulting from the EPM clinical
condition, consistent with their
treatment in BPCI episodes.
Response: We are clarifying that
under the BPCI models, IPF services
furnished following discharge from the
episode anchor hospitalizations but
during the episode are included in the
episode definition, unless they fall into
one of the excluded MS–DRGs for the
episode. Thus, we include inpatient
psychiatric services whether paid under
the IPPS or the IPF PPS in all episodes
under the BPCI initiative according to
the same policy that would exclude
readmissions paid under either payment
system based on the same exclusion list.
As we concluded for the CJR model (80
FR 73306), we see no reason for the
EPMs not to apply the standards we
proposed to define related and
unrelated Part A and Part B services
with respect to IPF services furnished
during EPM episodes. Therefore, we
believe the list of excluded MS–DRGs
applicable to the EPM episode identifies
those IPF admissions during the episode
that would be clinically unrelated to the
episode so we exclude them from the
EPM episode definition, whereas IPF
services any time during an EPM
episode that result in discharge from an
MS–DRG that is not excluded would be
related and included in the EPM
episode definition. We disagree with the
commenter that all IPF services
furnished following discharge from the
anchor hospitalization that initiates the
EPM episode after surgery are unlikely
to be related to or resulting from the
EPM clinical condition or its treatment.
Thus, we believe the MS–DRG
exclusions for the EPM episodes
identify those circumstances when IPF
services are unrelated to the episode.
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Comment: Several commenters
recommended that CMS exclude postacute care services from EPM episodes
if the beneficiary chooses a facility not
recommended by the EPM participant or
treating physician. Other commenters
recommended that CMS exclude postacute care services following excluded
readmissions due to how little is known
about the causal relationship between
an unrelated hospital readmission and
subsequent post-acute care services.
Response: As discussed in section
III.G.2. of this final rule, the proposed
EPMs would not limit an EPM
beneficiary’s ability to choose among
Medicare providers or the range of
services that would be available to
them. Beneficiaries would continue to
choose any Medicare participating
provider, or any provider that has opted
out of Medicare, with the same costs,
copayments, and responsibilities as they
have with other Medicare services.
Therefore, it would not be appropriate
to exclude post-acute care services from
the EPM episode definition if the
beneficiary chooses a post-acute care
facility that is not recommended by the
EPM participant or the beneficiary’s
treating physician.
With regard to requests that we
exclude post-acute services from EPM
episodes following excluded
readmissions, as Part A services are
generally intended to be comprehensive
in nature and because the beneficiary in
an EPM episode would still be in the
recovery period for the 90 days
following surgery or an AMI, we believe
any post-acute care services provided
during the EPM episode would be
related to the SHFFT, CABG, or AMI.
Regardless of the reason for the
hospitalization immediately preceding
the initiation of post-acute care services
during an EPM episode, the post-acute
care provider would need to address the
beneficiary’s post-surgical or post-AMI
recovery, even if the post-acute care
services followed an unrelated
admission to the hospital.
Comment: Several commenters
identified additional MS–DRGs or
conditions resulting in hospitalization
that they recommended be excluded
from the cardiac episodes. The
commenters requested that clinical
conditions that group to the following
MS–DRGs be excluded from the AMI
and CABG model episode definitions,
generally on the basis that these
readmissions are not integral to the
management of beneficiaries in the 90
days following discharge from the AMI
or CABG anchor hospitalization:
• 222 (Cardiac Defibrillator Implant
with Cardiac Catheterization with AMI/
HF/Shock with MCC).
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• 223 (Cardiac Defibrillator Implant
with Cardiac Catheterization with AMI/
HF/Shock without MCC).
• 224 (Cardiac Defibrillator Implant
with Cardiac Catheterization without
AMI/HF/Shock with MCC).
• 225 (Cardiac Defibrillator Implant
with Cardiac Catheterization without
AMI/HF/Shock without MCC).
• 226 (Cardiac Defibrillator Implant
without Cardiac Catheterization with
MCC).
• 227 (Cardiac Defibrillator Implant
without Cardiac Catheterization without
MCC).
• 266 (Endovascular Cardiac
Replacement with MCC).
• 267 (Endovascular Cardiac
Replacement without MCC).
• 273 (Percutaneous Intracardiac
Procedures with MCC).
• 274 (Percutaneous Intracardiac
Procedures without MCC).
Another commenter claimed that
CMS’ proposal to include nearly all
surgical MS–DRGs within Major
Diagnostic Category (MDC) 5 (Diseases
and Disorders of the Circulatory System)
in the AMI and CABG episode
definition, rather than also requiring an
acute care ICD–CM diagnosis code on
the claim for the MS–DRG in MDC 5 to
be included in the episode, especially
within the 31 to 90 days following
discharge from the anchor
hospitalization, could penalize hospitals
for providing necessary care within the
timeframe for AMI and CABG episodes.
Examples provided by the commenter
included abdominal aortic aneurysm;
peripheral bypass surgical and
endovascular procedures; surgical valve
repair or replacement; planned inpatient
or outpatient electrophysiology
admissions to replace cardiac
defibrillators or pacemakers; and staged
outpatient revascularization procedures
several months after an initial
intervention for AMI.
One commenter recommended that
readmissions for extracorporeal
membrane circulation (ECMO) that
would group to MS–DRG 003 (ECMO or
Tracheostomy with MV > 96 hours or
PDX Except Face, Mouth and Neck with
Major O.R. Procedure) be excluded from
the CABG episode definition. Another
commenter recommended the addition
of 241 MS–DRGs to CMS’ the
readmissions exclusion list for CABG
episodes, in addition to the 370 MS–
DRGs proposed by CMS on the list, on
the basis that these MS–DRGs did not
have any clinical relevance to CABG.
These additional MS–DRGs would
result in the exclusion of 611 MS–DRGs
out of a total of approximately 760 MS–
DRGs from CABG episodes.
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Finally, the commenter who favored
CMS’ adopting a more robust
methodology for differentiating planned
from unplanned use of inpatient and
outpatient services within the 90-day
post-discharge period, similar to the
methodology used in the HRRP for AMI
and CABG, requested that should CMS
continue with the MS–DRG exclusion
list that CMS revisit the proposed
exclusion lists for AMI and CABG
episodes. The commenter claimed there
were some inconsistencies in the
treatment of AMI MS–DRG-anchored
AMI episodes and CABG episodes
compared with PCI MS–DRG-anchored
AMI episodes. The commenter
identified MS–DRGs 326 (Stomach,
Esophageal, and Duodenal Procedures
with MCC); 327 (Stomach, Esophageal,
and Duodenal Procedures with CC); 328
(Stomach, Esophageal, and Duodenal
Procedures without CC/MCC); 266
(Endovascular Cardiac Valve
Replacement with MCC); and 267
(Endovascular Cardiac Valve
Replacement without MCC) as on the
PCI MS–DRG-anchored AMI exclusion
list but not on the AMI MS–DRGanchored AMI and CABG MS–DRG
exclusion list, and was unclear about
the rationale for these differences.
Response: We appreciate the requests
by the commenters to add certain MS–
DRGs to the exclusion list for one or
both of the cardiac care models. CMS
clinicians and coding staff reviewed the
three different proposed exclusion lists
for AMI MS–DRG-anchored AMI
episodes, PCI MS–DRG-anchored AMI
episodes, and CABG episodes for the
inconsistencies identified by one of the
commenters against the proposed
standards for excluding readmissions
during EPM episodes. We proposed to
exclude MS–DRGs 326–328 from PCIanchored AMI episodes and CABG
episodes but not from AMI MS–DRGanchored episodes. Based on clinical
review, we determined that admissions
to these MS–DRGs would be for acute
disease surgical diagnoses unrelated to
a condition resulting from or likely to
have been affected by care during the
AMI or CABG episode so these MS–
DRGs meet the proposed standards for
exclusion from AMI MS–DRG-anchored
AMI episodes. Therefore, we are adding
MS–DRGs 326–328 to the AMI MS–
DRG-anchored AMI exclusion list. MS–
DRGs 266–267 are on the exclusion list
for PCI MS–DRG-anchored AMI
episodes, but not on the exclusion list
for AMI MS–DRG-anchored AMI
episodes or CABG episodes. Based on
clinical review, we determined that
admissions to these MS–DRGs would be
for chronic disease surgical diagnoses
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unrelated to a condition likely to have
been affected by care during the AMI or
CABG episode so these MS–DRGs meet
the proposed standards for exclusion
from both AMI MS–DRG-anchored AMI
episodes and CABG episodes. Therefore,
we are adding MS–DRGs 266–267 to the
AMI MS–DRG-anchored AMI exclusion
list and the CABG exclusion list.
We note that MS–DRGs 222–227 and
273–274 requested for exclusion from
AMI and CABG episodes by several
commenters are surgical MS–DRGs in
MDC 5. As another commenter pointed
out, some of these may represent
planned readmissions following
discharge from the anchor
hospitalization during the 90-day postdischarge period. However, based on
our proposed readmission exclusion
methodology that identifies excluded
MS–DRGs without examining the
diagnosis coding on hospital claims to
determine the reason for the
readmission, as discussed in our
response to comments earlier in this
section, we will not exclude planned
readmissions from the AMI and CABG
episode definitions. Thus, we proposed
that MS–DRGs 222 through 227 and 273
through 274 not be excluded from AMI
(regardless of PCI or AMI MS–DRGanchor) and CABG episodes, and we are
continuing to include these MS–DRGs
in those episodes, as well as the other
surgical MS–DRGs in MDC 5 that we
did not propose to exclude from all AMI
and CABG episodes. Based on clinical
review, we determined that these
readmissions for circulatory system
procedures are related services in AMI
and CABG episodes, based on our
proposed standards for excluding
surgical MS–DRGs from the EPMs:
Chronic disease surgical diagnoses
unrelated to a condition likely to have
been affected by care during the EPM
episode; and acute disease surgical
diagnoses unrelated to a condition
resulting from or likely to have been
affected by care during the EPM
episode. While some commenters stated
that these readmissions were not
integral to AMI and CABG episodes,
that is not the standard we used for
determining related readmissions
because we are adopting broad episode
definitions for the EPMs. While we are
not adopting any specific methodologies
for identifying and making episode
payment adjustments for such planned,
related readmissions now except in the
case of a CABG readmission during an
AMI episode as discussed in section
III.D.4.b.(2).(c). of this final rule, we will
study this issue in more detail
especially as it relates to the cardiac
models. Should we determine a change
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259
to our policies regarding planned,
related readmission could be
appropriate, we will make proposals
through future rulemaking.
Finally, we carried out a clinical
review of the 241 MS–DRGs
recommended by a commenter for
addition to the CABG exclusion list, as
well as MS–DRG 003 that was
recommended for exclusion by another
commenter. About three-quarters of the
MS–DRGs recommended for exclusion
were medical MS–DRGs that did not
meet our proposed standards for
excluding readmissions based on
medical diagnoses, specifically
oncology or trauma medical diagnoses.
As we first discussed in the CJR Final
Rule (80 FR 73304) and in the EPM
proposed rule (81 FR 50833), we believe
all other readmissions for medical MS–
DRGs should be included in EPM
episodes because these are generally
linked to the condition that was the
focus of the anchor hospitalization as a
complication of that illness, a
complication of treatment or
interactions with the health care system,
or a chronic illness that may have been
affected by the course of episode care.
The inclusion of most MS–DRGs in EPM
episodes should encourage providers to
focus on comprehensive care for
beneficiaries during episodes. More
than half of the surgical MS–DRGs
recommended for CABG episode
exclusion were in MDC 5 and, with the
exception of MS–DRGs 266–267
discussed previously, we will not
exclude them from CABG episodes
based on the reasons discussed earlier
in this response. Of the remaining
surgical MS–DRGs spread across 7
MDCs representing different body
systems, we will also not exclude any of
these MS–DRGs because they do not
meet our standards for excluding MS–
DRGs from CABG episodes, namely that
the readmissions are for chronic disease
surgical diagnoses unrelated to a
condition likely to have been affected by
care during the CABG episode or acute
disease surgical diagnoses unrelated to
a condition resulting from or likely to
have been affected by care during the
CABG episode. We believe that our
determinations may be different than
the commenters’ recommendations
because our standard for exclusion in
broadly defined CABG episodes is much
more stringent than the commenters’
review of MS–DRGs based on their
clinical relevance to CABG.
Comment: Several commenters
requested that CMS add MS–DRGs 469
and 470 for major joint replacement of
the lower extremity to the exclusion list
for SHFFT episodes, unless the joint
replacement was for the joint that
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underwent a SHFFT procedure that
initiated the SHFFT episode. The
application of the exclusion in this way
would exclude elective LEJR
readmissions from SHFFT episodes. The
commenters claimed this approach
would avoid outliers and penalizing the
orthopedic surgeon for identification
and treatment of unmet medical needs
while treating a beneficiary following a
hip fracture. One commenter stated that
these circumstances would be highly
variable, particularly in hospitals with
small patient volume. They
recommended excluding MS–DRGs 469
and 470 from SHFFT episodes so as not
to penalize low-volume hospitals who
performed costly elective LEJR during
SHFFT episodes on an occasional basis.
Response: Based on our proposed
methodology to identify excluded
readmissions by a list of MS–DRGs, we
would have to substantially increase the
complexity of our exclusions
methodology to identify only a subset of
MS–DRG 469 and 470 readmissions for
exclusion because they were not related
to the joint surgery that initiated the
SHFFT episode. We do not believe this
additional complexity is necessary
because we expect that LEJR
replacement of another joint, whether
elective or for fracture, would be rare
during SHFFT episodes. Most LEJR is
elective, rather than for fracture, and
given the prolonged partial weightbearing commonly required for recovery
from SHFFT procedures and the general
complexity and frailty of many
beneficiaries who would be included in
SHFFT episodes, we believe that
elective LEJR of a joint other than that
involved in the initial SHFFT surgery
during the 90 days post-discharge from
the SHFFT model anchor
hospitalization would be exceedingly
rare. We would expect that most LEJR
procedures during SHFFT episodes
would be related because they would
involve the joint that had an initial
SHFFT procedure.
Comment: One commenter
recommended that CMS exclude Part B
services from CABG episodes based on
individual ICD–9–CM and ICD–10–CM
diagnosis codes, rather than categories
as CMS proposed. The commenter
claimed that CMS’ proposed process
would result in over 22,000 ICD–10–CM
diagnosis codes that would be classified
as included in the CABG episode,
thereby resulting in those services being
considered as related items and
services. The commenter believes that
this methodology would result in many
of the included services having no
clinical relevance to a CABG. The
commenter recommended CMS to
specify Part B episode exclusions at the
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ICD–CM code level to ensure that only
services that are clinically related to a
CABG are included in the episode. The
commenter recommended 4,960 specific
ICD–9–CM and 18,859 specific ICD–10–
CM diagnosis codes be added to the
CABG exclusion list.
Another commenter recommended
that CMS exclude the following ICD–
10–CM diagnosis code categories from
AMI episodes as they are not integral to
AMI treatment: I47 (Paroxysmal
tachycardia); I48 (Atrial fibrillation and
flutter); and I49 (Other cardiac
arrhythmias). The same commenter
recommended that CMS exclude ICD–9–
CM diagnosis code category 427
(Cardiac dysrhythmias) from AMI
episodes.
Response: We appreciate the
recommendations from the commenter
about additional ICD–9–CM and ICD–
10–CM diagnosis code categories to be
excluded from AMI episodes. However,
with respect to their requested additions
to the AMI Part B exclusion list, we
believe the four categories of ICD–CM
codes recommended for exclusion do
not meet our proposed Part B exclusions
standards, specifically those services
that are for acute disease diagnoses
unrelated to a condition resulting from
or likely to have been affected by care
during the EPM episode or for certain
chronic disease diagnoses, depending
on whether the condition was likely to
have been affected by care during the
EPM episode or whether substantial
services were likely to be provided for
the chronic condition during the EPM
episode. The ICD–CM diagnosis code
categories describe different types of
cardiac arrhythmias, which can result
from an AMI, where the arrhythmia
would be an acute condition related to
the AMI episode, or can be a chronic
condition where the management of the
arrhythmia would be affected by the
AMI treatment. Thus, we do not agree
with the commenter that these ICD–CM
diagnosis code categories should be
excluded from AMI episodes.
With respect to CABG episodes,
another commenter recommended
almost 19,000 ICD–10–CM diagnosis
codes be added to the CABG exclusion
list. The commenter submitted
individual codes in 750 ICD–10–CM
categories for exclusion, of which there
were 563 categories (75%) in which
they requested excluding all codes. We
note that there are about 71,000 billable
ICD–10–CM codes in 1,910 categories,
compared to about 15,000 ICD–9–CM
codes in 1,042 categories. Due to the
large number of diagnosis codes, we
believe it would be operationally
infeasible and unnecessarily complex to
determine excluded Part B services at
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the individual diagnosis code level. We
further believe that the ICD–CM
diagnosis code categories are
sufficiently narrow and descriptive that
they can be appropriately used to
determine Part B exclusions without
substantial risk of misidentifying
services that are unrelated to CABG
episodes according to our proposed Part
B exclusions standards. We have several
years of experience with 48 different
BPCI clinical episodes in Model 2,
including CABG, which has a similar
design to the proposed CABG model.
We have encountered no significant
concerns from BPCI Awardees or other
stakeholders about our BPCI
methodology which excludes Part B
services based on ICD–CM diagnosis
code categories, just as we use in the
CJR model and proposed for the CABG
model. Therefore, we are continuing to
consider changes to the Part B exclusion
list for the EPMs based on ICD–CM
categories.
We did not perform another clinical
review of the 187 categories where the
commenter only requested that we
exclude some of the individual ICD–10–
CM diagnosis codes in the category,
because we will continue to exclude
ICD–10–CM codes at the category level.
CMS clinicians and coding staff
reviewed all of the 563 ICD–10–CM
diagnosis code categories where the
commenter recommended that we
exclude all the diagnosis codes in order
to make a determination about
additional exclusions at the category
level. While the commenters claimed
that diagnosis codes in these categories
had no clinical relevance to CABG, we
do not agree that the additional
categories where the commenter
recommended 100 percent of the ICD–
10–CM diagnosis codes for exclusion
meet our proposed standards for
exclusion. For example, the commenter
requested that we exclude the categories
K20 (Esophagitis) and I12 (Hypertensive
chronic kidney disease) for Part B
services from the CABG model episode
definition. However, these two ICD–10–
CM diagnosis code categories do not
meet our proposed standards for the
exclusion of Part B services because
they include acute disease diagnoses for
a condition arising from or likely to
have been affected by care during the
CABG episode in the case of Esophagitis
and chronic disease diagnoses likely to
have been affected by care during the
CABG episode in the case of
Hypertensive chronic kidney disease.
The commenter’s recommendations
were prepared based on a standard of
‘‘clinical relevance’’ to CABG which we
believe is too narrow to define related
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Part B services for the proposed CABG
model which was designed to test
comprehensive, coordinated patientcentered care for the beneficiary
throughout broadly defined EPM
episodes. In our clinical review based
on the proposed standards for Part B
exclusions, we determined that the 563
ICD–10–CM diagnosis code categories
where the commenter recommended
that we exclude 100 percent of the
diagnosis codes do not meet the
standards for exclusion from CABG
episodes. Therefore, we are making no
changes to the CABG episode ICD–10–
CM Part B exclusion list.
The same commenter who made
recommendations about additional ICD–
10–CM diagnosis code exclusions also
recommended ICD–9–CM diagnosis
codes in 436 ICD–9–CM categories for
exclusion, and of those, the commenter
recommended that all codes be
excluded in 336 (77 percent) of the
categories. We did not perform an
additional clinical review of the
categories where the commenter only
requested that we exclude some of the
individual ICD–9–CM diagnosis codes
in the category, as we will continue to
exclude ICD–9–CM codes at the
category level. CMS clinicians and
coding staff reviewed all of the 100 ICD–
9–CM diagnosis categories where the
commenter recommended that we
exclude all the diagnosis codes in order
to make a determination about
additional exclusions at the category
level. Similar to our findings from our
review of the ICD–10–CM diagnosis
code categories where all codes were
recommended for exclusion, the ICD–9–
CM categories with all codes
recommended by the commenter for
CABG episode exclusion do not meet
our proposed exclusion standards for
Part B services. For example, the
commenter recommended that we
exclude all codes in ICD–9–CM
diagnosis code category 584 (Acute
kidney failure) and 250 (Diabetes
mellitus) from CABG episodes.
However, these two ICD–9–CM
diagnosis code categories do not meet
our proposed standards for the
exclusion of Part B services because
they include acute disease diagnoses for
a condition arising from or likely to
have been affected by care during the
CABG episode in the case of Acute
kidney failure and chronic disease
diagnoses likely to have been affected
by care during the CABG episode in the
case of Diabetes mellitus. In our clinical
review, we found that none of the 100
ICD–9–CM categories where the
commenter recommended that we
exclude 100 percent of the diagnosis
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codes meet our proposed standards for
excluding Part B services from CABG
episodes, so we are making no changes
to the CABG episode ICD–9–CM Part B
exclusion list.
Comment: One commenter stated that
their understanding was that emergency
transportation of beneficiaries with AMI
would be included in AMI episodes.
The commenter pointed out that this
cost could vary substantially based on
the transport mileage and the mode of
transport, with air transport being
substantially more costly than ground
transport. The commenter claimed that
the EPM participant where the episode
would be initiated has little or no input
on the transport method used but would
be held accountable for the
transportation cost in the AMI episode.
The commenter requested that transport
of the beneficiary to the AMI model
participant where the AMI episode is
initiated be excluded because the AMI
model participant would have little or
no control of that cost.
Response: We proposed to include all
Part A and Part B items and services in
AMI episodes beginning with the
admission of the beneficiary for the
anchor hospitalization and extending
through anchor hospitalization
discharge, whereupon the AMI model
exclusion list would be applied to Part
A and Part B items and services during
the 90 days post-discharge to make a
determination about their inclusion in
the AMI episode definition. With
respect to the inclusion of Part B
ambulance claims for air or ground
transport in the AMI episode definition,
we would exclude those services that
occurred prior to the hospital
admission. If the ambulance transport
occurs on the day of initial admission
for the anchor hospitalization and has
place-of-service code for ambulance on
the claim, the claim would not be
included in the AMI episode definition,
an approach which would be consistent
with the specific request of the
commenter.
However, if ambulance transport
occurs any other time during the anchor
hospitalization, the transportation
would be included in the AMI episode
definition as we include all Part B
services without regard to the Part B
exclusion list, except DME to which we
apply the Part B exclusion list during
the anchor hospitalization as well.
Following discharge from the anchor
hospitalization, the inclusion or
exclusion of ambulance transport in the
AMI episode during the 90 day postdischarge would be determined by our
proposed methodology for determining
exclusion of any Part B items and
services based on the principal
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261
diagnosis code on the claim and
whether that diagnosis code is on the
AMI model exclusion list.
We note that medically appropriate
air ambulance transportation is a
Medicare-covered service regardless of
the state or region in which it is
rendered. However, contractors approve
claims only if the beneficiary’s medical
condition is such that transportation by
either basic or advanced life support
ground ambulance is not appropriate.
Medical reasonableness is only
established when the beneficiary’s
condition is such that the time needed
to transport a beneficiary by ground, or
the instability of transportation by
ground, poses a threat to the
beneficiary’s survival or seriously
endangers the beneficiary’s health.59
Thus, the circumstances of covered air
transport are limited and, once the AMI
episode is initiated, the AMI model
participant would have an ongoing role
in beneficiary care that would result in
the participant’s input into the mode of
transport should transport be required.
Comment: One commenter
recommended that CMS include the
costs of pre-operative home visits in
EPM episodes, including services to
discuss goals of care and advance care
planning services. Another commenter
requested that CMS account for
preventive services in the EPMs,
although they acknowledged the
associated challenges in benchmarking
target prices based on historical claims
data. One commenter suggested that
CMS include the proposed HCPCS Gcodes for the Collaborative Care model
such that screening and follow-up
would be included in the payment
structure for each EPM, while another
commenter recommended CMS to make
resources for care coordination
strategies available to support advancing
care coordination through appropriate
pre-discharge planning and postdischarge follow up. The commenter
observed that the majority of
opportunities to advance care
coordination and improve patient
outcomes are in decreasing hospital
length of stay to only what is necessary
for appropriate treatment, preventing
unnecessary readmissions, and
controlling post-acute care costs. The
commenter stated that opportunities to
improve care coordination include
strong pre-discharge planning activities;
prevention of unnecessary patient visits
to the emergency department through
early recognition of decompensation;
increasing appropriate referral to
cardiac rehabilitation services; and
59 Medicare Benefit Policy Manual, Chapter 10—
Ambulance Services, 10.4 and 10.4.2.
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effective patient and family education.
The commenter claimed that ensuring
the social and environmental
components are in place prior to
discharge is critical and that
communication of the most appropriate
post-acute care facilities to not only the
patients, but to their families and
caregivers, can be essential to a patient’s
recovery.
Response: The only items and
services that are included in EPM
episode definitions are those that are
separately paid by Medicare under Part
A or Part B. We established EPM
episode definitions in order to add
Medicare payments for items and
services included in the EPM episode
definitions into EPM-episode
benchmark prices based on historical
EPM episodes and into the calculation
of actual EPM-episode spending. In
addition, we proposed that EPM
episodes begin with the anchor
hospitalization. Therefore, for the same
reasons as discussed in the CJR Final
Rule (81 FR 73316 through 73317)
regarding LEJR episodes, we would not
include any pre-operative home visits
that could be separately paid by
Medicare in the EPM episode
definitions because they would precede
the initiation of the episode which
begins with admission to the hospital
and discharge from an MS–DRG that is
included in the EPM.
In terms of including preventive
services and potential new HCPCS Gcodes for Part B services in the
Collaborative Care model in the EPM
episode definitions, we note that
according to our standard methodology
for identifying excluded Part B services
under the EPMs, specific Part B services
would be included in both historical
EPM episodes and actual EPM episodes
to the extent that the ICD–9–CM or ICD–
10–CM diagnosis code on the claim for
the preventive service or HCPCS G-code
for Part B services in the Collaborative
Care model is related to the EPM
episode and, therefore, not on the EPM
episode exclusion list. With regard to
CMS making specific financial resources
available to EPM participants for predischarge planning, post-discharge
follow-up, or other care coordination
activities, EPM participants would need
to develop their own strategies and use
their own resources for these activities,
as well as engage with EPM
collaborators, to redesign care to achieve
good quality and cost performance
under the EPMs. CMS will not provide
additional payments under the EPMs
specifically for these types of planning
and follow-up activities. However, EPM
participants who achieve acceptable
episode quality or better and reduce
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actual EPM-episode spending below the
quality-adjusted price are eligible for
payment of the difference through a
reconciliation payment, which can
support the resources used by EPM
participants and collaborators in
redesigning care to achieve model
success.
Comment: Several commenters
commended CMS for proposing to
exclude IPPS new technology add-on
payments for drugs, technologies, and
services from EPM episodes, as well as
OPPS transitional pass-through
payments for medical devices. They
believe that these proposals would
ensure EPM beneficiaries/access to
valuable new drugs, technologies,
services, and devices. The commenters
recommended CMS to go further and
exclude additional innovative
technologies from EPM episodes by
establishing a review process to
determine whether their costs should be
excluded from EPM-episode benchmark
prices and actual EPM-episode
spending. The commenters reasoned
that this new review process would
allow manufacturers to identify highcost breakthrough technologies and
treatments that offer clinical
improvements for all or certain types of
patients or offer significant therapeutic
advances for new populations or
conditions. The commenters
recommended that CMS utilize the same
processes as those used to determine
eligibility for IPPS new technology addon payments but without regard to the
statutory or regulatory policies that
apply only to new technology
approvals. They further suggested that
CMS also allow individual EPM
participants to request an EPM payment
adjustment if they adopt breakthrough
treatment in advance of other hospitals,
as well as manufacturers and developers
to request the adjustment.
One commenter recommended CMS
to consider other innovative capital
investments for an EPM episode
payment adjustment and to provide
payment for new technologies at 100
percent of their cost, not 50 percent as
under current CMS programs for
payment of new technologies. Finally,
another commenter suggested that CMS
should provide a financial incentive to
EPM participants to use technologies
that are shown to improve patient
outcomes and reduce cost within 12 to
24 months.
Response: We appreciate the support
of the commenters for our proposals
regarding the exclusion of new
technology payments from EPM
episodes and agree that EPM
beneficiaries should have access to
beneficial new technologies while they
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are in EPM episodes. We do not believe
it would be appropriate for the EPMs to
potentially hamper beneficiaries’ access
to new technologies that are receiving
IPPS new technology add-on payments
or OPPS transitional pass-through
payments or to burden EPM participants
who choose to use these new drugs,
technologies, services, or devices with
concerns about these payments counting
toward actual EPM-episode spending.
However, for the same reasons that
were discussed previously in the CJR
Final Rule (80 FR 73308) regarding LEJR
episodes, we will not establish a new
process to review innovative
technologies or different technologies
that would be ineligible for a payment
adjustment under the Medicare program
and make individual determinations
regarding their exclusion from the EPM
episode definitions, as recommended by
some commenters. Because the EPMs
are retrospective reconciliation models
that pay all providers and suppliers
under the regular Medicare program
throughout the episode of care, we
believe it is more appropriate to rely on
the existing processes under the
Medicare program to make
determinations about separate payment
for new technology items and services.
If those existing processes identify new
technologies that would qualify for addon payments under the IPPS or
transitional pass-through payments
under the OPPS, we will exclude them
from the EPM episode definitions as we
proposed, to ensure that beneficiaries’
access to new technology items and
services is not influenced by their care
being included in the EPMs. Similarly,
under these retrospective EPMs, we will
not provide additional payments for
new technologies beyond those that are
paid under the Medicare program.
Finally, we do not believe it would be
appropriate under the EPMs to provide
financial incentives to EPM participants
to use specific technologies that
improve beneficiary outcomes and
reduce cost over any specific period of
time. We understand that because the
EPMs would extend 90 days postdischarge from the anchor
hospitalization, the EPMs specifically
incentivize the use of technologies and
provision of services that improve
quality and reduce cost within the
limited episode timeframe for which the
EPM participant is responsible for
episode quality and cost performance.
However, we believe that EPM
participants, treating physicians, and
other EPM collaborators are best
positioned to select technologies and
furnish services that improve the quality
of care and reduce cost for EPM
beneficiaries and expect that their
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decisions factor in the long-term
interests of beneficiaries as well.
Comment: One commenter stated that
there was significant evidence
demonstrating that the use of more
expensive drug-eluting stents (DES)
results in better long-term outcomes in
many patients and fewer repeat
procedures for in-stent restenosis. The
commenter added that long-term benefit
for patients (avoiding the risk,
inconvenience and cost of secondary
procedures) and to Medicare (via fewer
repeat procedures in the long term)
would not be fully captured in an
episode extending 90 days post hospital
discharge, but the full additional costs
of DESs would be. The commenter
recommended CMS take steps to ensure
that the financial models used for the
EPMs do not discourage the appropriate
use of DES. The commenter claimed
that if the AMI model results in fewer
beneficiaries receiving DES, long-term
outcomes may deteriorate and overall
costs may grow.
Response: As discussed in section
III.C.4.a.(2) of this final rule, we would
initiate AMI episodes from PCI MS–
DRGs (246–251) with an AMI ICD–CM
diagnosis code in the principal or a
secondary position on the claim for the
anchor hospitalization. Medicare
payment for coronary stents, whether
bare metal or DES, used during a PCI
performed during a hospitalization are
included in the IPPS payment for the
inpatient hospitalization. While they are
not paid separately by Medicare,
payment for the required resources
would be included in AMI episodes
because the IPPS services for the anchor
hospitalization are included in the
episodes. We proposed to risk-stratify
EPM-episode prices based on MS–DRG
as discussed in section III.D.4.b.(1) of
this final rule and there are separate
MS–DRGs for PCIs that use DES (246
and 247) and non-DES (248 and 249) for
which there would be separate AMI
episode prices. Therefore, we do not
believe that the financial incentives
under the AMI model encourage the use
of any specific coronary stent because
the episode prices take into
consideration the IPPS payment for the
specific MS–DRG that applies to the
AMI model beneficiary. We do not
expect the AMI model to discourage the
appropriate use of DES.
Comment: Several commenters
pointed out that Arkansas and
Tennessee have bundled payment
programs that include CABG episodes,
and their efforts to implement bundled
payments include state Medicaid and
commercial health plans. The
commenters stated that in Arkansas, the
episode definition is consistent,
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specifically naming the duration,
responsible entity, and the included
services and conditions, across all
participating payers. If MSAs from
Arkansas or Tennessee are selected for
the AMI and CABG models, the
commenters recommended that CMS
should align the CABG episode
definition with that of the state
Medicaid plan. The commenters stated
that this approach to episode definition
would decrease the complexity and cost
to providers in those states and reduce
overlapping, independent efforts at care
redesign that both hospitals and cardiac
surgery groups would be simultaneously
undertaking, potentially independently.
The commenters added that this would
also allow CMS to experiment with
different episode definitions than those
under the BPCI initiative and CJR model
and proposed for the EPMs.
Response: We appreciate the
commenters drawing our attention to
the states that are currently engaged in
testing bundled payment models. We
are encouraged that several states have
identified clinical conditions that
overlap with those proposed in the
EPMs for testing bundled payment
models, specifically CABG and PCI in
the context of acute AMI (acute PCI).
The choice of these states to test
bundled payment models for some of
the same clinical conditions that are
included the EPMs provides additional
support for the opportunities under our
proposal of these models for Medicare
beneficiaries. Specifically, Arkansas and
Tennessee are testing CABG bundled
payment models which are similar to
the CMS CABG model, while Ohio and
Tennessee are testing acute PCI bundled
payment models that are similar to the
subset of beneficiaries in the CMS AMI
model discharged from PCI MS–DRGs
with an AMI ICD–CM diagnosis code on
the hospital claim. As displayed in
section III.B.5 of this final rule, MSAs in
Arkansas, Tennessee, and Ohio have
been selected for participation in the
CMS AMI and CABG models.
The state and CMS models for acute
PCI and CABG episodes have similar
design features. First, the responsible
entity for CABG episodes is the hospital
in Tennessee (the physician in
Arkansas) like the CMS model and for
acute PCI episodes in both states it is
the facility where the PCI is performed,
which would most commonly be the
hospital for an acute procedure as in the
CMS model where the hospital is
responsible. Second, both the state and
CMS models begin with the inpatient
hospitalization (or with performance of
the procedure), although the state model
episodes extend 30 days following
discharge, whereas the CMS model
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263
episodes extend 90 days. We note that
for CMS CABG episodes, 92 percent of
episode spending occurs during the
anchor hospitalization and the 30 days
post-discharge, while 84 percent of
acute PCI episode spending occurs
during that same period of time.60 Thus,
despite the differences in episode
duration between the state and CMS
models, the large majority of episode
spending occurs in the first 30 days
post-discharge so the state and CMS
models contain most of the same
episode spending. Third, the state and
CMS models include most services
furnished in the episode post-discharge
from the anchor hospitalization,
although the state models are not quite
as inclusive. Fourth, episode payments
are tied to quality measures in both the
state and CMS models. Finally, both the
state and CMS models included twosided risk and risk adjustment (or risk
stratification) based on payer-specific
factors.
Both the state and CMS CABG and
acute PCI models support the
implementation and testing of bundled
payment models for these costly
episodes that significantly impact the
health of individuals with cardiac
disease. While it is operationally
infeasible for CMS to apply the different
definitions used by state Medicaid
agencies in different states testing
episode payment in an EPM of the scope
of the CMS CABG and AMI models, the
state and CMS models that included
CABG and acute PCI are sufficiently
similar and clinical pathways around
CABG and acute PCI care reasonably
well-established such that we believe
coordination among the various
providers, including hospitals and
physicians, caring for all beneficiaries in
CABG and acute PCI episodes,
regardless of payer, should not pose a
significant burden on the providers
involved. Although the CMS CABG
model places the responsibility for the
episode upon the hospital, like the
Tennessee CABG model, the financial
arrangements that are permissible for
individuals and entities that collaborate
with the hospital toward the goal of
improved quality and efficiency of
CABG episode care as discussed in
section III.I. of this final rule provide
participant hospitals with substantial
opportunity to share upside and
downside risk with their collaborators,
including physicians that might be
leading CABG bundled payment efforts
60 Episodes for AMI and CABG beneficiaries
initiated by all U.S. IPPS hospitals not in Maryland
and constructed using standardized Medicare FFS
Parts A and B claims, as proposed in the proposed
rule, that began in CY 2012–2014.
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in Arkansas. The financial arrangement
policies under the CMS CABG model
should help to minimize the occurrence
of independent, potentially overlapping
efforts of hospitals and physician groups
to redesign care for CABG patients
covered by different insurers. We
believe that the state and CMS bundled
payment models for overlapping clinical
conditions are complementary efforts
that will provide substantial new
information about the effects of bundled
payments on the quality and cost of care
for CABG and acute PCI. While we
understand that implementation of the
EPMs will result in testing CABG and
acute PCI episodes with minor
differences in design for beneficiaries of
Medicare versus Medicaid and other
commercial payers in MSAs selected for
the AMI and CABG models in Arkansas,
Tennessee, and Ohio, these differences
are unlikely to affect the episode care
redesign strategies of the responsible
hospitals under the CMS and state
models.
Comment: While a number of
commenters supported the proposal to
update the EPM excluded services
through the proposed sub-regulatory
process to provide for flexibility and
timeliness in adding exclusions to EPM
episodes, several commenters opposed
CMS’ proposal to make changes to EPM
episode exclusions through an annual,
at a minimum, update outside of
rulemaking. The commenters
encouraged CMS to use notice and
comment rulemaking to evaluate and
exclude additional services from EPM
episodes. The commenters stated that
because participation in the EPMs is
required in selected geographic areas
and, therefore, the EPMs affect a large
number of hospitals and providers, it is
important that CMS implement the
process to update services to be
excluded from these episodes through
notice and comment rulemaking, so that
provider feedback throughout the course
of EPM implementation is reflected in
CMS’ decisions. They added that
hospitals of different sizes, geographic
locations, organizational capabilities,
and socio-economic factors all have
unique preferences, and their ideas and
opinions should be accounted for when
CMS makes changes to the list of
conditions and services to be included
and/or excluded from the episodes.
Many commenters recommended
CMS to continue to evaluate the list of
services to be excluded from EPM
episodes. They encouraged CMS to
consider excluding a variety of
additional services, including hospital
readmissions planned for the
beneficiary prior to the anchor
hospitalization for consistency with
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other CMS policies such as the
treatment of planned readmissions
under the HRRP; ongoing care for
beneficiaries’ chronic conditions for
which management is outside the scope
of the EPMs and their exclusion could
confound the EPM test of optimizing
quality and costs for certain episodes;
and post-acute care following excluded
readmissions where little is known
about the causal relationship between
the hospital readmission and
subsequent post-acute care services.
Response: We appreciate the interest
of the commenters in ensuring that
future changes to the EPM episode
definitions involve a transparent
process with opportunity for broad
stakeholder input. We have some
experience with a similar sub-regulatory
update process for the CJR model for
both the list of excluded services and
the fracture ICD–10–CM diagnosis codes
that are used to identify episodes for
fracture risk-stratification. We used this
process after publication of the CJR
Final Rule and again more recently to
update the CJR model exclusion list for
changes to the FY 2017 IPPS MS–DRGs
and ICD–10–CM diagnosis codes. We
have received significant public input
through those processes, which has
allowed us to consider and incorporate,
as appropriate based on the regulatory
review standards for the processes,
stakeholder input and in turn
communicate timely final updates to the
exclusions and fracture lists to CJR
participant hospitals. We have not heard
any concerns about the sub-regulatory
update processes as we have applied
them during CJR model implementation.
As we concluded for the CJR model,
we continue to believe that updating the
exclusions annually, at a minimum, is
most appropriate for the 5-year EPMs,
and allowing more frequent updates
than through rulemaking as necessary to
accommodate timely ICD–10–CM
annual coding changes and annual IPPS
MS–DRG changes, as well as to address
significant issues raised by EPM
participants and other stakeholders or
by CMS as we continue to evaluate the
list of excluded services for the EPM
episodes. We will explore the additional
areas recommended by the commenters
and others that may arise during EPM
implementation, and we will utilize the
exclusion list update process to suggest
any future changes based on our
additional analyses.
The commenters who supported an
exclusion list update process outside of
rulemaking did not suggest specific
revisions to the proposed standards for
updating the EPM episode exclusions,
namely:
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• We would not exclude the
following items or services that are:
++ Directly related to the EPM
episode or the quality or safety of the
EPM episode care.
++ For chronic conditions that may
be affected by the EPM episode care.
• We would exclude the following
items and services that are:
++ For chronic conditions not
generally affected by the EPM episode
care.
++ For acute clinical conditions, not
arising from existing EPM episoderelated chronic clinical conditions or
complications of EPM episode care.
Thus, we continue to believe these
standards provide the appropriate
clinical review framework for updates to
the EPM exclusion list. Finally, we
believe that our proposed process to
post the potential revised exclusions,
which could include additions to or
deletions from the exclusion list, to the
CMS Web site to allow for public input
on our planned application of these
standards, and then adopt changes to
the exclusion list with posting to the
CMS Web site of the final revised
exclusion list after our consideration of
the public input is consistent with the
recommendation of commenters that we
use a transparent process reflective of
broad opportunity for public input,
including implementation experience
with the EPMs. Conducting this update
process outside of rulemaking based on
the standards set forth in this final rule
allows us the greatest flexibility to
update the exclusions as changes to the
MS–DRGs and ICD–10–CM diagnosis
codes, upon which our exclusions rely,
are released. This process also allows us
to respond quickly to any episode
definition issues that arise during
implementation of the EPMs across the
broad array of EPM participants in the
selected MSAs, as well as consider any
new analysis conducted by CMS or
stakeholders about the relationship
among items and services to the EPM
episodes that might result in a different
assessment of the inclusion or exclusion
of existing MS–DRGs or ICD–10–CM
diagnosis codes in the definition of EPM
episodes. We would widely publicize
the opportunity for review and public
input through the CMS Web site and
listservs. We also note that any changes
to our overall approach to identifying
excluded items and services or to our
standards for evaluating items and
services for exclusion would be address
through future rulemaking. Therefore,
we are finalizing our proposal to update
the exclusion list annually, at a
minimum, using the standards and
process as described.
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Final Decision: After consideration of
the public comments received, we are
finalizing the proposals in § 512.210(a),
without modification, to identify related
items and services for EPM episodes as
the following items and services paid
under Medicare Part A and Part B, after
the EPM-specific exclusions are applied:
• Physicians’ services.
• Inpatient hospital services.
• IPF services.
• LTCH services.
• IRF services.
• SNF services.
• HHA services.
• Hospital outpatient services.
• Independent outpatient therapy
services.
• Clinical laboratory services.
• Durable medical equipment.
• Part B drugs.
• Hospice.
We are also finalizing the proposals,
without modification, to use the
following standards to exclude items
and services from EPM episodes:
• Hospital readmissions for MS–
DRGs that group to the following
categories of diagnoses: Oncology;
trauma medical admissions; surgery for
chronic conditions unrelated to a
condition likely to have been affected by
care furnished during the EPM episode;
and surgery for acute conditions
unrelated to a condition resulting from
or likely to have been affected by care
during the EPM episode.
• Part B items and services for acute
disease diagnoses unrelated to a
condition resulting from or likely to
have been affected by care during the
EPM episode, and certain chronic
disease diagnoses, as specified by CMS
on a diagnosis-by-diagnosis basis,
depending on whether the condition
was likely to have been affected by care
during the EPM episode or whether
substantial services were likely to be
provided for the chronic condition
during the EPM episode.
• Drugs that are paid outside of the
MS–DRGs included in the EPM episode
definitions, specifically hemophilia
clotting factors.
• IPPS new technology add-on
payments for drugs, technologies, and
services.
• OPPS transitional pass-through
payments for medical devices.
We are finalizing the proposals in
§ 512.210(b) to exclude from EPM
episodes specific readmissions, Part Bcovered items and services with specific
ICD–9–CM or ICD–10–CM diagnosis
codes in the principal position on
claims for items and services during the
90 days post-discharge from the anchor
hospitalization, and additionally Part-B
covered DME with specific ICD–9–CM
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or ICD–10–CM diagnosis codes in the
principal position on claims during the
anchor hospitalization, with
modification to place MS–DRGs 326–
328 on the AMI MS–DRG-anchored AMI
exclusion list and MS–DRGs 266–267
on the AMI MS–DRG-anchored AMI
exclusion list and the CABG exclusion
list. As discussed in section III.C.4.a.(5)
of this final rule, we are not finalizing
our proposed AMI model inpatient-toinpatient transfer episode initiation and
attribution policy so we will not use the
terms chained anchor hospitalization
and price MS–DRG in the final AMI
episode definition and pricing policies.
Therefore, the applicable EPM exclusion
list is applied to the EPM episode on the
basis of the MS–DRG that anchors the
EPM episode. The final EPM exclusion
lists based on ICD–9–CM and ICD–10–
CM diagnosis codes and MS–DRGs as of
FY 2016 are posted on the CMS Web
site at https://innovation.cms.gov/
initiatives/epm.
Lastly, we are finalizing our proposals
in § 512.210(c) to update the exclusion
lists by sub-regulatory guidance on an
annual basis, at a minimum, to reflect
annual changes to ICD–10–CM coding
and annual changes to the MS–DRGs
under the IPPS, as well as to address
any other issues that are brought to our
attention throughout the course of the
EPMs, without modification. The
standards for this updating process are:
• Include any items or services that
are directly related to the EPM episode
diagnosis or procedure (for example, a
subsequent admission for heart failure
or repeat revascularization) or the
quality or safety of care (for example,
sternal wound infection following
CABG);
• Include items or services for
chronic conditions that may be affected
by the EPM diagnosis or procedure and
the post-discharge care (for example,
diabetes);
• Exclude items and services for
chronic conditions that are generally not
affected by the EPM diagnosis or
procedure and the post-discharge care
(for example, prostate removal for
cancer); and
• Exclude items and services for
acute clinical conditions not arising
from existing EPM episode-related
chronic clinical conditions or
complications from the EPM episode
(for example, appendectomy).
The potential revised exclusions,
which could include additions to or
deletions from the exclusion lists, will
be posted to the CMS Web site to allow
for public input. After receiving and
reviewing public input on potential
revised exclusions, we will post the
final revised exclusion lists, including
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265
providing information to the public
about when the revisions would take
effect and to which episodes they would
apply.
With the publication of this final rule,
we are initiating the sub-regulatory
update process to incorporate changes
to the MS–DRGs and ICD–10–CM
diagnosis codes for 2017 into the EPMs
by posting potential changes to the
exclusion lists for the EPMs. We did not
consider the 2017 changes in the EPM
proposed rule, because the final MS–
DRGs and ICD–10–CM codes were not
yet available when the proposed rule
was published in the Federal Register
on August 2, 2016. There are no MS–
DRG changes for FY 2017 that resulted
in our suggesting potential changes to
the exclusion lists for the EPMs. We are
suggesting potential modifications to the
principal ICD–10–CM diagnosis code
categories for excluded Part B services
in the AMI, CABG, and SHFFT models
as of July 1, 2017, based on new ICD–
10–CM diagnosis code categories for FY
2017 and clinical review of existing
ICD–10–CM diagnosis code categories to
which new ICD–10–CM diagnosis codes
have been added for FY 2017. The
potential modifications to the exclusion
list for each EPM are posted on the CMS
Web site at https://innovation.cms.gov/
initiatives/epm. We request that public
input on the potential modifications be
sent to epm@cms.hhs.gov by 11:59 p.m.
on Friday, January 27, 2017. After
receiving and reviewing public input on
potential revised exclusions, we will
post the final revised exclusions by
February 24, 2017, including providing
information to the public about when
the revisions will take effect and to
which episodes they would apply.
4. EPM Episodes
a. Beneficiary Care Inclusion Criteria
and Beginning of EPM Episodes
(1) General Beneficiary Care Inclusion
Criteria
Because of the clinical variability
leading up to these EPM episodes and
the challenge of identifying unrelated
services given the multiple chronic
conditions experienced by many EPM
beneficiaries, we proposed to follow the
CJR model precedent and not begin an
EPM episode prior to the anchor
hospitalization (80 FR 73315 and
73318). We proposed that all services
that were already included in the IPPS
payment based on established Medicare
policies (for example, 3-day payment
window payment policies) would be
included in these EPM episodes, and
that the defined population of Medicare
beneficiaries whose care would be
included in the EPMs would meet all of
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the following criteria on admission to
the anchor or chained anchor
hospitalization:
• Enrolled in Medicare Part A and
Part B.
• Eligible for Medicare not on the
basis of end-stage renal disease.
• Not enrolled in any managed care
plan (for example, Medicare Advantage,
Health Care Prepayment Plans, costbased health maintenance
organizations).
• Not covered under a United Mine
Workers of America health plan, which
provides health care benefits for retired
mine workers.
• Have Medicare as their primary
payer.
• Not aligned to an ACO in the Next
Generation ACO model or an ACO in a
track of the Comprehensive ESRD Care
Initiative incorporating downside risk
for financial losses.
• Not under the care of an attending
or operating physician, as designated on
the inpatient hospital claim, who is a
member of a physician group practice
that initiates BPCI Model 2 episodes at
the EPM participant for the MS–DRG
that would be the anchor MS–DRG
under the EPM.
• Not already in any BPCI model
episode.
• Not already in an AMI, SHFFT,
CABG or CJR model episode with an
episode definition that does not exclude
the MS–DRG that would be the anchor
MS–DRG under the applicable EPM.
For a discussion of our proposal to
exclude certain ACO-assigned
beneficiaries from EPM episodes, we
refer to section III.D.6.c.(3) of the
proposed rule (81 FR 50869 through
50870). For a discussion of our
proposals for addressing potential
overlap of beneficiaries in episode
payment models that are relevant to
these last two criteria, we refer to
sections III.D.6.c.(1) and (2) of the
proposed rule (81 FR 50868 through
50869).
The proposal for beneficiary care
inclusion policies was included in
proposed § 512.230. We sought
comment on our proposal of beneficiary
care inclusion policies.
The following is a summary of the
comments received and our responses.
We refer to sections III.D.6.c.(1) through
(3) of this final rule for a summary of the
comments received and our responses
on the proposed three general
beneficiary care inclusion criteria that
relate to beneficiaries in other CMS
models and programs.
Comment: Many commenters
expressed support for the proposed
general beneficiary care inclusion
criteria as reasonable and consistent
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with other models and programs. On the
other hand, a number of commenters
requested that CMS exclude
beneficiaries with certain clinical
characteristics from all three proposed
EPMs, including beneficiaries receiving
hospice care before or during the
episode; experiencing an inpatient
psychiatric hospitalization preceding or
during an episode; having preexisting
functional disabilities in activities of
daily living; bearing a diagnosis of
dementia; residing in a SNF; and
experiencing illnesses for which it is
expected that the beneficiary would be
likely to die within the upcoming year.
The commenters generally stated that
these beneficiaries should be excluded
due to high and variable needs for care
that would not be typical for
beneficiaries in EPM episodes. One
commenter recommended CMS to adopt
an ‘‘out clause’’ for the most complex
patients to be exempt from the EPMs,
such as beneficiaries with multi-organ
system involvement or comorbidities or
poly-chronic illnesses. The commenters
were concerned that without accurate
risk adjustment under the EPMs,
hospitals disproportionately caring for
these beneficiaries would experience
undue financial risk for necessary
episode care. The commenters
recommended that if CMS did not
exclude high-risk beneficiaries, CMS
must adopt more robust risk adjustment
to account for socioeconomic, clinical,
or other risk factors that are out of the
hospital’s control and impact patients’
health and recovery. Several
commenters recommended that at least
the initial implementation of the EPMs
should exclude vulnerable populations
with complicated or intensive care
needs from the EPMs until the EPMs
demonstrate sufficient quality outcomes
and have developed accurate risk
adjustments and patient safeguards to
ensure high-quality care for populations
that the commenters believe could face
serious care disadvantages in the EPMs
and put hospitals at an unacceptable
level of financial risk.
Response: Most beneficiaries with
anchor hospitalizations that would
initiate EPM episodes would have
underlying conditions that may affect
care throughout the episode or that may
be influenced by the surgery or AMI that
initiates the episode. Similar to our
rationale in the CJR Final Rule regarding
LEJR episodes (80 FR 73371), we believe
it is important to include these
beneficiaries in the EPMs so that they
can benefit from the increased
opportunities for care coordination and
management throughout the episodes,
and including the broadest feasible
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array of Medicare beneficiaries in the
EPMs provides EPM participants with
the greatest volume of episodes and
incentive to redesign episode care. We
do not believe it would be appropriate
to exclude beneficiaries from the EPMs
just because they are potentially
expected to have high-cost, variable
health care needs under the EPMs. We
refer to section III.D.4.b.(2) of this final
rule for a discussion of risk adjustment
for the EPMs. Therefore, we will not
exclude additional beneficiaries with
certain clinical characteristics from the
EPMs beyond those general beneficiary
care inclusion criteria that we proposed.
Comment: Several commenters
requested that CMS exclude
beneficiaries with a home address not in
the service area of the treating hospital.
The commenters believe that including
beneficiaries in this scenario would
result in an unfair financial and
administrative burden for EPM
participants relative to other EPM
beneficiaries residing in the service area
of the hospital in meeting the challenges
of remote post-discharge care
coordination and ensuring ultimate
quality outcomes for medically complex
out-of state-patients.
Response: We acknowledge that in
occasional circumstances, EPM
participants may have limited ability to
coordinate care. For similar reasons as
our discussion in the CJR Final Rule (80
FR 73317 through 73318) regarding
LEJR episodes, following the care
coordination that takes place in the EPM
participant during the anchor
hospitalization, we expect that much of
the subsequent coordination of postacute care services and other related
services for EPM beneficiaries during
the 90 days post-discharge can be
accomplished through
telecommunications that do not require
the patient to remain within the
geographic proximity of the hospital
responsible for the EPM episode. In
addition, the design of the EPMs does
not preclude hospitals from
coordinating care with other providers
outside of their immediate service area,
which may be necessary especially in
the case of beneficiaries who are
admitted to a o-i or inpatient-toinpatient (i-i) transfer hospital after an
outpatient-to-inpatient or inpatient-toinpatient transfer, respectively, for a
different or higher level of cardiac care
that is not available at the local hospital
to which they originally presented with
symptoms of an AMI. As discussed in
section III.C.4.a.(5) of this final rule,
under our final AMI model policy we
are canceling all AMI episodes that
begin at an initial treating hospital
through an inpatient admission that
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initiates the AMI episode when the
beneficiary is transferred for admission
to an i-i transfer hospital after the AMI
episode begins. Thus, hospitals that are
AMI and CABG model participants and
that receive beneficiaries in transfer
either from outpatient or inpatient
status at an initial treating hospital will
commonly initiate and be responsible
for AMI or CABG episodes that begin at
the o-i/i-i transfer hospital. This
attribution of episodes to the o-i/i-i
transfer hospital increases the
probability that the home of
beneficiaries is not in the service area of
the responsible hospital under the AMI
or CABG model, yet most commenters
requested that we adopt this transfer
attribution policy. Therefore, we believe
that most EPM participants have the
tools to engage in effective remote care
coordination that results in high quality
episode care.
Finally, we note that we are finalizing
several waivers of Medicare program
rules, as discussed in section III.J. of this
final rule, to facilitate efficient and
effective episode care coordination for
beneficiaries in remote or distant
locations outside of the EPM
participant’s immediate community. We
are also finalizing policies for financial
arrangements in section III.I. of this final
rule that allow EPM participants to
share upside and downside financial
risk with a variety of individuals and
entities who collaborate with the EPM
participant in redesigning care and
caring for EPM beneficiaries, regardless
of the geographic proximity of these
individuals and entities to the EPM
participant. Through financial
arrangements, EPM participants could
align the financial incentives of
providers in the EPM beneficiary’s
home community with the goals of the
EPM participant to improve the quality
and reduce the cost of EPM episodes.
Therefore, we will not exclude
beneficiaries from the EPMs who are
referred to EPM participants that are not
close to the beneficiary’s home.
Comment: Several commenters
requested clarification about whether
patients who buy in to Medicare A or
B through the Medicaid program would
be excluded from the EPMs.
Response: As long as the beneficiaries
are enrolled in both Medicare Part A
and Part B, regardless of whether
enrollment occurs through Medicaid
program buy in, and assuming the
beneficiaries meet the other general
beneficiary care inclusion criteria, their
care would be included in the EPMs.
Comment: A commenter presented a
scenario where an EPM participant
admitted and successfully treated a
beneficiary with a SHFFT procedure,
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but the patient later falls and has a
subsequent hip fracture requiring
surgical fracture repair within the
post-acute period of the episode. The
commenter requested clarification about
whether this instance would trigger a
new SHFFT episode or the cost of the
readmission to repair the second
fracture would be included in the prior
SHFFT episode’s total cost.
Response: During such a readmission,
the beneficiary would already be in a
SHFFT episode. Therefore, the ongoing
SHFFT episode would not be canceled
and a new SHFFT episode would not be
initiated because the beneficiary would
not meet the proposed beneficiary care
inclusion criteria to initiate a SHFFT
episode since he or she is already in a
SHFFT episode. Because SHFFT MS–
DRGs 480–482 are not on the exclusion
list for SHFFT episodes, the related
readmission would be included in the
ongoing SHFFT episode and its cost
included in the calculation of actual
episode spending for the SHFFT
episode that began with the initial
hospitalization for a SHFFT procedure.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposals in § 512.230 for
the general beneficiary care inclusion
criteria, with modification to remove
references to chained anchor
hospitalization which we are not
including in the final EPM policies as
discussed in section III.C.4.a.(5) of this
final rule. We are additionally excluding
from EPM episodes beneficiaries who
are assigned to a Shared Savings
Program ACO in Track 3, as discussed
in section III.D.6.c.(3) of this final rule.
We define the population of Medicare
beneficiaries whose care is included in
the EPM as those who meet all of the
following criteria on admission to the
anchor hospitalization:
• Enrolled in Medicare Part A and
Part B.
• Eligible for Medicare not on the
basis of end-stage renal disease.
• Not enrolled in any managed care
plan (for example, Medicare Advantage,
Health Care Prepayment Plans, costbased health maintenance
organizations).
• Not covered under a United Mine
Workers of America health plan, which
provides health care benefits for retired
mine workers.
• Have Medicare as their primary
payer.
• Not prospectively assigned to:
++ An ACO in the Next Generation
ACO model;
++ An ACO in a track of the
Comprehensive ESRD Care Model
incorporating downside risk for
financial losses; or
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267
++ A Shared Savings Program ACO
in Track 3.
• Not under the care of an attending
or operating physician, as designated on
the inpatient hospital claim, who is a
member of a physician group practice
that initiates BPCI Model 2 episodes at
the EPM participant for the MS–DRG
that would be the anchor MS–DRG
under the EPM.
• Not already in any BPCI model
episode.
• Not already in an AMI, SHFFT,
CABG or CJR model episode with an
episode definition that does not exclude
the MS–DRG that would be the anchor
MS–DRG under the applicable EPM.
(2) Beginning AMI Episodes
We proposed that, as long as the
beneficiary met the general beneficiary
care inclusion criteria, then an AMI
episode would begin with admission of
a Medicare beneficiary to an IPPS
hospital for the following MS–DRGs,
where the specific MS–DRG would be
called the anchor MS–DRG for the
episode:
• AMI MS–DRGs—
++ 280 (Acute myocardial infarction,
discharged alive with MCC);
++ 281 (Acute myocardial infarction,
discharged alive with CC); and
++ 282 (Acute myocardial infarction,
discharged alive without CC/MCC).
• PCI MS–DRGs, when the claim
includes an AMI ICD–10–CM diagnosis
code in the principal or secondary
position on the IPPS claim as specified
in Table 3—
++ 246 (Percutaneous cardiovascular
procedures with drug-eluting stent with
MCC or 4+ vessels/stents);
++ 247 (Percutaneous cardiovascular
procedures with drug-eluting stent
without MCC);
++ 248 (Percutaneous cardiovascular
procedures with non-drug-eluting stent
with MCC or 4+ vessels/stents);
++ 249 (Percutaneous cardiovascular
procedures with non-drug-eluting stent
without MCC);
++ 250 (Percutaneous cardiovascular
procedures without coronary artery
stent with MCC); and
++ 251 (Percutaneous cardiovascular
procedures without coronary artery
stent without MCC).
Table 3 displays the ICD–9–CM codes
that we proposed to use to identify
historical AMI episodes for beneficiaries
discharged from PCI MS–DRGs, as well
as the ICD–10–CM diagnosis codes that
would be used to identify AMI episodes
for beneficiaries discharged from PCI
MS–DRGs throughout the duration of
the AMI model. The sub-regulatory
process for updating this AMI ICD–10–
CM diagnosis code list was described in
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section III.C.3.a.(1) of the proposed rule
(81 FR 50831).
We first identified the ICD–9–CM
diagnosis codes for the initial AMI
episode-of-care that were historically
used to report care for a newly
diagnosed AMI patient admitted to the
hospital. These codes all have a fifth
digit of ‘‘1’’ and were applicable until
the patient was discharged from acute
medical care, including for any transfers
to and from other acute care facilities
that occurred. These AMI ICD–9–CM
diagnosis codes would be used to
identify historical AMI episodes for
developing AMI model-episode
benchmark prices for anchor PCI MS–
DRGs. We proposed to cross-walk the
ICD–9–CM diagnosis codes for the
initial AMI episode-of-care to the ICD–
10–CM diagnosis codes that would be
reported for similar beneficiaries during
the AMI model performance years. The
crosswalk in Table 5 is consistent with
the crosswalk CMS posted for public
comment regarding ICD–9–CM to ICD–
10–CM diagnosis codes used for HIQR
Program measures, including AMI
quality measures.61
TABLE 5—PROPOSED ICD–9–CM AND ICD–10–CM AMI DIAGNOSIS CODES IN THE PRINCIPAL OR SECONDARY POSITION
ON THE IPPS CLAIM FOR PCI MS–DRGS (246–251) THAT INITIATE AMI EPISODES
ICD–9–CM
Diagnosis
code
ICD–9–CM
Description
ICD–10–CM
Diagnosis
code
410.01 .............
Acute myocardial infarction of anterolateral wall, initial episode of care.
121.09
122.0
410.11 .............
Acute myocardial infarction of other anterior wall, initial episode of care.
121.01
121.02
121.09
122.0
410.21 .............
Acute myocardial infarction of inferolateral wall, initial
episode of care.
121.10
122.1
410.31 .............
Acute myocardial infarction of inferoposterior wall, initial episode of care.
121.11
122.1
410.41 .............
Acute myocardial infarction of other inferior wall, initial episode of care.
121.19
122.1
410.51 .............
Acute myocardial infarction of other lateral wall, initial
episode of care.
121.29
122.8
410.61 .............
True posterior wall infarction, initial episode of care ..
121.29
122.8
410.71 .............
Subendocardial infarction, initial episode of care .......
121.4
122.2
410.81 .............
Acute myocardial infarction of other specified sites,
initial episode of care.
121.21
121.29
122.8
410.91 .............
Acute myocardial infarction of unspecified site, initial
episode of care.
121.3
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122.9
ICD–10–CM
Description
ST elevation (STEMI) myocardial infarction involving
other coronary artery of anterior wall.
Subsequent ST elevation (STEMI) myocardial infarction of anterior wall.
ST elevation (STEMI) myocardial infarction involving
left main coronary artery.
ST elevation (STEMI) myocardial infarction involving
left anterior descending coronary artery.
ST elevation (STEMI) myocardial infarction involving
other coronary artery of anterior wall.
Subsequent ST elevation (STEMI) myocardial infarction of anterior wall.
ST elevation (STEMI) myocardial infarction involving
other coronary artery of inferior wall.
Subsequent ST elevation (STEMI) myocardial infarction of inferior wall.
ST elevation (STEMI) myocardial infarction involving
right coronary artery.
Subsequent ST elevation (STEMI) myocardial infarction of inferior wall.
ST elevation (STEMI) myocardial infarction involving
other coronary artery of inferior wall.
Subsequent ST elevation (STEMI) myocardial infarction of inferior wall.
ST elevation (STEMI) myocardial infarction involving
other sites.
Subsequent ST elevation (STEMI) myocardial infarction of other sites.
ST elevation (STEMI) myocardial infarction involving
other sites.
Subsequent ST elevation (STEMI) myocardial infarction of other sites.
Non-ST elevation (NSTEMI) myocardial infarction.
Subsequent non-ST elevation (NSTEMI) myocardial
infarction.
ST elevation (STEMI) myocardial infarction involving
left circumflex coronary artery.
ST elevation (STEMI) myocardial infarction involving
other sites.
Subsequent ST elevation (STEMI) myocardial infarction of other sites.
ST elevation (STEMI) myocardial infarction of unspecified site.
Subsequent ST elevation (STEMI) myocardial infarction of unspecified site.
The proposal for beginning AMI
episodes was included in proposed
§ 512.240(a)(1). We sought comment on
our proposal to begin AMI episodes.
We address some of the comments
related to the proposed AMI ICD–CM
diagnosis codes displayed in Table 5 in
section III.C.3.a.(1) of this final rule in
the context of our discussion of the
61 https://www.cms.gov/Medicare/QualityInitiatives-Patient-Assessment-Instruments/
HospitalQualityInits/Downloads/HIQR-ICD9-toICD10-Tables.pdf.
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clinical conditions that define AMI
episodes. We received no comments
specific to the ICD–9–CM to ICD–10–
CM crosswalk of the AMI ICD–CM
diagnosis codes included in Table 5.
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The following is a summary of the
comments received on other issues
related to our proposal to begin AMI
episodes and our responses.
Comment: Several commenters stated
that uncomplicated acute AMI can be
treated and discharged the next day.
They pointed out that under Medicare’s
Two-Midnight rule, these beneficiaries
would be classified as outpatients. They
requested clarification about whether
CMS believes these beneficiaries with
AMI should be classified as inpatient
even if the expectation of the treating
physician is a less than Two-Midnight
hospital stay so the AMI model would
include all beneficiaries with AMI.
Response: The AMI model does not
change Medicare’s current payment
policy for classifying Medicare
beneficiaries as outpatients or
inpatients, including beneficiaries with
AMI. Therefore, AMI model participants
should continue to follow all existing
Medicare rules that apply to classifying
beneficiaries as inpatients or outpatients
for beneficiaries with AMI who could
potentially initiate AMI episodes if they
were admitted to the AMI model
participant.
To provide greater clarity to hospitals
and physician stakeholders, and to
address the higher frequency of
beneficiaries being treated as hospital
outpatients for extended periods of
time, CMS adopted the Two-Midnight
rule for admissions beginning on or after
October 1, 2013. This rule established
Medicare payment policy regarding the
benchmark criteria to use when
determining whether inpatient
admission is reasonable and necessary
for purposes of payment under
Medicare Part A.62 In general, the
original Two-Midnight rule stated that:
• Inpatient admissions would
generally be payable under Part A if the
admitting practitioner expected the
patient to require a hospital stay that
crossed two midnights and the medical
record supported that reasonable
expectation.
• Medicare Part A payment was
generally not appropriate for hospital
stays expected to last less than two
midnights. Cases involving a procedure
identified on the inpatient-only list or
that were identified as ‘‘rare and
unusual exception’’ to the TwoMidnight benchmark by CMS were
exceptions to this general rule and were
deemed to be appropriate for Medicare
Part A payment.
The Two-Midnight rule also specified
that all treatment decisions for
beneficiaries were based on the medical
62 Fact Sheet: Two-Midnight Rule; CMS; October
30, 2015.
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judgment of physicians and other
qualified practitioners. The TwoMidnight rule did not prevent the
physician from providing any service at
any hospital, regardless of the expected
duration of the service.
We acknowledge that full provider
implementation of hospital care in
accordance with the Two-Midnight rule
did not occur immediately on October 1,
2013 and that the first CMS’ contractor
reviews of short stay inpatient
admissions did not begin until October
2015. Therefore, we understand that
shifts in classifying certain beneficiaries
with uncomplicated AMI as outpatients
instead of inpatients could have
occurred during the period of historical
AMI episodes that would span January
1, 2013 and December 31, 2015 and
would be used for setting qualityadjusted target prices in performance
years 1 and 2 of the AMI model. Under
our monitoring and evaluation activities
as discussed in sections III.G.4. through
6. and section IV. of this final rule,
respectively, we will monitor the site-ofservice for treatment of beneficiaries
with AMI over the course of the model
to detect any issues related to access to
care, quality of care, or delayed care. We
will also evaluate the AMI model with
respect to changes in AMI case mix for
AMI model participants, and if we
observe them, we would conduct
analyses about the potential causes of
such changes, including whether AMI
model participants shifted to treating
some uncomplicated beneficiaries with
AMI as outpatients rather than
inpatients. We further note that when
we first update the data used for
historical EPM episode payments in
performance year 3 of the EPMs to be
calendar years 2015 through 2017, we
expect that any changes in care patterns
related to the Two-Midnight rule would
have been made by the beginning of that
3-year period.
Comment: One commenter agreed
with CMS that it is currently rare for a
beneficiary with AMI to have an
outpatient PCI and, therefore, almost all
beneficiaries with AMI who are treated
with PCI would be in the AMI model
under current hospital treatment
practices. However, the commenter
added that by excluding beneficiaries
who receive outpatient PCI from the
AMI model, EPM participants may
change their billing to outpatient PCI,
especially for more complex and costly
beneficiaries for which AMI episode
costs would be expected to be high. The
commenter recommended that CMS
should put all AMI patients on the
inpatient only list.
Response: We appreciate the concern
expressed by the commenter about the
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269
potential for the financial incentives in
the AMI model to lead to shifting in the
site-of-service for PCI for beneficiaries
with AMI from inpatient to outpatient.
We note that the OPPS inpatient only
list includes procedures that are only
paid under the IPPS and does not assign
certain diagnoses to inpatient only care.
PCI currently is commonly performed in
the outpatient hospital department for
beneficiaries that do not have AMI, and
we do not believe it would be
appropriate to place PCI procedures on
the inpatient only list due to concerns
about the shifting of the site-of-service
from inpatient to outpatient for AMI
model beneficiaries who require PCI. As
we stated in the proposed rule (81 FR
50829) patients experiencing an AMI are
almost uniformly admitted to the
hospital for further evaluation and
management based on clinical
guidelines for the treatment of
beneficiaries with AMI.63 We do not
believe that EPM participants would
change their patterns of treatment of
beneficiaries with AMI, especially for
those complex patients with significant
medical needs, in ways that would risk
beneficiaries not receiving the medically
necessary inpatient hospital evaluation
and management recommended for their
AMI treatment. We will be monitoring
patterns of care as discussed in sections
III.G.4. through 6. of this final rule for
evidence of clinically-unexplained
changes in care, including the site-ofservice for AMI beneficiaries who
receive PCI, especially if we believe
there is the potential to compromise
beneficiary access to care or quality of
care or to delay care.
Comment: A commenter requested
that CMS further clarify how an EPM
participant can determine whether
beneficiaries with AMI who have a
CABG would be attributed to the AMI
or CABG model.
Response: We appreciate the
opportunity to provide clarification on
the specific episode attribution of
beneficiaries with AMI who have a
CABG. We refer to section III.D.4.a.(5) of
this final rule for further discussion of
the final transfer attribution policy for
AMI episodes that involve an inpatientto-inpatient transfer for AMI care. AMI
and CABG episodes are initiated based
on the MS–DRG that is assigned to the
final discharge that occurs during the
anchor hospitalization. Thus, if a
beneficiary hospitalized for treatment of
AMI has a CABG during that anchor
hospitalization, we expect that the
63 Amsterdam et al. 2014 AHA/ACC Guideline for
the Management of Patients with Non-ST—
Elevation Acute Coronary Syndromes. Circulation.
2014; 130:e344–e426.
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beneficiary would be discharged from a
CABG MS–DRG (231–236) and,
therefore, would initiate a CABG
episode. We refer to section III.D.4.b.(b)
of this final rule for the pricing
adjustment that would apply to CABG
episodes for beneficiaries who have a
CABG during the initial hospitalization
for AMI treatment. However, if a
beneficiary with an AMI hospitalized
for initial treatment is discharged from
the anchor hospitalization and then
readmitted for CABG during the 90 day
post-discharge episode duration, the
beneficiary would initiate an AMI
episode, which would not be canceled
due to the CABG readmission. We refer
to section III.D.4.b.(c) of this final rule
for the pricing adjustment that would
apply to AMI episodes with CABG
readmissions.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposals in
§ 512.240(a)(1), without modification, to
begin AMI episodes with admission of
a Medicare beneficiary to an IPPS
hospital for the following MS–DRGs,
where the specific MS–DRG is called
the anchor MS–DRG for the episode:
• AMI MS–DRGs—
++ 280 (Acute myocardial infarction,
discharged alive with MCC);
++ 281 (Acute myocardial infarction,
discharged alive with CC); and
++ 282 (Acute myocardial infarction,
discharged alive without CC/MCC).
• PCI MS–DRGs, when the claim
includes an AMI ICD–10–CM diagnosis
code in the principal or secondary
position on the IPPS claim as specified
in Table 6—
++ 246 (Percutaneous cardiovascular
procedures with drug-eluting stent with
MCC or 4+ vessels/stents);
++ 247 (Percutaneous cardiovascular
procedures with drug-eluting stent
without MCC);
++ 248 (Percutaneous cardiovascular
procedures with non-drug-eluting stent
with MCC or 4+ vessels/stents);
++ 249 (Percutaneous cardiovascular
procedures with non-drug-eluting stent
without MCC);
++ 250 (Percutaneous cardiovascular
procedures without coronary artery
stent with MCC); and
++ 251 (Percutaneous cardiovascular
procedures without coronary artery
stent without MCC).
TABLE 6—FINAL ICD–9–CM AND ICD–10–CM AMI DIAGNOSIS CODES IN THE PRINCIPAL OR SECONDARY POSITION ON
THE IPPS CLAIM FOR PCI MS–DRGS (246–251) THAT INITIATE AMI EPISODES
ICD–9–CM
Diagnosis
code
ICD–9–CM
Description
ICD–10–CM
Diagnosis
code
410.01 .............
Acute myocardial infarction of anterolateral wall, initial episode of care.
121.09
122.0
410.11 .............
Acute myocardial infarction of other anterior wall, initial episode of care.
121.01
121.02
121.09
122.0
410.21 .............
Acute myocardial infarction of inferolateral wall, initial
episode of care.
121.10
122.1
410.31 .............
Acute myocardial infarction of inferoposterior wall, initial episode of care.
121.11
122.1
410.41 .............
Acute myocardial infarction of other inferior wall, initial episode of care.
121.19
122.1
410.51 .............
Acute myocardial infarction of other lateral wall, initial
episode of care.
121.29
122.8
410.61 .............
True posterior wall infarction, initial episode of care ..
121.29
122.8
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410.71 .............
Subendocardial infarction, initial episode of care .......
121.4
122.2
410.81 .............
Acute myocardial infarction of other specified sites,
initial episode of care.
121.21
121.29
122.8
410.91 .............
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Acute myocardial infarction of unspecified site, initial
episode of care.
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121.3
Sfmt 4700
ICD–10–CM
Description
ST elevation (STEMI) myocardial infarction involving
other coronary artery of anterior wall.
Subsequent ST elevation (STEMI) myocardial infarction of anterior wall.
ST elevation (STEMI) myocardial infarction involving
left main coronary artery.
ST elevation (STEMI) myocardial infarction involving
left anterior descending coronary artery.
ST elevation (STEMI) myocardial infarction involving
other coronary artery of anterior wall.
Subsequent ST elevation (STEMI) myocardial infarction of anterior wall.
ST elevation (STEMI) myocardial infarction involving
other coronary artery of inferior wall.
Subsequent ST elevation (STEMI) myocardial infarction of inferior wall.
ST elevation (STEMI) myocardial infarction involving
right coronary artery.
Subsequent ST elevation (STEMI) myocardial infarction of inferior wall.
ST elevation (STEMI) myocardial infarction involving
other coronary artery of inferior wall.
Subsequent ST elevation (STEMI) myocardial infarction of inferior wall.
ST elevation (STEMI) myocardial infarction involving
other sites.
Subsequent ST elevation (STEMI) myocardial infarction of other sites.
ST elevation (STEMI) myocardial infarction involving
other sites.
Subsequent ST elevation (STEMI) myocardial infarction of other sites.
Non-ST elevation (NSTEMI) myocardial infarction.
Subsequent non-ST elevation (NSTEMI) myocardial
infarction.
ST elevation (STEMI) myocardial infarction involving
left circumflex coronary artery.
ST elevation (STEMI) myocardial infarction involving
other sites.
Subsequent ST elevation (STEMI) myocardial infarction of other sites.
ST elevation (STEMI) myocardial infarction of unspecified site.
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TABLE 6—FINAL ICD–9–CM AND ICD–10–CM AMI DIAGNOSIS CODES IN THE PRINCIPAL OR SECONDARY POSITION ON
THE IPPS CLAIM FOR PCI MS–DRGS (246–251) THAT INITIATE AMI EPISODES—Continued
ICD–9–CM
Diagnosis
code
ICD–10–CM
Diagnosis
code
ICD–9–CM
Description
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122.9
(3) Beginning CABG Episodes
We proposed that, as long as a
beneficiary met the general beneficiary
care inclusion criteria, a CABG episode
would begin with the admission of a
Medicare beneficiary to an IPPS hospital
for a CABG that is paid under the
following CABG MS–DRGs and the
specific MS–DRG would be called the
anchor MS–DRG for the episode:
• 231 (Coronary bypass with
percutaneous transluminal coronary
angioplasty (PTCA) with MCC).
• 232 (Coronary bypass with PTCA
without MCC).
• 233 (Coronary bypass with cardiac
catheterization with MCC).
• 234 (Coronary bypass with cardiac
catheterization without MCC).
• 235 (Coronary bypass without
cardiac catheterization with MCC).
• 236 (Coronary bypass without
cardiac catheterization without MCC).
The proposal for beginning CABG
episodes was included in proposed
§ 512.240(b)(1). We sought comment on
our proposal to begin CABG episodes.
The following is a summary of the
comments received and our responses.
Comment: One commenter
recommended that CMS begin elective
CABG prior to admission for the anchor
hospitalization, since all of the workup
prior to an elective CABG happens in
the weeks or months before the
hospitalization. The commenter claimed
that the patient workup can vary
considerably among providers, which
may result in unnecessary costs. As an
example, the commenter stated that a
patient could have every cardiac
diagnostic test prior to CABG when only
several may be necessary. To help
address unnecessary utilization prior to
elective CABG, the commenter
recommended that CMS begin the
episode for elective CABG prior to the
hospitalization for surgery.
The commenter further disagreed
with CMS’ proposal that elective and
urgent CABG would be included in one
EPM, because the beneficiaries behave
differently during the episode and with
respect to their risk profiles. The
commenter recommended that CMS
separate CABG under these two
circumstances into separate EPMs and
test both models.
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ICD–10–CM
Description
Subsequent ST elevation (STEMI) myocardial infarction of unspecified site.
Response: We appreciate the interest
expressed by the commenter in starting
CABG episodes prior to the hospital
admission, and we recognize that the
beneficiary’s care that ultimately leads
to the CABG, including the physicianpatient relationship and diagnostic
workup, can begin long before the
surgical procedure. However, for similar
reasons to our consideration of
analogous comments in the CJR Final
Rule (81 FR 73316 through 73317)
regarding LEJR episodes, beginning the
episode too far in advance of the CABG
would make it difficult to avoid
bundling unrelated items and services,
and starting the episode prior to the
hospital admission is more likely to
encompass costs that vary widely
among beneficiaries with CAD that are
potential candidates for CABG, which
would make the episode more difficult
to price appropriately. We continue to
believe that beginning the CABG
episode with the anchor hospitalization
is most appropriate due to the clinical
variability leading up to the CABG and
the challenge of distinguishing between
related and unrelated services. We also
believe that beginning the episode with
the anchor hospitalization, and not prior
to admission, would be easier to
administer and provide more consistent
episodes for testing the CABG model.
Furthermore, we agree with the
commenter that beneficiaries
experiencing elective versus urgent
CABG behave differently during the
episode due to their different health
care needs. However, rather than
creating two EPMs for these
beneficiaries for whom we believe the
same CABG episode definition would
apply, we are providing a pricing
adjustment as discussed in section
III.D.4.b.(2)(b) of this final rule for
CABG model beneficiaries with an AMI
diagnosis code on the claim for the
anchor hospitalization who have
substantially higher historical episode
spending than CABG model
beneficiaries without AMI. The two
groups correspond to the urgent versus
elective groups recommended by the
commenter. We believe this pricing
adjustment policy accomplishes the
major objective of the commenter who
recommended two CABG EPMs so that
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we price CABG episodes for the two
groups of CABG model beneficiaries
differently based on their different
patterns of health care utilization.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposals in
§ 512.240(b)(1), without modification, to
begin CABG episodes with the
admission of a Medicare beneficiary to
an IPPS hospital for a CABG that is paid
under the following CABG MS–DRGs
and the specific MS–DRG is called the
anchor MS–DRG for the episode:
• 231 (Coronary bypass with
percutaneous transluminal coronary
angioplasty (PTCA) with MCC).
• 232 (Coronary bypass with PTCA
without MCC).
• 233 (Coronary bypass with cardiac
catheterization with MCC).
• 234 (Coronary bypass with cardiac
catheterization without MCC).
• 235 (Coronary bypass without
cardiac catheterization with MCC).
• 236 (Coronary bypass without
cardiac catheterization without MCC).
(4) Beginning SHFFT Episodes
We proposed that as long as a
beneficiary met the general inclusion
criteria, a SHFFT episode would begin
with the admission of a Medicare
beneficiary to an IPPS hospital for
surgical treatment of hip or femur
fracture (other than joint replacement)
that is paid under the following SHFFT
MS–DRGs and where the specific MS–
DRG would be called the anchor MS–
DRG for the episode:
• 480 (Hip and femur procedures
except major joint with MCC).
• 481 (Hip and femur procedures
except major joint with complication or
comorbidity (CC).
• 482 (Hip and femur procedures
except major joint without CC or MCC).
The proposal for beginning SHFFT
episodes was included in proposed
§ 512.240(c)(1). We sought comment on
our proposal to begin SHFFT episodes.
We received no comments specific to
our proposal to begin SHFFT episodes.
Final Decision: We are finalizing the
proposals in § 512.240(c)(1), without
modification, to begin SHFFT episodes
with the admission of a Medicare
beneficiary to an IPPS hospital for
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surgical treatment of hip or femur
fracture (other than joint replacement)
that is paid under the following SHFFT
MS–DRGs and where the specific MS–
DRG is called the anchor MS–DRG for
the episode:
• 480 (Hip and femur procedures
except major joint with MCC).
• 481 (Hip and femur procedures
except major joint with complication or
comorbidity (CC).
• 482 (Hip and femur procedures
except major joint without CC or MCC).
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(5) Special Policies for Hospital
Transfers of Beneficiaries With AMI
The asymmetric distribution of
cardiac care across hospitals makes
transfer, either from an inpatient
admission or from the emergency
department (without inpatient
admission) of one hospital to another, a
common consideration in the treatment
course for beneficiaries with an initial
diagnosis of AMI. Therefore, transfer for
cardiac care is an important
consideration for the AMI and CABG
models.
The availability of revascularization
and intensive cardiac care are
particularly important considerations in
the transfer of beneficiaries with an
AMI. A substantial portion of hospitals
do not have revascularization capability
(that is, a cardiac catheterization lab for
PCI or cardiothoracic surgeons who can
perform CABG) or cardiovascular
intensive care units (CVICU) and,
therefore, must transfer beneficiaries to
provide access to these services. In the
PCI and CABG examples, the discharge
from the transfer hospital that accepted
the beneficiary would result in
discharge under the MS–DRGs for PCI
(246–251) or CABG (231–236). For the
CVICU example, the transfer hospital’s
discharge MS–DRG would be AMI (280–
282). There is evidence of the
asymmetric distribution of cardiac care
in the 2014 IPPS and critical access
hospital claims data: While 4,332
hospitals submitted at least one claim
for an AMI MS–DRG, only 1,755 (41
percent) and 1,156 (27 percent) of these
hospitals filed at least one claim for PCI
or CABG MS–DRGs, respectively.64
The potential transfer scenarios are
best illustrated by the care pathways
experienced by beneficiaries with AMI.
These beneficiaries typically present to
a hospital’s emergency department
where the evaluation identifies the AMI
diagnosis and determines the initial
indicated treatments. Depending on the
64 AMI,
CABG and PCI MS–DRG inpatient claims
from all U.S. IPPS hospitals and CAHs derived from
the 2014 Geographic Variations Inpatient Claims
File located in the Chronic Conditions Warehouse.
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beneficiary’s clinical needs and the
hospital’s treatment capacity, the
beneficiary could be—
• Admitted to the initial treating
hospital, with no transfer to another
hospital during the initial
hospitalization for AMI. We refer to this
scenario as no transfer;
• Admitted to the initial treating
hospital and later transferred to a
transfer hospital. We refer to this
scenario as inpatient-to-inpatient
transfer and the transfer hospital as an
i-i transfer hospital; or
• Transferred from the initial treating
hospital to a transfer hospital without
admission to the initial treating
hospital. We refer to this scenario as
outpatient-to-inpatient transfer and the
transfer hospital as an o-i transfer
hospital.
Our proposals and alternatives
considered for these scenarios are
described in detail in this section. In our
proposals for AMI or CABG episodes for
initial AMI care, our overarching policy
was that every AMI or CABG episode
would begin at the first AMI or CABG
model participant to which the
beneficiary was admitted for an AMI
MS–DRG, PCI MS–DRG with an AMI
ICD–CM diagnosis code, or CABG MS–
DRG. The AMI or CABG model
participant where the episode began
would then be financially responsible
for the AMI or CABG episode unless the
episode was canceled.
Based on our analysis of Medicare
claims data, in the proposed rule (81 FR
50836) we presented the finding that
about 75 percent of historical AMI
episodes and CABG episodes for
beneficiaries with AMI began through
the emergency department of the
hospital where the anchor
hospitalization for the AMI or CABG
episode would occur. In another 18
percent of historical AMI episodes and
CABG episodes for beneficiaries with
AMI, the anchor hospitalization
occurred at a transfer hospital following
an emergency department visit at
another hospital without admission to
that hospital for an MS–DRG that would
initiate an AMI or CABG episode.65
In each of these scenarios, policies to
determine which episode type would
apply, the beginning of the episode, and
the specific hospital with financial
responsibility for the episode must be
determined (for example, AMI or CABG,
if CABG is provided as an initial
treatment in an outpatient-to-inpatient
or inpatient-to-inpatient scenario). In
65 Episode for beneficiaries with AMI initiated by
all U.S. IPPS hospitals and constructed using
standardized Medicare FFS Parts A and B claims,
as proposed in the proposed rule, that end in CY
2014.
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the proposed rule, we discussed each of
the scenarios in detail and provide a
summary of the scenarios in Table 7.
In the no transfer scenario, the
episode would begin upon admission to
an AMI or CABG model participant
under circumstances that meet the
criteria discussed in sections III.C.4.a.(1)
and (2) or (3) of the proposed rule (81
FR 50847 through 50848), and the AMI
or CABG episode that applied would be
determined by the specific MS–DRG for
the anchor hospitalization. Financial
responsibility for the episode would be
attributed to the sole treating hospital
involved in the initial AMI care. Under
this proposal, the treating hospital’s
quality measure performance would
determine the effective discount factor
to be applied to the AMI or CABG
model benchmark episode price for the
episode at reconciliation as described in
section III.D.4.b.(10) of the proposed
rule (81 FR 50861 through 50862).
The inpatient-to-inpatient transfer
scenario had several potential outcomes.
If the beneficiary initially presented for
AMI care to a hospital that was not an
AMI model participant and was
admitted and then transferred to an i-i
transfer hospital that was an AMI or
CABG model participant, the episode
would first initiate at the i-i transfer
hospital and, therefore, the i-i transfer
hospital would be financially
responsible for the AMI or CABG
episode. The i-i transfer hospital’s
quality measure performance would
determine the effective discount factor
to be applied to the AMI or CABG
model benchmark episode price for the
episode at reconciliation as described in
section III.D.4.b.(10) of the proposed
rule (81 FR 50861 through 50862).
If a beneficiary initially presented for
AMI care to an AMI model participant
and was admitted and then transferred
to an i-i transfer hospital (hereinafter a
chained anchor hospitalization) and the
i-i transfer hospital was not an AMI or
CABG model participant, the episode
would initiate at the initial treating
hospital and would only be canceled for
beneficiaries discharged from the i-i
transfer hospital under MS–DRGs that
were not anchor MS–DRGs for AMI or
CABG episodes as discussed in section
III.C.4.b. of the proposed rule (81 FR
50841 through 50842). The initial
treating hospital’s quality measure
performance would determine the
effective discount factor to be applied to
the AMI or CABG model benchmark
episode price for the episode at
reconciliation as described in section
III.D.4.b.(10) of the proposed rule (81 FR
50861 through 50862). We also refer to
section III.D.4.b.(2)(a) of the proposed
rule (81 FR 50849 through 50851) for
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further discussion of our proposal for
price MS–DRGs that could differ from
the anchor MS–DRG in AMI episodes
that included a chained anchor
hospitalization, in order to provide
pricing adjustments for episodes where
the initial treating hospital was
responsible for the AMI episode.
Inpatient-to-inpatient transfers
between AMI and CABG model
participant hospitals were further
considered in this section and
specifically included beneficiaries
experiencing an AMI who were
transferred for revascularization (that is,
PCI or CABG) or a higher level of
medical AMI care. We noted that of all
beneficiaries experiencing an AMI in
historical episodes, about half received
no revascularization (PCI or CABG)
during the anchor hospitalization or the
90-day post-hospital discharge period,
about 40 percent received a PCI, and
less than 10 percent had CABG
surgery.66 Moreover, three-quarters of
CABG procedures and over 90 percent
of PCIs for beneficiaries experiencing an
AMI occurred at the hospital that first
admitted the beneficiary for an inpatient
hospitalization.67
However, given the asymmetric
distribution of cardiac care capacity, we
noted in the proposed rule (81 FR
50837) that there would be beneficiaries
who initiated an AMI episode by
admission to an initial treating hospital
but then required transfer to an i-i
transfer hospital for additional
treatment during the AMI episode,
resulting in a chained anchor
hospitalization. For historical AMI
episodes ending in CY 2014, only about
12 percent of beneficiaries who would
have initiated an AMI episode through
admission and assignment to an AMI
MS–DRG at the initial treating hospital
were transferred to an i-i transfer
hospital, with 30 percent and 20 percent
receiving PCI or CABG, respectively, at
the i-i transfer hospital. Another 20
percent were discharged from the i-i
transfer hospital in the chained anchor
hospitalization under an AMI MS–DRG.
The remaining 30 percent of
beneficiaries were discharged from the
i-i transfer hospital in the chained
anchor hospitalization under other MS–
DRGs that would not have initiated AMI
or CABG episodes, including cardiac
66 Episodes for beneficiaries with AMI initiated
by all U.S. IPPS hospitals and constructed using
standardized Medicare FFS Parts A and B claims,
as proposed in the proposed rule, that end in CY
2014.
67 Episodes for beneficiaries with AMI initiated
by all U.S. IPPS hospitals and constructed using
standardized Medicare FFS Parts A and B claims,
as proposed in the proposed rule, that end in CY
2014.
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valve surgery, septicemia, and renal
failure. From the perspective of hospital
capacity and transfer patterns, most
hospitals transferred less than 10
percent of beneficiaries initiating a
historical AMI episode under an AMI
MS–DRG at the first admitting hospital,
and only a handful of hospitals
transferred the majority of their patients
in this scenario.68 This small number of
hospitals that transferred the majority of
their patients included a range of urban
and rural hospitals with 50 to 250 beds.
The need to transfer a beneficiary in
an AMI episode during the anchor
hospitalization for appropriate care that
resulted in a chained anchor
hospitalization where the hospitals were
both AMI or CABG model participants
raised considerations about whether
attribution of the AMI episode should
be to the first treating hospital that
admitted the beneficiary or the i-i
transfer hospital, as well as
considerations about the specific model
(AMI or CABG) for attribution of the
episode in some circumstances. For
example, if the first treating hospital
initiated an AMI episode by admitting a
beneficiary and then transferred the
beneficiary to another hospital where
the beneficiary was treated and
ultimately discharged from acute care,
ending the chained anchor
hospitalization under a CABG MS–DRG,
then we needed to determine whether
the beneficiary would be included in
the AMI or CABG model, which
hospital would assume financial
responsibility for the beneficiary’s
episode, and under what circumstances,
if any, would the AMI episode be
canceled if a transfer occurred.
In considering the model episode that
would include the beneficiary’s care
and accountability for the beneficiary in
inpatient-to-inpatient transfer scenarios
between AMI and CABG model
participant hospitals that resulted in a
chained anchor hospitalization for AMI,
several factors were relevant, including
the timing of final discharge disposition
of the beneficiary, including to postacute care; the location of the post-acute
care; the identity and location of the
physician who was most responsible for
managing the beneficiary’s care after
discharge; and consistency with other
CMS transfer policies. We noted in the
proposed rule (81 FR 50837) that while
64 percent of CABG beneficiaries in
historical episodes received post-acute
care services following discharge from
the anchor hospitalization (most
68 Episodes for AMI beneficiaries initiated by all
U.S. IPPS hospitals and constructed using
standardized Medicare FFS Parts A and B claims,
as proposed in the proposed rule, that end in CY
2014.
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273
commonly home health services—43
percent received home health services
only and 13 percent a combination of
home health and SNF services), only 36
percent of historical AMI beneficiaries
received post-acute services.69 Of
further relevance for beneficiaries with
an AMI diagnosis was that significant
follow up care was usually performed
by cardiologists who managed the
patient’s underlying cardiovascular
disease, rather than the interventional
cardiologist or cardiothoracic surgeon
that performed the revascularization
procedure. PCI procedures, billed by
interventional cardiologists, have a 0day global period, reflecting that follow
up care is not typically furnished by
interventional cardiologists. We further
noted that patients in commercial
programs that require travel to regional
centers of excellence for CABG
generally only stay in the remote
location away from the patient’s home
for a week or so post-hospital discharge.
We expected that beneficiaries
hospitalized for treatment of AMI, even
if they were transferred to a
revascularization hospital resulting in a
chained anchor hospitalization, would
receive most follow up care in their
local communities, a view that was
supported by many commenters on the
CJR model proposed rule who believed
that many patients requiring post-acute
care prefer to return to their home
communities for that care following
hospital discharge (80 FR 23457).
Finally, consistency across other CMS
program policies when a beneficiary
with an AMI experienced an inpatientto-inpatient transfer was relevant to
developing policies for the AMI and
CABG models. Specifically, we noted
that the Hospital-Level, RiskStandardized Payment Associated with
a 30-Day Episode of Care for AMI (NQF
#2431) measure used in the hospital
value-based purchasing (HVBP) Program
attributes payments for transferred
beneficiaries to the hospital that
admitted the patient for the initial AMI
hospitalization.70
Based on these considerations, we
proposed that once an AMI episode was
initiated at an AMI model participant
hospital through an inpatient
hospitalization, the AMI episode would
continue under the financial
responsibility of that participant
hospital, regardless of whether the
69 Episodes for AMI and CABG beneficiaries
initiated by all U.S. IPPS hospitals and constructed
using standardized Medicare FFS Parts A and B
claims, as proposed in the proposed rule, that end
in CY 2014.
70 https://www.cms.gov/Medicare/QualityInitiatives-Patient-Assessment-Instruments/
HospitalQualityInits/Measure-Methodology.html.
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beneficiary was transferred to another
AMI or CABG model participant
hospital for further medical
management of AMI, or for a PCI or
CABG during a chained anchor
hospitalization. Under this proposal, the
initial treating hospital’s quality
measure performance would determine
the effective discount factor to be
applied to the AMI model benchmark
episode price for the episode at
reconciliation as described in section
III.D.4.b.(10) of the proposed rule (50861
through 50862) rule. Our proposal to
cancel AMI episodes for beneficiaries
discharged from the i-i transfer hospital
under MS–DRGs that were not anchor
MS–DRGs for AMI or CABG episodes
was discussed in section III.C.4.b. of the
proposed rule (81 FR 50841 through
50842). We also referred to section
III.D.4.b.(2)(a) of the proposed rule (81
FR 50849 through 50851) for further
discussion of the proposal for price MS–
DRGs that could differ from the anchor
MS–DRG in AMI episodes that included
a chained anchor hospitalization, in
order to provide pricing adjustments for
episodes where the initial treating
hospital was responsible for the AMI
episode.
In the proposed rule (81 FR 50838),
we noted that we did not propose to
cancel the AMI episode even if the
transfer and admission to the i-i transfer
hospital would otherwise initiate a
CABG episode at the i-i transfer
hospital. We believed that once the AMI
episode had been initiated, all related
care during the episode (including
hospital care for transfers and related
readmissions for CABG) should be fully
attributed to the AMI episode in the
manner described in this section for the
episode and that the first hospital that
initiated the AMI episode should be
financially responsible for the AMI
episode. Therefore, we did not propose
to cancel the AMI episode if a CABG
was performed during a chained anchor
hospitalization, nor did we propose that
a beneficiary could simultaneously be in
an AMI and CABG episode for
overlapping periods of time due to the
different MS–DRGs that applied during
the chained anchor hospitalization.
Instead, we would make an AMI
episode pricing adjustment for these
circumstances by paying the AMI model
participant based on a price MS–DRG
that was different from the anchor MS–
DRG to reflect Medicare payment for the
CABG as discussed in section
III.D.4.b.(2)(a) of the proposed rule (81
FR 50849 through 50851).
We considered several alternatives to
our proposal for AMI episode
attribution for inpatient-to-inpatient
transfer scenario where both hospitals
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are AMI or CABG model participants.
First, we considered canceling the AMI
episode initiated at the initial treating
hospital when a transfer occurs, and
basing any AMI or CABG episode
initiation on the MS–DRG for the final
i-i transfer hospital admission in the
chained anchor hospitalization as long
as that latter hospital was an AMI or
CABG model participant. This would
place financial responsibility for the
episode on the i-i transfer hospital if the
beneficiary went on to be discharged
from acute care at that hospital.
Attributing episodes under this
alternative policy would assign
beneficiaries to the final i-i transfer
hospital for the AMI or CABG episode
based on the model episode definitions
in sections III.C.4.a.(2) and (3) of the
proposed rule (81 FR 50834 through
50835). That is, if the beneficiary was
discharged from the final admission in
the chained anchor hospitalization
under an AMI MS–DRG or a PCI MS–
DRG, then the AMI episode initiated at
the initial treating hospital would be
canceled and the i-i transfer hospital
accepting the beneficiary on referral
would initiate an AMI episode.
Similarly, if the beneficiary was
discharged from the final admission in
the chained anchor hospitalization
under a CABG MS–DRG, then the AMI
episode initiated at the first hospital
would be canceled and the i-i transfer
hospital accepting the beneficiary on
referral would initiate a CABG episode.
Under this alternative, the i-i transfer
hospital’s quality measure performance
would determine the effective discount
factor to be applied to the AMI or CABG
model benchmark episode price for the
episode at reconciliation as described in
section III.D.4.b.(10) of the proposed
rule (81 FR 50861 through 50862).
However, we did not propose this
alternative because we believed that
post-acute care and care management
following hospital discharge would be
more likely to be effectively provided
near the beneficiary’s home community,
rather than near the i-i transfer hospital
accepting the beneficiary upon referral.
Second, we considered proposing an
episode hierarchy such that, during a
chained anchor hospitalization, the
most resource-intensive MS–DRG
during the whole chained anchor
hospitalization would determine the
model episode and the financially
responsible hospital for the episode. For
example, if we established CABG, PCI,
and AMI MS–DRGs in descending order
of inpatient hospital resource-intensity,
we would initiate a model episode
based on the most resource-intensive
MS–DRG during the chained anchor
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hospitalization and attribute the model
episode to the hospital discharging the
beneficiary under that MS–DRG. Under
this scenario, either the initial treating
or i-i transfer hospital’s quality measure
performance would determine the
effective discount factor to be applied to
the AMI or CABG model benchmark
episode price for the episode at
reconciliation as described in section
III.D.4.b.(10) of the proposed rule (81 FR
50861 through 50862), depending on the
specific hospital discharging the
beneficiary under the most resourceintensive MS–DRG during the chained
anchor hospitalization. However, we
did not propose this alternative because
we believed, like the first alternative we
considered, this could frequently lead to
episode responsibility being attributed
to the i-i transfer hospital when the
local hospital first caring for the
beneficiary with AMI may be better
positioned to coordinate care in the
beneficiary’s home community.
Thus, our proposal would have
placed responsibility for care during the
90-day post-hospital discharge period in
the AMI episode on the AMI model
participant hospital to which the
beneficiary initially presented for AMI
care and was admitted, rather than on
the i-i transfer hospital to which the
beneficiary was transferred after
initiating the AMI episode. Given the
broad episode definition of AMI
episodes, we believed that the postdischarge care required following
hospitalization that included CABG,
PCI, or medical management was best
coordinated and managed by the
hospital that originally admitted the
beneficiary for the AMI. Such postdischarge care could include follow up
for adherence to cardiac rehabilitation
referral and management of the
beneficiary’s underlying CAD and
comorbidities. Even in the case of the
more common surgical complications of
CABG, such as wound infection, the
beneficiary commonly would be
admitted to the local hospital for
treatment.
We further proposed that, as
discussed in section III.I.3. of the
proposed rule (81 FR 50918 through
50920), hospitals could be collaborators
in the AMI, CABG, and SHFFT models
in order to increase the financial
alignment of hospitals and other EPM
collaborators with EPM participants that
were financially responsible for EPM
episodes. Therefore, we expected that
community hospital participants in the
AMI model would be able to enter into
sharing arrangements with i-i transfer
hospitals accepting AMI model
beneficiaries on referral to allow sharing
of episode reconciliation payments or
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repayment responsibility with the i-i
transfer hospitals if those hospitals
played a significant role in care redesign
of AMI or CABG care pathways or
management of beneficiaries throughout
AMI or CABG episodes, including
during the 90 days post-hospital
discharge. We expected that community
hospitals would need to coordinate
closely with i-i transfer hospitals
accepting AMI model beneficiaries on
referral as the beneficiaries in AMI
episodes were discharged from those
hospitals, in order to improve the
quality and efficiency of AMI episodes.
This coordination could potentially be
enhanced if i-i transfer hospitals were
AMI model collaborators with financial
incentives that were aligned with those
of the AMI model participants through
sharing arrangements.
The proposal for AMI episode
attribution in circumstances that
involve inpatient-to-inpatient transfers
of beneficiaries with AMI was included
in proposed § 512.240(a)(2). We sought
comment on our proposal for AMI
episode attribution in circumstances
that involved inpatient-to-inpatient
transfers of beneficiaries with AMI,
including comment on the alternatives
considered.
In the outpatient-to-inpatient transfer
scenario where a beneficiary with AMI
was transferred from the emergency
department of the initial treating
hospital without admission to that
hospital as an inpatient to an o-i transfer
hospital for admission, we proposed
that the AMI or CABG episode would
begin at the o-i transfer hospital based
on the MS–DRG (and AMI ICD–CM
diagnosis code if a PCI MS–DRG
applies) that was assigned to that anchor
hospitalization. That is, if a beneficiary
received initial AMI care in a hospital
emergency department without
admission and was transferred to an
AMI or CABG model participant (the oi transfer hospital) for admission, then
the AMI or CABG episode would begin
in the first hospital involved in the
beneficiary’s AMI or CABG care that
admitted the beneficiary as an inpatient,
specifically the o-i transfer hospital.
Therefore, the o-i transfer hospital
would be financially responsible for the
AMI or CABG episode. This attribution
was in accordance with the AMI and
CABG model rules, as discussed in
sections III.C.4.a.(2) and (3) of the
proposed rule (81 FR 50834 through
50835), that initiated an AMI episode
with a hospitalization that results in
discharge from an AMI MS–DRG or PCI
MS–DRG with an AMI ICD–CM
diagnosis code in the principal or
secondary position from an AMI model
participant or a CABG episode with a
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hospitalization that resulted in
discharge from a CABG MS–DRG. Under
this proposal, the o-i transfer hospital’s
quality measure performance would
determine the effective discount factor
to be applied to the AMI or CABG
model benchmark episode price for the
episode at reconciliation as described in
section III.D.4.b.(10) of the proposed
rule (81 FR 50861 through 50862).
Under this proposal, regardless of
whether the initial treating hospital was
an AMI or CABG model participant, an
AMI or CABG episode would only be
initiated at the o-i transfer hospital if
that hospital was an AMI or CABG
model participant.
We considered an overarching
alternative policy that would begin
every AMI or CABG episode at the first
AMI or CABG model participant at
which either:
• The beneficiary presented to the
emergency department for initial AMI
care before being transferred to an o-i
transfer hospital; or
• The beneficiary was admitted for an
AMI MS–DRG, PCI MS–DRG with an
AMI ICD–CM diagnosis code, or a CABG
MS–DRG.
The AMI or CABG model participant
where the episode began would then be
financially responsible for the AMI or
CABG episode unless the episode was
canceled. Under this alternative, there
would no changes to our proposals for
attributing episodes with no transfers or
inpatient-to-inpatient transfers.
However, under this alternative, if the
beneficiary presented for initial AMI
care to the emergency department of an
AMI or CABG model participant, the
AMI or CABG episode would begin at
this initial treating hospital when a
beneficiary was transferred from the
emergency department for his or her
first inpatient hospitalization which
occurred at an o-i transfer hospital. This
would place financial responsibility for
the AMI or CABG episode on the initial
treating hospital despite the fact that the
beneficiary was transferred from that
hospital without being admitted, and
the initial treating hospital’s quality
measure performance would determine
the effective discount factor to be
applied to the AMI or CABG model
benchmark episode price for the episode
at reconciliation as described in section
III.D.4.b.(10) of the proposed rule (81 FR
50861 through 50862).
Identifying the emergency department
visit at the initial treating hospital
would require using Field (Form
Locator) 15—Point of Origin for
Admission or Visit code on the CMS
1450 IPPS claim from the o-i transfer
hospital to identify transfer from
another hospital and linking that claim
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275
to the hospital outpatient claims from
the initial treating hospital for the
emergency department visit and other
hospital outpatient services that
occurred within a certain period of time
prior to the o-i transfer hospital
admission and that were related to the
AMI care. The episode would be
assigned to the AMI model even if the
beneficiary received a CABG at the o-i
transfer hospital, and we would assign
financial responsibility for the AMI
episode to the initial treating hospital.
Under this alternative, the initial
treating hospital’s quality measure
performance would determine the
effective discount factor to be applied to
the AMI model benchmark episode
price for the episode at reconciliation as
described in section III.D.4.b.(10) of the
propose rule (81 FR 50861 through
50862). We would also need to identify
other types of related services to include
in the episode that would begin prior to
the o-i transfer hospital admission, such
as physicians’ services for care in the
emergency department.
This alternative would have had the
benefit of consistently including all care
in each AMI or CABG episode that
occurred following presentation of a
beneficiary with AMI to the emergency
department of an AMI or CABG model
participant to the AMI or CABG
episode, regardless of whether an AMI
or CABG episode involved no transfer,
o-i transfer, or i-i transfer. However,
because this alternative would have
begun the AMI episode prior to the
initial hospital admission, we would
have needed to establish additional
policies for identifying the beneficiaries
who initiated these episodes and
defined the timeframe and services that
would have been included in the AMI
or CABG episode prior to admission to
the o-i transfer hospital.
We did not propose this alternative
because we believed the policies
necessary to begin the AMI or CABG
episode at the first treating hospital
when an inpatient hospitalization did
not occur would be complex,
challenging to operationalize, and
required assumptions about the
relationship of care to the AMI based
solely on administrative claims data that
were insufficient to ensure we could
accurately identify related care. We
believed it remained problematic to
define the services to be included in
AMI or CABG episodes if those services
preceded an inpatient hospitalization
that would otherwise initiate the AMI or
CABG episode. For example, we would
need to define the timeframe for
beginning an AMI or CABG episode
with an emergency department visit for
AMI that resulted in a transfer to the o-
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i transfer hospital, as well as the Part A
and Part B services to be included in the
AMI or CABG episode that would result.
As we discussed in section III.C.4.a.(1)
of the proposed rule (81 FR 50834), we
did not propose to begin any EPM
episode prior to the anchor
hospitalization because of the clinical
variability leading up to all EPM
episodes and the challenge of
identifying unrelated services prior to
the inpatient hospitalization. Thus, we
did not propose to make an exception
for transfers from the emergency
department of the initial treating AMI or
CABG model participant hospital when
the beneficiary with AMI was not
admitted to that hospital.
We sought comment on the proposal
for AMI and CABG episode initiation
and attribution for the outpatient-toinpatient transfer scenario, as well as
the alternative considered that would
begin an episode upon presentation of a
beneficiary for initial AMI care to the
emergency department of an AMI or
CABG model participant when the care
resulted in an outpatient-to-inpatient
transfer.
Table 7 included in the proposed rule
(81 FR 50840) provided a summary of
episode initiation and attribution at the
beginning of AMI care for no transfer,
inpatient-to-inpatient transfer, and
outpatient-to-inpatient transfer
scenarios, including a description of
how these related to the participation in
the AMI or CABG models of hospitals
providing initial AMI care.
TABLE 7—PROPOSED INITIATION AND ATTRIBUTION OF AMI AND CABG EPISODES THAT INVOLVE NO TRANSFER, OR
OUTPATIENT-TO-INPATIENT OR INPATIENT-TO-INPATIENT TRANSFERS AT THE BEGINNING OF AMI CARE
Proposed episode initiation and attribution
No transfer (participant): Beneficiary admitted to an initial treating hospital that is a participant in the AMI or CABG model for an AMI MS–
DRG, PCI MS–DRG with AMI ICD–CM diagnosis code, or CABG
MS–DRG.
No transfer (nonparticipant): Beneficiary admitted to an initial treating
hospital that is not a participant in the AMI or CABG model for an
AMI MS–DRG, PCI MS–DRG with AMI ICD–CM diagnosis code, or
CABG MS–DRG.
Inpatient–to–inpatient transfer (nonparticipant to participant): Beneficiary admitted to an initial treating hospital that is not an AMI or
CABG model participant and later transferred to an i–i transfer hospital that is an AMI or CABG model participant for an AMI MS–DRG,
PCI MS–DRG with AMI ICD–CM diagnosis code, or CABG MS–DRG.
Inpatient–to–inpatient transfer (participant to participant or participant to
nonparticipant): Beneficiary admitted to an initial treating hospital that
is an AMI or CABG model participant for an AMI MS–DRG, PCI MS–
DRG with AMI ICD–CM diagnosis code, or CABG MS–DRG and
later transferred to an i–i transfer hospital for an AMI, PCI, or CABG
MS–DRG, regardless of whether the i–i transfer hospital is an AMI or
CABG model participant.
Outpatient–to–inpatient transfer (nonparticipant to participant or participant to participant): Beneficiary transferred without admission from
the initial treating hospital, regardless of whether the initial treating
hospital is an AMI or CABG model participant, to a o–i transfer hospital that is an AMI or CABG model participant and is discharged
from the o–i transfer hospital for an AMI MS–DRG, PCI MS–DRG
with AMI ICD–CM diagnosis code, or CABG MS–DRG.
Outpatient–to–inpatient transfer (participant to nonparticipant): Beneficiary transferred without admission from the initial treating hospital
that is an AMI or CABG participant to an o–i transfer hospital that is
not an AMI or CABG model participant.
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Scenario
Initiate AMI or CABG episode based on anchor hospitalization MS–
DRG.
Attribute episode to the initial treating hospital.
The following is a summary of the
comments received and our responses.
Comment: A number of commenters
expressed support for the proposed AMI
model transfer episode initiation and
attribution policy that would initiate an
AMI episode under the responsibility of
an initial treating hospital that is an
AMI model participant where the
beneficiary is assigned to an AMI MS–
DRG or PCI MS–DRG with AMI ICD–CM
diagnosis code and the beneficiary is
later transferred to another hospital and
ultimately discharged from an AMI, PCI,
or CABG MS–DRG. One commenter
further recommended that CMS
consider implementing this policy in
the BPCI initiative and future episode
payment models that are under
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No AMI or CABG episode is initiated.
Initiate AMI or CABG episode based on the MS–DRG at i–i transfer
hospital.
Attribute episode to the i–i transfer hospital.
Initiate AMI or CABG episode based on anchor hospitalization MS–
DRG at initial treating hospital. If the chained anchor hospitalization
results in a final AMI, PCI, or CABG MS–DRG, calculate episode
benchmark price based on the AMI, PCI or CABG MS–DRG with the
highest IPPS weight. If the final MS–DRG is not an AMI, PCI, or
CABG MS–DRG, cancel the episode. Attribute episode to the initial
treating hospital.
Initiate AMI or CABG episode based on anchor hospitalization MS–
DRG at o–i transfer hospital. Attribute episode to the o–i transfer
hospital.
No AMI or CABG episode is initiated.
development. Several commenters
stressed the importance of beneficiaries
receiving rehabilitation services in their
home communities to improve
adherence to the treatment plan, and
acknowledged that CMS’ AMI model
transfer attribution proposal would
encourage this care pattern. Another
commenter pointed out that CMS
should differentiate patient-directed
presentation with AMI at a hospital
emergency department versus
emergency medical services-directed
delivery to the hospital emergency
department. The commenter explained
that the usual practice in the case of
STEMI identified in the field by
emergency medical services would be to
transport the beneficiary to a hospital
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with appropriate capacity to avoid any
need for transfer that could delay
treatment and impair outcomes. The
commenter added that the trend
nationally for emergency medical
services delivery of patients with an
AMI is for the patient to be taken to a
facility that is capable of managing that
patient rather than taking them to the
closest hospital. Thus, the commenter
believes the transfer issues should be
only applicable to the minority of
beneficiaries who present to the
emergency department under their own
power.
Other commenters who supported the
proposed AMI model transfer episode
initiation and attribution policy,
including the proposal to cancel
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episodes that contain a chained anchor
hospitalization with a final discharge
MS–DRG that is not an AMI, PCI, or
CABG MS–DRG, however expressed
concern that the proposal for a price
MS–DRG payment adjustment does not
go far enough to provide a level playing
field for AMI episodes involving a
chained anchor hospitalization. One of
these commenters presented analysis
showing that while only a minority of
episodes involving a chained anchor
hospitalization resulted in a final
discharge MS–DRG other than an AMI,
PCI, or CABG MS–DRG, the episode
costs were very high in those cases
because they were atypical. The
commenter concluded that CMS’
proposal to cancel these episodes was
appropriate.
Additional analysis by the commenter
demonstrated that hospitals that transfer
AMI beneficiaries frequently are more
likely to be smaller community
hospitals with much higher episode
spending, who would be penalized by
the lack of a more robust transferadjustment methodology just because
they do not have the most sophisticated
cardiac care available. Several
commenters stated that these hospitals
often have no choice but to transfer their
most complicated patients to larger,
tertiary hospitals so that the patients can
receive the most appropriate cardiac
care and that hospitals should not be
penalized for doing so. These
commenters requested that CMS
exclude the IPPS amount paid to the
initial admitting hospital when
calculating quality-adjusted target prices
and actual episode spending to put
these hospitals on a more level playing
field with larger referral hospitals that
offer comprehensive cardiac care in
order to encourage the best provision of
care to beneficiaries in AMI episodes.
Additionally, the commenters
recommended that CMS provide
additional explanation of the framework
for chained anchor hospitalizations in
the final rule and include illustrative
examples about how the methodology
works.
One commenter expressed support for
the second of the two alternatives
considered by CMS for attributing AMI
episodes in inpatient-to-inpatient
transfer scenarios that would begin an
AMI episode and assign episode
responsibility to the hospital in the
chained anchor hospitalization
discharging the beneficiary under the
most resource-intensive MS–DRG
according to a hierarchy of CABG, PCI,
and AMI MS–DRGs in descending order
of inpatient hospital resource-intensity.
The commenter reasoned that in
comparison with CMS’ proposal, this
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approach would provide a more direct
association in the transfer policy
between hospital episode responsibility
and the hospital providing the highest
level of care for the beneficiary with
AMI during the chained anchor
hospitalization. The commenter stated
that if a hospital admits a beneficiary
but then has to transfer the beneficiary
to another hospital for more advanced
cardiac care that the initial treating
hospital cannot provide, it does not
seem reasonable to make that initial
hospital responsible for all follow up
care post-discharge for that condition.
The majority of commenters opposed
CMS’ proposed AMI model transfer
episode initiation and attribution
policy, with the majority addressing the
inpatient-to-inpatient transfer scenario
where the initial treating hospital and
the i-i transfer hospital are both AMI
and CABG model participants. In
general, the commenters believe the
inpatient-to-inpatient transfer proposal
was too complex and would be
unmanageable for EPM participants.
They stated that while CMS partially
predicated its AMI model transfer
episode initiation and attribution
proposal on public input on the CJR
model that beneficiaries often prefer to
receive follow up care after hospital
discharge in their community, the AMI
and CABG models are sufficiently
different from the CJR model that this
perspective may not apply to the
proposed models. In the AMI and CABG
models, the commenters emphasized
that beneficiaries would be more likely
to require emergent care and, therefore,
have less of an opportunity to seek care
from a facility located outside of their
region. Thus, the commenters believe
that many AMI model beneficiaries
experiencing a chained anchor
hospitalization during their initial
hospital treatment for AMI would
remain in the same region as the i-i
transfer hospital for post-acute care
services, in contrast to primarily
elective LEJR under the CJR model
where procedures may be planned in
advance and involve farther travel for
the surgery. Thus, the commenters
reasoned that the initial treating
hospital and the i-i transfer hospital
caring for a beneficiary in an AMI
episode would be likely to be in the
same region as one another and the
beneficiary’s home community. Thus,
they concluded that CMS’ interest in
AMI model attribution policy for
inpatient-to-inpatient transfers that
could support beneficiary follow up in
their own community following
discharge could be met equally well
through AMI episode attribution to the
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277
i-i transfer hospital as to the initial
treating hospital.
Therefore, for inpatient-to-inpatient
transfer scenarios for AMI model
beneficiaries, many commenters who
disagreed with CMS’ proposal
recommended CMS to adopt the first
alternative considered for i-i transfers
once an AMI episode is initiated at the
initial treating hospital. Consistent with
CMS’ discussion of this alternative
considered in the proposed rule (81 FR
50838), the commenters encouraged
CMS to cancel the AMI episode initiated
at the initial treating hospital every time
an inpatient-to-inpatient transfer occurs,
and base any AMI or CABG episode
initiation on the MS–DRG for the final
i-i transfer hospital admission in the
chained anchor hospitalization if the ii transfer is an AMI or CABG model
participant. This would place financial
responsibility for the episode on the ii transfer hospital if the beneficiary
went on to be discharged from acute
care at that hospital and the hospital
was an AMI or CABG model participant.
The commenters claimed this approach
would greatly simplify the initiation,
attribution, and pricing methodologies
under the AMI and CABG models.
The commenters favoring AMI
episode initiation and episode
assignment to the i-i transfer hospital
contended that CMS’ proposal to assign
AMI episode responsibility to the initial
treating hospital could encourage the
initial treating hospital to either
prematurely transfer patients who
present to the emergency department
with symptoms of AMI or not transfer
AMI patients at all to retain control of
the episode and its associated costs. The
commenters speculated that while these
hospital responses could be clinically
appropriate, it is unclear whether this
would be the best approach for
beneficiaries and whether long-term this
type of transfer policy within the AMI
model could reduce the capacity of
small and rural hospitals to effectively
manage care for cardiac patients, while
creating an overreliance on larger
hospitals.
The commenters stated that CMS’
proposal placed too much importance
on the role of the local hospital and
physicians associated with the initial
AMI treatment and too little importance
on the role of the hospital providing the
majority of the AMI care. They
maintained that the i-i transfer hospital
would be more likely to influence the
post-discharge plan and post-acute care
the beneficiary receives and would be in
a better position to retain financial
responsibility for the beneficiary and
assume final risk for the EPM episode.
The commenters claimed that it is the
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discharging i-i transfer hospital that
would develop the discharge plan; make
recommendations on the type of postacute care services necessary and make
arrangements with specific post-acute
care providers; schedule follow up
appointments; educate the beneficiary
and caregivers about the beneficiary’s
clinical condition; and communicate
post-discharge instructions.
In addition, several commenters
pointed out that the initial treating
hospital may not know the beneficiary’s
final MS–DRG until days after discharge
from the i-i transfer hospital. They
stated that this time lag makes it
problematic to assign episode
responsibility to the initial treating
hospital because that hospital would not
be able to identify and intervene with
AMI model beneficiaries prior to their
discharge from acute care, a care
redesign strategy that the commenters
believe is important for AMI model
success. Some commenters stated that
CMS failed to appreciate the complexity
of accurate beneficiary identification
and its impact on facilitating effective
post-acute care services in the proposed
AMI model transfer policy.
A number of commenters recognized
CMS’ intent to link transferring
hospitals with larger, tertiary hospitals
through the AMI model transfer episode
initiation and attribution proposal in
order to strengthen the quality and
efficiency of health care within
communities. The commenters agreed
that there needs to be increased
communication and collaboration
among these hospitals in order to
achieve better patient outcomes, yet
they also believe that ongoing
challenges with the timely
communication of beneficiary
information among providers and the
current competitive healthcare
landscape are not conducive to this type
of collaboration.
In general, many commenters
expressed concern that the complexity
of the AMI model’s proposed transfer
attribution policies and the potential
resulting confusion about beneficiary
notification and hospital episode
responsibility in an environment that
lacks established electronic tracking
programs that can communicate among
many hospitals in different systems.
Several commenters believe the
proposed policy could focus an AMI
model participant’s limited resources on
administrative issues that do not
actually improve care and reduce
episode costs for AMI beneficiaries.
They stated that hospital time and
resources would be better spent
improving care, developing sharing
arrangements among providers, and
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tracking beneficiary outcomes. The
commenters emphasized that this is
especially true since transfers are
expected to occur in a small minority of
AMI episodes.
The majority of commenters also
expressed various concerns about
potential beneficiary harm due to AMI
model transfer policies under an EPM,
whether those proposed or
recommended by some of the
commenters, that would establish new
financial incentives for hospitals around
transfers for beneficiaries with AMI in
the absence of clear best transfer
practices for hospitals with varying
levels of cardiac care capacity. The
commenters claimed that CMS’ proposal
did not include sufficient protections
against EPM participants engaging in
adverse patient selection to improve
quality and cost performance in each
type of transfer scenario (no transfer,
outpatient-to-inpatient, and inpatientto-inpatient). The commenters believe
that inappropriate transfers and costshifting among competitors in a
geographic market could occur under
the AMI model, and they recommended
to CMS to provide robust patient
protections and transfer methodologies
in the final rule.
Most commenters expressed support
for CMS’ proposal to initiate AMI
episodes upon admission to the o-i
transfer hospital in an outpatient-toinpatient transfer scenario, as well as
attribute responsibility for the episode
to the o-i transfer hospital. The
commenters agreed with CMS that this
approach would not require potentially
flawed assumptions about the
relatedness of services preceding the
hospital admission and, therefore,
would result in clearly defined AMI
episodes. However, several commenters
recommended CMS to address the
operational issues identified in the
proposed rule (81 FR 50839) related to
outpatient-to-inpatient transfers that
would not allow CMS to begin AMI
episodes when an initial treating
hospital provides only outpatient
emergency care prior to transfer to an oi transfer hospital. The commenters
believe it would be important to
mitigate these concerns in order to
avoid the potential unintended
consequences of unnecessary and
medically inappropriate outpatient-toinpatient beneficiary transfers.
Due to the complexity of transfer
scenarios and the lack of clarity about
the best approaches to caring for
beneficiaries with AMI under an EPM in
communities with varying cardiac care
capacity distributed among hospitals in
the region, several commenters further
recommended that CMS gather clinical
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expert advice through an advisory panel
or other dialogue with stakeholders to
further explore the AMI model transfer
policy consequences on hospitals’
willingness to transfer patients. Finally,
many commenters recommended CMS
to provide clarification and ongoing
guidance and support to AMI model
participants related to transfers and
episode attribution and monitor for any
unintended consequences of the final
AMI model transfer episode initiation
and attribution policies.
Response: We appreciate the variety
of perspectives of the commenters on
the proposed AMI model transfer
episode initiation and attribution
policies. We agree with the commenters
that this area of policy is both complex
and significant under the AMI model,
given the variety of care patterns
experienced by beneficiaries with AMI
and the variation in cardiac care
capacity among hospitals. The transfer
policy has substantial implications for
AMI and CABG model participants with
varying cardiac care capacity,
beneficiaries who experience transfers
during emergency treatment of AMI,
and CMS due to the potential for the
AMI model transfer policy to result in
changes in transfer patterns that do not
improve the quality or efficiency of care
for beneficiaries with AMI, both those
beneficiaries included the model and
those whose care is not included in the
AMI model. We recognized the
importance of considering the potential
advantages and disadvantages of various
approaches to AMI model transfer
episode initiation and attribution for
beneficiaries and hospitals in our
extensive discussion in the proposed
rule (81 FR 50838 through 50840) about
alternatives considered for outpatientto-inpatient and inpatient-to-inpatient
transfer scenarios. We also continue to
believe that collaboration among
community hospitals and referral
hospitals with more advanced cardiac
care capacity is important to improving
the quality and efficiency of health care
in communities, especially for
beneficiaries with conditions requiring
emergency evaluation and treatment
such as AMI.
We considered the analysis provided
by some commenters and the
commenters’ different perspectives on
the proposed AMI model transfer
episode initiation and attribution
proposal and the alternatives
considered, including the potential for
unintended consequences under any
transfer policy we would establish for
the AMI model. At this point in time,
we appreciate that there are important
advantages and disadvantages to each of
the potential AMI model transfer
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episode initiation and attribution
policies that require ongoing
consideration over the longer-term
during AMI model implementation in
order to optimize the interests of
beneficiaries, hospitals, and CMS, while
limiting the risk of unintended
consequences that could create
problems for beneficiaries, hospitals,
and CMS. For example, several
commenters stressed that changes to
current AMI transfer patterns under
transfer policies of the AMI model that
encourage the initial treating hospital to
either more quickly transfer patients
who present to the emergency
department with symptoms of AMI or
not transfer AMI patients at all to retain
control of the episode and its associated
cost could be clinically appropriate but
also could reflect premature transfers
that were not medically necessary or a
care pattern that poses a risk to
beneficiaries’ health. Thus, while we are
finalizing a policy now to address
transfer situations under the AMI model
to allow for implementation of the
model, we are also coupling this policy
with heightened monitoring and
evaluation of transfers of Medicare AMI
beneficiaries to and from AMI and
CABG model participants and may
propose refinements to the policy or
payment adjustments in the future
depending on our findings.
With respect to the policy for
outpatient-to-inpatient transfers of
beneficiaries with AMI, we proposed to
begin AMI and CABG episodes upon the
first inpatient admission to a treating
hospital that is an AMI or CABG model
participant, rather than in the outpatient
department of the initial treating
hospital that did not admit the
beneficiary. In the proposed rule (81 FR
50839), we also considered an
overarching alternative policy that
could begin every AMI and CABG
episode at the first AMI or CABG model
participant at which the beneficiary was
either admitted for an AMI MS–DRG,
PCI MS–DRG with an AMI ICD–CM
diagnosis code, or CABG MS–DRG or
presented to the emergency department
for initial AMI care (including
observation status) before being
transferred to an o-i transfer hospital.
However, we are not beginning AMI or
CABG episodes with care furnished by
an AMI or CABG model participant
when the beneficiary is not admitted as
an inpatient to that hospital. Given the
commenters’ concerns about our
proposal to begin AMI episodes at the
initial treating hospital under the
circumstance of an inpatient-toinpatient transfer, we believe that
beginning AMI episodes at a hospital
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furnishing only emergency AMI care
could interfere with the hospital’s focus
on emergency stabilization and transfer
of the beneficiary. It could also place an
undue burden on the initial treating
hospital for long-term responsibility for
the AMI episode in which the initial
treating hospital had a role that was
limited to stabilization prior to transfer
for AMI treatment. We would not expect
the initial treating hospital in these
circumstances to be substantially
involved in the beneficiary’s AMI
treatment after the initial emergency
care. The commenters confirmed our
concerns, as discussed in the proposed
rule (81 FR 50839), that this approach
would be complex, challenging to
operationalize, and require assumptions
about the relationship of care to the AMI
based solely on administrative claims
data that would be insufficient to ensure
we could accurately identify related
care.
Thus, we have concluded that it
remains problematic to define the
services to be included in AMI episodes
if those services precede an inpatient
hospitalization that would otherwise
initiate the AMI or CABG episode. As
we discuss in section III.C.4.a.(1) of this
final rule, we are not beginning an EPM
episode prior to the anchor
hospitalization because of the clinical
variability leading up to all EPM
episodes and the challenge of
identifying unrelated services prior to
the inpatient hospitalization. Thus, we
will not make an exception for transfers
from the emergency department or
observation status of the initial treating
AMI or CABG model participant when
the beneficiary with AMI is not
admitted to that hospital. As discussed
in sections III.G.4. through 6. and IV. of
this final rule, we will be engaged in
monitoring and evaluation specifically
as they relate to the risks associated
with this policy of adverse patient
selections that could result in increased
transfers of complex beneficiaries with
AMI to other hospitals so that an AMI
model participant can avoid high-cost
episodes. Should we observe concerning
outpatient-to-inpatient transfer patterns,
we may engage in future rulemaking to
refine the AMI episode initiation policy
or to make a payment adjustment for
this scenario.
With respect to the proposed policy
for inpatient-to-inpatient transfers, we
appreciate the detailed comments on the
proposal as well as on the two
alternatives considered in the proposed
rule (81 FR 50838). In response to the
commenters who contended that the
proposal to assign AMI episode
responsibility to the initial treating
hospital in an inpatient-to-inpatient
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279
transfer scenario could increase
premature transfers, we are unclear that
this would be the case since we also
proposed not to initiate AMI episodes
based only on care in the outpatient
department. Thus, we believe it would
be more likely expected that AMI model
participants pursuing early transfer
would transfer the beneficiary prior to
admission to the hospital. However, we
are concerned that the proposal to
assign AMI episode responsibility to the
initial treating hospital could lead to
beneficiaries not being transferred in
circumstances where they need a higher
level of cardiac care, as a number of
commenters claimed.
We appreciate the support of the
commenter for the second alternative
we discussed in the proposed rule (81
FR 50838) for inpatient-to-inpatient
transfer, which would assign AMI or
CABG episode responsibility to the
hospital in the chained anchor
hospitalization discharging the
beneficiary under the most resourceintensive MS–DRG according to a
hierarchy of CABG, PCI, and AMI MS–
DRGs in descending order of inpatient
hospital resource-intensity. While we
continue to believe that this alternative
could have merit by placing AMI
episode responsibility on the hospital
that furnished the most intensive
treatment to the AMI beneficiary during
the chained anchor hospitalization, we
are not adopting this policy due to
concerns about the episode attribution
complexity that it would present. Many
commenters pointed out significant
challenges for AMI model participants
that would arise under our proposal to
assign AMI episode responsibility
consistently to the initial treating
hospital that admitted the beneficiary
regarding the ability of AMI model
participants to meet the requirements of
the model, such as timely beneficiary
notification. They also raised concerns
about the timeliness of the responsible
hospital’s identification of model
beneficiaries especially if the hospital is
not the one discharging the beneficiary
from acute care and stated that a delay
in beneficiary identification could
seriously impede the hospital’s ability
to intervene with AMI and CABG model
beneficiaries to begin coordinating care
prior to hospital discharge. Thus, we
believe that an inpatient-to-inpatient
transfer policy that assigns AMI episode
responsibility in some cases to the
initial treating hospital and in other
cases to the i-i transfer hospital
depending on the different MS–DRGs
during the chained anchor
hospitalization would be even more
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complex and could lead to even greater
hospital confusion than our proposal.
We also considered the potential for
making a payment adjustment while
holding the initial treating hospital
accountable for the AMI episode as
recommended by a number of
commenters, in order to put hospitals
with lesser cardiac care capacity that
more frequently need to transfer AMI
beneficiaries on a more level playing
field with hospitals that can themselves
furnish comprehensive cardiac care.
While this recommendation from the
commenters would be operationally
feasible and address some of the
concerns raised by commenters about
the transfer incentives inherent in our
proposal, while maintaining the
responsible hospital for the AMI
episode in an inpatient-to-inpatient
transfer scenario as the initial treating
hospital that would be most likely to be
in the beneficiary’s community, this
recommendation would add even
greater complexity to the AMI model
pricing methodology, already an area of
significant concern to the commenters.
This refinement also would not address
the challenges for the initial treating
hospital raised by other commenters
related to timely beneficiary
identification and notification.
Therefore, we are not adopting this
recommendation for the AMI model.
However, we note that because we are
changing the responsible hospital for
AMI and CABG episodes that involve
inpatient-to-inpatient transfers in our
final policy as discussed later in this
section, we believe the commenters’
interest in creating a more level playing
field among AMI model participants
that transfer beneficiaries to variable
degrees is addressed through that final
policy.
Most commenters favored the first
alternative we discussed in the
proposed rule (81 FR 50838) for AMI
model transfer episode initiation and
attribution in the inpatient-to-inpatient
transfer scenario. Specifically, this
policy would cancel the AMI episode
initiated at the initial treating hospital
that is an AMI model participant when
any inpatient-to-inpatient transfer
occurs. The beneficiary would initiate a
new AMI or CABG episode at the i-i
transfer hospital if that hospital is an
AMI or CABG model participant and the
MS–DRG for that hospitalization is an
AMI MS–DRG, PCI MS–DRG with AMI
ICD–CM diagnosis code, or CABG MS–
DRG. If the i-i transfer hospital is not an
AMI or CABG model participant, then
the beneficiary would not be included
in any AMI or CABG episode regardless
of the MS–DRG assigned. This approach
would place financial responsibility for
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the AMI or CABG episode on the i-i
transfer hospital if the beneficiary went
on to be discharged from acute care at
that hospital. Episode initiation and
attribution in this way addresses the
concerns of commenters about
establishing a level playing field for
AMI model participants that more
frequently transfer beneficiaries for AMI
treatment because it would not hold
those hospitals accountable for AMI
episodes with inpatient-to-inpatient
transfers that are, on average, highercost than AMI episodes without
transfers.
This approach also addresses the
commenters’ significant concerns about
the potential burden our proposal
would have placed on the initial
treating hospital to track beneficiaries
transferred to the i-i transfer hospital
and determine if they were discharged
from the i-i transfer hospital under an
MS–DRG that would assign the
beneficiary to an AMI episode for which
the initial treating hospital would be
responsible. The resources necessary for
the initial treating hospital to coordinate
with the i-i transfer hospital that was
actually discharging the beneficiary
around the discharge and follow up
plan could be substantial, given that the
i-i transfer hospital would hold the
discharge planning responsibility for
that beneficiary. It is not clear that the
opportunity for the initial treating
hospital to enter into financial
arrangements to share upside and/or
downside risk with the i-i transfer
hospital as discussed in section III.I. of
this final rule would have been
sufficient to incentivize the degree of
timely collaboration and coordination
by the i-i transfer hospital that would be
needed by the responsible initial
treating hospital.
Therefore, we believe the most
prudent final AMI model transfer
episode initiation and attribution policy
at this time is to cancel the AMI episode
initiated at the initial treating hospital
whenever an inpatient-to-inpatient
transfer occurs, and base any new AMI
or CABG episode initiation on the MSDRG for the i-i transfer hospital
admission if the i-i transfer hospital is
an AMI or CABG model participant.
This attribution approach is simple and
unambiguous. It eliminates the need for
us to adopt the concept of chained
anchor hospitalization altogether, as
well as the complex policy that would
have established a price MS–DRG that
could be different from the MS–DRG
that was assigned to the hospitalization
that initiates the AMI episodes as
discussed in section III.D.4.b.(2)(a) of
this final rule. We do not believe there
is a need to make any additional pricing
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adjustments for inpatient-to-inpatient
transfer scenarios that include more
than one IPPS payment for continuous
acute care services in the beginning of
AMI episodes in order to ensure a level
playing field for hospitals that more
commonly transfer beneficiaries for AMI
treatment. By making the hospital
ultimately discharging the beneficiary
from acute care responsible for the AMI
or CABG episode and beginning the
episode at that hospital, we reduce the
hospital’s uncertainty as much as
possible around identifying
beneficiaries in the model. In the
inpatient-to-inpatient transfer scenario,
the uncertainty about identification of
beneficiaries who were transferred is no
different than if all the care for the
beneficiary occurred at a single hospital.
We also do not hold a hospital
financially responsible for inpatient or
outpatient hospital and Part B services
that precede the beneficiary’s admission
to the responsible hospital, services the
responsible hospital would be unable to
influence according to the commenters.
While we are finalizing this AMI
model transfer episode initiation and
attribution policy at this time for the
AMI model that differs from our
proposal for the reasons discussed, we
continue to have some concerns about
the care patterns that could be
perpetuated and changes that could be
incentivized by the policy. First, we
recognize that this policy does not
encourage any efficiencies in the
transfer patterns of beneficiaries with
AMI, while we know that episodes
which include inpatient-to-inpatient
transfers in the beginning of AMI care
are costly for the Medicare program. A
recent analysis by DataGen of 90-day
episodes of care for AMI found that
nationally, Medicare payments (that is,
costs to the program) for AMI acute care
transfers (not just those receiving PCI)
were second only to the costs for
patients going to long-term care.71 This
analysis is consistent with information
provided by the commenters that AMI
episodes that include inpatient-toinpatient transfers are significantly more
costly than AMI episodes that do not
include such transfers. The analysis
identified three scenarios for AMI care
as follows:
• In hospitals that are licensed to
perform PCIs, a patient who is admitted
with AMI and needs a PCI receives his
or her full treatment at that hospital.
This results in one MS–DRG assignment
and payment for the PCI.
71 The Truth Behind Variation in Episode
Payments; May 5, 2014. Accessed October 18, 2016
at https://www.beckershospitalreview.com/finance/
the-truth-behind-variation-in-episodepayments.html.
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• In hospitals not licensed to perform
PCIs, a patient admitted with an AMI
who needs a PCI is assigned an AMI
MS–DRG at the initial treating hospital
and then transferred to an i-i transfer
hospital for the PCI. This results in two
MS–DRG payments, one for the AMI
care and one for the PCI. In this case,
the inpatient acute care costs for the
initial AMI treatment are substantially
higher. The analysis found that the
average length-of-stay at the initial
treating hospital was 3 days, but it was
not possible to determine from
administrative claims whether that
relatively long length-of-stay was due to
patient stabilization or the need to wait
for the PCI to be scheduled at the i-i
transfer hospital.
• In hospitals that are licensed to
perform PCIs, a patient who is admitted
with an AMI and needs a PCI receives
some care at the initial treating hospital
and then is transferred to an i-i transfer
hospital for the PCI. This also results in
two MS–DRG payments and
substantially higher inpatient acute care
costs for the initial AMI treatment
In summary, medically unnecessary
or inappropriate inpatient-to-inpatient
transfers lead to inefficiencies in initial
AMI treatment, yet both the second and
third scenarios may provide
opportunities for care redesign.
However, the final AMI model transfer
episode initiation and attribution policy
is not able to test such opportunities at
this time.
In addition to not creating incentives
for transfer efficiency, the final AMI
model policy may create additional
incentives for an AMI model participant
to transfer complex beneficiaries or
beneficiaries with potentially avoidable
complications resulting from AMI
treatment who would be expected to
result in high-cost episodes to i-i
transfer hospitals. Transfers could occur
to i-i transfer hospitals that are also
participants in the AMI model where
the costs of care at the initial treating
hospital would not be included in the
AMI episode initiated at the i-i transfer
hospital or to hospitals outside the MSA
that would not be participants in the
AMI model. Such transfer patterns
could ultimately result in either
complex beneficiaries or those with
complications resulting from the initial
AMI treatment disproportionately not
being the financial responsibility of the
initial AMI model treating hospital or
not being included in the AMI model at
all.
Given these concerns about the
potential missed opportunities and
unintended consequences due to the
final AMI model transfer episode
initiation and attribution policy, we will
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be examining AMI transfers to and from
AMI model participants very closely
through our monitoring and evaluation
activities as discussed in sections
III.G.4. through 6. and IV. of this final
rule, both of beneficiaries that
ultimately are included in AMI episodes
and those that are not. We may revisit
the transfer policy or propose payment
adjustments through future rulemaking
if we see reduced AMI transfer
efficiency; opportunities to increase
transfer efficiency; disproportionate
transfers of complex AMI beneficiaries
suggesting that AMI model participants
are engaging in adverse patient
selection; high rates of transfers of
beneficiaries with potentially avoidable
complications of AMI treatment at the
initial treating hospital; inordinate loss
of beneficiaries from the AMI model due
to transfer outside of the MSAs where
the AMI and CABG models are being
tested; or other patterns of concern.
The final policies for initiation and
attribution of AMI and CABG episodes
that involve no transfer, outpatient-toinpatient transfer, or inpatient-toinpatient transfers at the beginning of
AMI care are summarized in Table 8.
Comment: One commenter requested
that CMS establish a transfer attribution
policy for the SHFFT model as well,
because beneficiaries with SHFFT are
occasionally transferred from the initial
treating hospital to another hospital for
SHFFT surgery. The commenter
recommended that the SHFFT episode
be attributed to the transfer hospital,
that is, the hospital receiving the
beneficiary upon transfer from the
initial treating hospital.
Response: We appreciate the
commenter’s suggestion. However, we
do not believe it is necessary to
establish a specific transfer policy for
the SHFFT model. A SHFFT episode
would only be initiated in the hospital
where the beneficiary had SHFFT
surgery and where a SHFFT model MS–
DRG is first assigned to the beneficiary’s
hospitalization. The initial treating
hospital would only assign a SHFFT
model MS–DRG to the beneficiary if the
beneficiary received SHFFT surgery at
that hospital and the transfer hospital
could not assign a SHFFT model MS–
DRG unless the beneficiary had surgery
on the other hip, an unlikely scenario.
Therefore, under the circumstances
described by the commenter, without
any special policies beyond the
standard rules of SHFFT episode
initiation, the SHFFT episode would be
initiated at the transfer hospital, which
would be responsible for the SHFFT
episode. We note that if the SHFFT
surgery was performed at the initial
treating hospital where an episode was
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281
initiated and then the beneficiary was
transferred to another hospital for
additional care, the SHFFT episode
would continue under the responsibility
of the initial treating hospital. We note
that we would apply the SHFFT model
exclusion list to the transfer hospital
MS–DRG to determine whether those
inpatient services were included in the
SHFFT episode.
Final Decision: After consideration of
the public comments received, we are
not finalizing our proposal to attribute
AMI episodes to the initial treating
hospital when an inpatient-to-inpatient
transfer occurs during the anchor
hospitalization. Instead, we are adopting
a final policy to cancel the AMI episode
initiated at the initial treating hospital
when an inpatient-to-inpatient transfer
occurs, and base any AMI or CABG
episode initiation on the MS–DRG for
the final i-i transfer hospital admission
if the i-i transfer hospital is an AMI or
CABG model participant. If the i-i
transfer hospital is not an AMI or CABG
model participant, the beneficiary’s care
is not included in any AMI or CABG
episode. We are not using the terms
chained anchor hospitalization and
price MS–DRG in the final episode
definition and pricing policies for the
AMI model as discussed in sections
III.C.4.a.(5) and III.D.4.b.(2)(a) of this
final rule. Instead, the episode
definition and pricing is determined
only by the anchor MS–DRG for the
AMI or CABG model episode.
The proposal for AMI episode
attribution in circumstances that
involve inpatient-to-inpatient transfers
of beneficiaries with AMI was included
in proposed § 512.240(a)(2). We no
longer need a specific attribution
provision for the AMI model because
attribution of AMI and CABG episodes
occurs in the usual manner to the AMI
or CABG model participant that
discharges the beneficiary under an AMI
MS–DRG, PCI MS–DRG with AMI ICD–
CM diagnosis code, or CABG MS–DRGs
that initiates the AMI or CABG episode
at that hospital. Therefore, we are
renumbering proposed § 512.240(a)(3)
(Cancellation of an AMI model episode)
to § 512.240(a)(2), and revising proposed
§ 512.240(a)(3)(iii) which has been
renumbered § 512.240(a)(2)(iii) to
specify that an AMI model episode is
canceled if the beneficiary is transferred
during the anchor hospitalization to
another hospital for inpatient
hospitalization.
The final policies for initiation and
attribution of AMI and CABG episodes
that involve no transfer, outpatient-toinpatient transfer, or inpatient-toinpatient transfers at the beginning of
AMI care are summarized in Table 8.
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TABLE 8—FINAL INITIATION AND ATTRIBUTION OF AMI AND CABG EPISODES THAT INVOLVE NO TRANSFER, OR
OUTPATIENT-TO-INPATIENT OR INPATIENT-TO-INPATIENT TRANSFERS AT THE BEGINNING OF AMI CARE
Scenario
Final episode initiation and attribution policy
No transfer (participant): Beneficiary admitted to an initial treating hospital that is a participant in the AMI or CABG model for an AMI MS–
DRG, PCI MS–DRG with AMI ICD–CM diagnosis code, or CABG
MS–DRG.
No transfer (nonparticipant): Beneficiary admitted to an initial treating
hospital that is not a participant in the AMI or CABG model for an
AMI MS–DRG, PCI MS–DRG with AMI ICD–CM diagnosis code, or
CABG MS–DRG.
Inpatient–to–inpatient transfer (nonparticipant to participant): Beneficiary admitted to an initial treating hospital that is not an AMI or
CABG model participant and later transferred to an i–i transfer hospital that is an AMI or CABG model participant for an AMI MS–DRG,
PCI MS–DRG with AMI ICD–CM diagnosis code, or CABG MS–DRG.
Inpatient–to–inpatient transfer (participant to nonparticipant): Beneficiary admitted to an initial treating hospital that is an AMI or CABG
model participant for an AMI MS–DRG or PCI MS–DRG with AMI
ICD–CM diagnosis code and later transferred to an i–i transfer hospital for an AMI, PCI, or CABG MS–DRG, where the i–i transfer hospital is not an AMI or CABG model participant.
Inpatient–to–inpatient transfer (participant to participant): Beneficiary
admitted to an initial treating hospital that is an AMI or CABG model
participant for an AMI MS–DRG or PCI MS–DRG with AMI ICD–CM
diagnosis code later transferred to an i–i transfer hospital for an AMI,
PCI, or CABG MS–DRG, where the i–i transfer hospital is an AMI or
CABG model participant.
Outpatient–to–inpatient transfer (nonparticipant to participant or participant to participant): Beneficiary transferred without admission from
the initial treating hospital, regardless of whether the initial treating
hospital is an AMI or CABG model participant, to a o–i transfer hospital that is an AMI or CABG model participant and is discharged
from the o–i transfer hospital for an AMI MS–DRG, PCI MS–DRG
with AMI ICD–CM diagnosis code, or CABG MS–DRG.
Outpatient–to–inpatient transfer (participant to nonparticipant): Beneficiary transferred without admission from the initial treating hospital
that is an AMI or CABG participant to an o–i transfer hospital that is
not an AMI or CABG model participant.
Initiate AMI or CABG episode based on anchor hospitalization MS–
DRG.
Attribute episode to the initial treating hospital.
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b. Middle of EPM Episodes
Similar to the CJR model, we
proposed that once an EPM episode
begins, it would continue until the end
of the episode as described in the
following section, unless certain
circumstances arise during the episode
(80 FR 73318). When an EPM episode
was canceled, we proposed that the
services furnished to beneficiaries prior
to and following the EPM episode
cancellation would continue to be paid
by Medicare as usual but there would be
no actual EPM episode spending
calculation that would be reconciled
against the EPM quality-adjusted target
price.
Specifically, we proposed that the
following circumstances occurring
during an EPM episode would cancel
the EPM episode:
• The beneficiary ceases to meet any
of the general beneficiary inclusion
criteria described in section III.C.4.a.(1)
of the proposed rule (81 FR 50834),
except the three criteria regarding
inclusion in other episode payment
model episodes.
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No AMI or CABG episode is initiated.
Initiate AMI or CABG episode based on the MS–DRG at i–i transfer
hospital.
Attribute episode to the i–i transfer hospital.
Cancel AMI episode. No other AMI or CABG episode is initiated.
Cancel AMI episode at the initial treating hospital. Initiate an AMI or
CABG episode at the i–i transfer hospital. Attribute episode to the i–i
transfer hospital.
Initiate AMI or CABG episode based on anchor hospitalization MS–
DRG at o–i transfer hospital. Attribute episode to the o–i transfer
hospital.
No AMI or CABG episode is initiated.
• The beneficiary dies during the
anchor hospitalization.
• The beneficiary initiates any BPCI
model episode.
For purposes of cancellation of EPM
episodes for beneficiary overlap with
other episode payment models, we
proposed that if a beneficiary in an EPM
episode would initiate any BPCI model
episode, the EPM episode would be
canceled. We refer to section III.D.6.c.(1)
of the proposed rule (81 FR 50868) for
further discussion of our proposals
addressing potential overlap of
beneficiaries in the EPMs with the BPCI
initiative. We also refer to section
III.D.6.c.(3) of the proposed rule (81 FR
50869 through 50871) for discussion of
our proposal to cancel EPM episodes for
beneficiaries who become assigned to
specified ACOs during EPM episodes.
Our proposal to only cancel the EPM
episode if a beneficiary dies during the
anchor hospitalization differs from the
final CJR model policy that cancels an
episode if a beneficiary dies any time
during the episode (80 FR 73318). As
discussed in the CJR Final Rule for LEJR
episodes, we believe that it also would
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be appropriate to cancel an episode in
the AMI, CABG, and SHFFT models
when a beneficiary dies during the
anchor hospitalization as there would
be limited incentives for efficiency that
could be expected during the anchor
hospitalization itself (80 FR 73318). We
agreed with commenters on the CJR
model proposed rule that we should
cancel CJR episodes for death any time
during those episodes, because
beneficiary deaths following LEJR
would be uncommon and expected to
vary unpredictably, leading to extremely
high or low episode spending that was
not typical for a LEJR episode. A recent
analysis that pooled results from 32
studies showed the incidence of
mortality during the first 30 and 90 days
following hip replacement to be 0.30
percent and 0.65 percent, respectively,
confirming our expectation of low
mortality rates during LEJR episodes.72
72 Berstock JR, Beswick AD, Lenguerrand E,
Whitehouse MR, Blom AW. Mortality after total hip
replacement surgery: A systematic review. Bone &
Joint Research. 2014; 3(6):175–182. doi:10.1302/
2046–3758.36.2000239.
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In contrast, the 30-day national CABG
and AMI mortality rates as displayed on
Hospital Compare are significantly
higher at approximately 3 percent and
14 percent respectively.73 Several CMS
programs use 30-day mortality measures
for CABG and AMI as measures of
hospital quality, and these measures
were proposed for use in the pay-forperformance methodology for the CABG
and AMI models as discussed in section
III.E.3.f. of the proposed rule (81 FR
50880). Similarly, a 2009 study shows a
30-day hip fracture mortality rate for
Medicare beneficiaries of approximately
5 percent, significantly higher than the
mortality rate following LEJR
procedures.74 Thus, we would expect
that deaths during SHFFT episodes
would be more common than in CJR
episodes. Because beneficiaries in AMI,
CABG, and SHFFT episodes would be at
significant risk of death during these
episodes that we proposed to extend 90
days post-hospital discharge, we
considered mortality to be a harmful
beneficiary outcome that should be
targeted for improvement through care
redesign incentivized by the EPMs for
these clinical conditions. Therefore, in
the proposed rule (81 FR 50841) we
discussed our belief that it would not be
appropriate to exclude beneficiaries
from AMI, CABG, or SHFFT episodes
who die any time during the episode
like we do in the CJR model. Instead, we
proposed to maintain beneficiary
episodes in the EPMs even if death
occurred during the episodes, meaning
we would calculate actual EPM episode
spending when beneficiaries die
following discharge from the anchor
hospitalization but within the 90-day
post-hospital discharge episode
duration and reconcile it against the
quality-adjusted target price. We
believed this proposal would encourage
EPM participants to actively manage
EPM beneficiaries to reduce their risk of
death, especially as death would often
be preceded by expensive care for
emergencies and complications.
Because of the higher mortality rates for
all of the EPM episodes than for LEJR
episodes in the CJR model, we did not
consider mortality following hospital
discharge to be atypical and, therefore,
we proposed to cancel EPM episodes
only for death during the anchor
hospitalization.
We further proposed that the
following circumstances also would
cancel an AMI episode in the
73 https://www.medicare.gov/hospitalcompare/
search.html.
74 Brauer CA, Coca-Perraillon M, Cutler DM,
Rosen AB. Incidence and Mortality of Hip Fractures
in the United States. JAMA. 2009;302(14):1573–
1579. doi:10.1001/jama.2009.1462.
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circumstances of a chained anchor
hospitalization when the beneficiary
was discharged from acute care under
an MS–DRG from the final transfer
hospital in the chained anchor
hospitalization that could not, itself,
initiate an AMI or CABG episode,
regardless of whether the final transfer
hospital was an AMI or CABG model
participant (that is, the episode would
be canceled if the final transfer hospital
MS–DRG was any MS–DRG other than
an AMI MS–DRG, PCI MS–DRG, or
CABG MS–DRG).
While we proposed to begin an AMI
episode with the first hospitalization in
the chained anchor hospitalization that
would initiate an episode as discussed
in section III.C.4.a.(5) of the proposed
rule (81 FR 50836 through 50840), we
also proposed to cancel AMI episodes
under the circumstances when a
beneficiary in an AMI episode was
discharged from acute care under an
MS–DRG from the final i-i transfer
hospital in the chained anchor
hospitalization that was not an AMI,
PCI, or CABG MS–DRG that could
initiate an AMI or CABG episode (that
is, the episode would be canceled if the
final transfer hospitalization MS–DRG
was any MS–DRG other than an AMI,
PCI, or CABG MS–DRG). Overall, this
proposal treated the hospital that
initiated the AMI episode and then
transferred the beneficiary most
similarly to a hospital that furnished all
of the beneficiary’s inpatient care itself,
with respect to whether or not the
beneficiary’s care was ultimately
included as an episode in the AMI
model.
Finally, we did not propose to cancel
an AMI episode altogether for a CABG
readmission during the 90-day posthospital discharge period or cancel the
AMI episode and initiate a CABG
episode because planned CABG
readmission following an anchor
hospitalization that initiates an AMI
episode may be an appropriate clinical
pathway for certain beneficiaries.
Instead, we proposed to provide an
adjusted AMI model-episode benchmark
price that includes a CABG readmission
in such circumstances so as not to
financially penalize participant
hospitals for relatively uncommon,
costly, clinically appropriate care
patterns for beneficiaries in AMI
episodes. We refer to section
III.D.4.b.(2)(c) of the proposed rule (81
FR 508520 for discussion of the adjusted
AMI model-episode benchmark price
that would apply in the case of CABG
readmission during an AMI episode.
The proposals for cancellation of EPM
episodes were included in proposed
§§ 512.240(a)(3), (b)(2), and (c)(2). We
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283
sought comment on our proposals for
cancellation of EPM episodes.
The following is a summary of the
comments received and our responses.
Comment: With the exception of the
proposal for cancellation of EPM
episodes for death only during the
anchor hospitalization, many
commenters expressed support for the
other proposed EPM episode
cancellation policies, especially the
proposal to cancel EPM episodes in the
circumstances of a chained anchor
hospitalization when the beneficiary is
discharged from acute care under an
MS–DRG from the final transfer hospital
in the chained anchor hospitalization
that could not, itself, initiate an AMI or
CABG episode. The commenters
pointed out that when a transfer results
in discharge from the final hospital in
the chained anchor hospitalization
under an MS–DRG that could not
initiate an AMI or CABG episode, those
episodes are disproportionately likely to
reflect high-cost episodes that would
not be conducive to care redesign due
to beneficiary complexity and the need
for atypical beneficiary care. Several
commenters encouraged CMS to
monitor cancellation circumstances
because EPM participants could engage
in gaming by discharging a dying
patient from the hospital to garner a
low-cost episode or encouraging
beneficiaries to enroll in a Medicare
Advantage plan.
A few commenters requested that
CMS cancel EPM episodes when a
beneficiary has an excluded
readmission because the Part A and Part
B services furnished following that
readmission would be related to the
clinical condition that was the basis for
the readmission, and not the condition
that was the focus of the EPM.
Response: We appreciate the support
for our proposals to cancel an EPM
episode when a beneficiary initiates an
EPM episode but then fails to meet the
general beneficiary care inclusion
criteria sometime during the episode,
which include enrollment in Medicare
Part A and Part B; eligibility for
Medicare not on the basis of end-stage
renal disease; not enrolled in any
managed care plan; not covered under a
United Mine Workers of American
health plan; have Medicare as their
primary payer; and not to an ACO in the
Next Generation ACO model or an ACO
in a track of the Comprehensive ESRD
Care Model incorporating downside risk
for financial losses. In addition, we
appreciate the support for our proposals
to cancel an AMI episode when a
beneficiary initiates any BPCI episode
and when an AMI model beneficiary is
discharged from the final hospital in a
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chained anchor hospitalization under an
MS–DRG that is not an AMI, PCI, or
CABG MS–DRG, regardless of whether
the final transfer hospital is an AMI or
CABG model participant. As discussed
in section III.C.4.a.(5) of this final rule,
we are finalizing this proposal, but with
modification to cancel all AMI episodes
that begin at an initial treating hospital
when an inpatient-to-inpatient transfer
occurs after the AMI episode has begun.
In response to those commenters
requesting that we cancel EPM episodes
for the occurrence of an excluded
readmission, we do not agree that all
Part A and Part B services furnished
following discharge from the excluded
readmission but within the original 90day post-discharge period for the EPM
episode would be unrelated to the
clinical condition that is the focus of the
EPM. Instead, we believe care during
that period would also be furnished for
EPM beneficiary management and
recovery following the AMI, CABG, or
SHFFT hospitalization that initiated the
EPM episode. The application of our
exclusion list for readmissions and Part
B services continues to identify those
readmissions and Part B services that
would be excluded from the EPM
episode definition throughout the full
post-discharge episode duration,
regardless of the occurrence of an
excluded readmission during the EPM
episode.
Additionally, as discussed in sections
III.G.4. through 6. of this final rule, we
plan to monitor EPM participants’
claims data and audit EPM participants’
and their EPM collaborators medical
records and claims as we deem
appropriate and will include canceled
EPM episodes in this monitoring to
ensure that we do not observe patterns
of cancellation suggestive of gaming of
the EPM episode cancellation policies.
Comment: Several commenters
expressed support for CMS’ proposal to
cancel EPM episodes for death during
the anchor hospitalization but not for
death during the 90-day post-discharge
episode period. These commenters
agreed that death during the inpatient
hospitalization would be atypical and
should result in EPM episode
cancellation, whereas death within the
90 days following hospital discharge
would not be rare for the clinical
conditions in the EPMs and could
appropriately be targeted for
improvement through EPM care
redesign. The commenters pointed out
that CMS’ proposals to use AMI and
CABG mortality rates in the AMI and
CABG model pay-for-performance
methodologies was consistent with the
opportunities for EPM care redesign to
reduce mortality rates in the 30 days
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following discharge from the anchor
hospitalization for AMI and CABG. A
few commenters suggested that CMS
should not cancel EPM episodes for any
death once they are initiated, even for
death during the anchor hospitalization,
arguing that such cancellations could
skew episode costs and that some inhospital deaths may be preventable,
which the EPMs should provide
incentives to prevent.
However, many commenters,
including MedPAC, recommended that
CMS adopt the same policy as the CJR
model and cancel episodes for death at
any time during the EPM episode,
including during the 90 days posthospital discharge. Some of the
commenters stated that episodes during
which a beneficiary dies usually involve
atypical courses of care, which may
include extensive end-of-life care that
hospitals should not be penalized for
providing. MedPAC speculated that on
the one hand, stays during which the
EPM beneficiary dies could be
exceptionally high-cost if the patient
lives for most of the 90 days and
receives end-of-life care. On the other
hand, if the EPM beneficiary dies
shortly after discharge from the hospital,
the patient may receive little post-acute
care services or end-of-life care,
resulting in unusually low-cost
episodes. They concluded that in either
case, the episode spending would not be
typical and, therefore, these stays
should be excluded from calculating the
target price and reconciliation payment
for the EPM participant. They stated
that excluding these episodes would
make the spending data less ‘‘noisy’’
and better reflect the typical spending
for the EPM participant’s episodes.
MedPAC also claimed that CMS has
better tools than including in the EPMs
beneficiaries who die in the 90 days
following hospital discharge that
encourage lower mortality rates, such as
use of the AMI and CABG mortality
rates in the HVBP Program, and care
coordination, such as the Medicare
Spending Per Beneficiary (MSPB)
measure in the HVBP Program and the
HRRP.
Some commenters further contended
that the proposal to cancel SHFFT
episodes only for death during the
anchor hospitalization compared to CJR
model episode cancellation for
beneficiary death any time during a
LEJR episode leads to a lack of
consistency between hip fracture
beneficiaries included in the CJR and
SHFFT models. Under CMS’ proposal,
hip fracture beneficiaries treated with a
SHFFT would be subject to one set of
rules, while those treated with a hip
replacement would be subject to another
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set, leading to confusion among the
hospitals that would be participants in
both the CJR and SHFFT models and
inequitable treatment of beneficiaries
with the same clinical condition of hip
fracture. The commenters also believe
that CMS’ rationale for not canceling
SHFFT episodes for beneficiaries who
die following discharge from the anchor
hospitalization due to a higher risk of
death for hip fracture patients than
patients receiving LEJR ignored the fact
that a substantial portion of the hip
fracture population is treated with a
LEJR. These commenters concluded that
this overlap of fracture beneficiaries
between SHFFT and LEJR confounded
the comparison CMS was trying to make
between the higher mortality rate of
beneficiaries following SHFFT versus
LEJR and led to questions about its
validity.
Response: While we appreciate that
there may be some opportunities to
reduce in-hospital deaths for
beneficiaries treated with CABG or
SHFFT, we believe that there are limited
efficiencies that could be expected
during the anchor hospitalization itself.
Furthermore, we note that there are
three separate MS–DRGs for
beneficiaries who die during a
hospitalization for AMI (MS–DRG 283
Acute Myocardial Infarction, Expired
with MCC; MS–DRG 284 Acute
Myocardial Infarction, Expired with CC;
MS–DRG 285 Acute Myocardial
Infarction, Expired without CC/MCC),
and we did not propose that these MS–
DRGs would initiate AMI episodes.
Thus, there would be no situations
when AMI episodes were canceled for
death during an anchor hospitalization.
Thus, we do not believe it would be
appropriate to include beneficiaries who
die during the anchor hospitalization in
any of the EPMs.
While beneficiary deaths in the 90days post-discharge from the anchor
hospitalization would be expected to be
more common in AMI, CABG, and
SHFFT episodes than in the LEJR
episodes included in the CJR model, we
agree with the commenters that the
costs of such episodes are likely to vary
unpredictably across EPM participants.
We also agree with the commenters’
argument about the importance of
policy consistency in similar episode
payment models for deaths because
adopting different cancellation policies
for death under the CJR model than we
proposed for the EPMs could be
confusing for those hospitals that are
participants in both the SHFFT and CJR
models. While we continue to believe
that reductions in mortality following
discharge from a hospitalization for
AMI, CABG, or SHFFT are a harmful
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beneficiary outcome that should be
targeted for improvement through care
redesign incentivized by the EPMs for
these clinical conditions, we agree with
the commenters that it would be
appropriate to cancel all EPM episodes
for beneficiary death any time during
the episode. We note that our use of 30day AMI and CABG mortality measures
in the pay-for-performance
methodologies of the AMI and CABG
models, respectively, as discussed in
sections III.E.2.b. and c. of this final rule
encourages AMI and CABG model
participant to actively manage AMI and
CABG beneficiaries to reduce this risk of
death, to supplement existing incentives
in other CMS programs that encourage
lower mortality rates.
Comment: Several commenters
requested that CMS clarify its
administrative policies for identifying
and informing EPM participants about
beneficiaries whose episodes are
initiated and then canceled. The
commenters stated that CMS should
inform EPM participants in a timely
manner when an episode is canceled for
any reason, with one commenter
specifying at least quarterly notification.
The commenters pointed out that an
EPM participant’s awareness of episode
cancellation is important for several
reasons, including the EPM participant’s
simultaneous calculation of EPM
episode spending; beneficiary
notification; provision of beneficiary
engagement incentives; and
determination of beneficiary eligibility
for certain Medicare program rule
waivers which is discussed further in
section III.J. of this final rule. The
commenters claimed that while the EPM
participant is in the best position to
know when the triggering procedures or
services they have been providing will
result in a MS–DRG that would initiate
an EPM episode, the EPM participant
will not always know when a patient
meets certain exclusion criteria
throughout the course of the EPM
episode. The commenters emphasized
that it is important for the EPM
participant to know if beneficiaries they
expect to be part of the EPM episode are
going to be part of the EPM episode on
a timely basis for cancellations or events
that would serve to disqualify the
beneficiary from a given hospital’s
attribution of an episode. Therefore, the
commenters recommended that CMS
inform EPM participant and CJR
participant hospitals timely when an
episode is canceled for any reason.
Response: We appreciate the interest
of the commenters in conducting timely
analysis of EPM episode spending, as
well as ensuring that the requirements
of the EPM are met in their treatment of
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Medicare beneficiaries. Given our plans
for providing and updating episode
claims data to EPM participants upon
request as frequently as quarterly as
discussed in section III.K.5 of this final
rule, we will explore adding indicators
to the beneficiary-identifiable claims
data supplied to EPM participants that
provide information about
circumstances that could result in EPM
episode cancellation, such as admission
of a beneficiary to a hospital that
initiates episodes under a BPCI model
for care that could potentially cancel an
EPM episode. To the extent adding such
indicators to the claims data is feasible,
providing this information through the
claims data to EPM participants would
ensure that EPM participants are
informed as frequently as quarterly
about beneficiary circumstances that
could result in EPM episode
cancellation. This information would
not be real-time, however, and while
our best estimate, would likely be
incomplete even based on the best
available information at the time. At a
minimum, it would always reflect the
time lag for the EPM episode claims to
be submitted and processed and then
reported back to the EPM participant in
the updated claims data. We note that
at reconciliation, complete information
would be provided to EPM participants
that have requested beneficiary-level
claims data or summary beneficiary
claims data reports about those episodes
that were ultimately included in the
EPM participant’s reconciliation report
as discussed in section III.D.5. of this
final rule.
We note that we expect EPM
participants to be actively managing all
of their beneficiaries with conditions
characterized by AMI, CABG, or SHFFT
based on their care pathways developed
for such beneficiaries, regardless of the
model or program that may ultimately
apply to the beneficiary under the
uncommon circumstances of EPM
episode cancellation. We also
emphasize the importance of strong,
ongoing communication among
providers in a given geographic area
caring for beneficiaries in similar
models or programs where provider
interests in delivering high quality,
efficient health care should align.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposals in
§§ 512.240(a)(2), (b)(2), and (c)(2) for
cancellation of EPM episodes, with
modification to also cancel EPM
episodes if the beneficiary dies during
the episode.
We are canceling EPM episodes for
the following circumstances:
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285
• The beneficiary ceases to meet any
of the general beneficiary inclusion
criteria described in section III.C.4.a.(1)
of this final rule, except the three
criteria regarding inclusion in other
episode payment model episodes.
• The beneficiary dies.
• The beneficiary initiates any BPCI
model episode.
Additionally, in the AMI model we
are canceling the AMI episode when a
beneficiary is transferred during the
anchor hospitalization for inpatient
hospitalization at another hospital as
discussed in section III.C.4.a.(5) of this
final rule.
Because we are not finalizing the
proposed AMI model transfer episode
initiation and attribution policy, as
discussed in section III.C.4.a.(5) of this
final rule, we are not adopting the
policy included in proposed
§ 512.240(a)(2). Therefore, we are
renumbering proposed § 512.240(a)(3) to
§ 512.240(a)(2) to specify the final AMI
episode cancellation policy. This
includes renumbering proposed
§ 512.240(a)(3)(iii) to final
§ 512.240(a)(2)(iii) and revising the
provision to specify the final inpatientto-inpatient transfer policy that cancels
an AMI model episode if the beneficiary
is transferred during the anchor
hospitalization for inpatient
hospitalization at another hospital.
c. End of EPM Episodes
(1) AMI and CABG Models
We proposed a 90-day post-hospital
discharge episode duration for AMI
episodes. AMI in general, whether
managed medically or with
revascularization, has a lengthy
recovery period, during which the
beneficiary has a higher than average
risk of additional cardiac events and
other complications, as well as higher
utilization of diagnostic testing and
related cardiac procedures. AMI
frequently serves as a sentinel event that
marks the need for a heightened focus
on medical management of coronary
artery disease and other beneficiary risk
factors for future cardiac events, cardiac
rehabilitation over multiple months,
and beneficiary education and
engagement. Given the broad episode
definition for AMI episodes that
includes beneficiaries receiving both
medical and PCI management for an
acute event, we do not believe that an
episode longer than 90 days would be
feasible due to the higher risk of
including unrelated services in the
episode beyond several months after
hospital discharge. However, we believe
that 90-day post-hospital discharge
episodes would provide substantial
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incentives for aggressive medical
management, cardiac rehabilitation, and
beneficiary education and engagement,
whereas a shorter episode duration
would have less effect. We acknowledge
that ongoing disease management for
beneficiaries with cardiovascular
disease must extend long after the
conclusion of the AMI episodes.
However, we believe the 90-day posthospital discharge episode duration
remains appropriate for an episode
payment model focused around a
hospitalization. We expect that the
medical management and care
coordination during AMI episodes
would continue to be provided as
beneficiaries transition out of AMI
episodes, potentially into a primary care
medical home or other model or
program with accountability for
population health, such as an ACO.
We further note based on analysis of
historical episodes that about 10 percent
of beneficiaries hospitalized with AMI
who received a CABG received the
CABG between 2 and 90 days postdischarge from the anchor
hospitalization (these beneficiaries
would be in AMI episodes), while the
remaining 90 percent of CABGs for
beneficiaries hospitalized with AMI
were provided during the initial
hospitalization (these beneficiaries
would in CABG episodes). In contrast,
fewer than 3 percent of those AMI
model beneficiaries who received an
inpatient or outpatient PCI during an
AMI episode received the PCI between
2 and 90 days post-discharge from the
anchor hospitalization, while more than
97 percent received the PCI during the
anchor hospitalization.75 We refer to
section III.D.4.b.(2)(c) of this final rule
for further discussion of pricing
adjustments and alternatives considered
for setting EPM-episode benchmark
prices for AMI episodes where PCI or
CABG occurs during the AMI episode
but post-discharge from the anchor or
chained anchor hospitalization.
Finally, for similar reasons, we
believe CABG episodes should extend
90 days post-hospital discharge. About
one-third of CABG procedures are
performed in the context of a hospital
admission for AMI, leading to the same
considerations discussed previously in
this section around the appropriate
episode duration for beneficiaries with
AMI. The remaining CABG model
beneficiaries are likely to have
significant ischemic heart disease,
making the occurrence of CABG itself a
75 Episodes for AMI beneficiaries initiated by all
U.S. IPPS hospitals and constructed using
standardized Medicare FFS Parts A and B claims,
as proposed in the proposed rule, that end in CY
2014.
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sentinel event, like AMI, that marks the
need for a heightened focus on medical
management of CAD and other
beneficiary risk factors for future cardiac
events, cardiac rehabilitation over
multiple months, and beneficiary
education and engagement. Moreover,
CABG procedures have 90-day global
periods under the Physician Fee
Schedule, consistent with the lengthy
period of recovery associated with major
chest surgery. Thus, a 90-day posthospital discharge episode duration is
consistent with the recovery period
from CABG surgery. We acknowledge
that ongoing disease management for
beneficiaries with cardiovascular
disease must extend long after the
conclusion of the CABG episodes.
However, we believe the 90-day posthospital discharge episode duration
remains appropriate for an episode
payment model focused around a
hospitalization. We expect that the
medical management and care
coordination during CABG episodes
would continue to be provided as
beneficiaries transition out of CABG
episodes, potentially into a primary care
medical home or other model or
program with accountability for
population health, such as an ACO.
As in the CJR model, we proposed
that the day of discharge from the
anchor hospitalization counts as day 1
of the post-hospital discharge period (80
FR 73324). Since the post-hospital
discharge period is intended to extend
90 days for recovery following hospital
discharge, we believe it is appropriate
under these circumstances to begin the
90-day count when the beneficiary is
ultimately discharged from acute care
for the first time during the AMI
episode. However, the hospital that
initiated the AMI episode in the chained
anchor hospitalization would continue
to be responsible in the AMI model for
the episode discussed previously in
section III.C.4.a.(5) of this final rule.
The proposals for the end of AMI and
CABG episodes were included in
proposed §§ 512.240(a)(1) and (b)(1),
respectively. We sought comment on
our proposals to end AMI and CABG
episodes.
We received a number of comments
on the proposed episode duration for
the AMI and CABG models, although
most commenters provide similar
rationale and recommendations for the
three proposed EPMs. Thus, we refer to
the next section for a discussion of the
comments regarding the proposed
ending of EPM episodes, including
SHFFT as well as AMI and CABG
episodes.
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(2) SHFFT Model
We believe that SHFFT model
beneficiaries are similar to CJR model
beneficiaries who undergo hip
replacement for fracture. We believe
that the same episode duration as the
CJR model of 90 days is appropriate for
SHFFT episodes in order to include the
full time for recovery of function for
these beneficiaries, which extends
beyond 60 days based on patterns of
post-acute care provider use (80 FR
73319 through 73324). Therefore, we
proposed a 90-day post-hospital
discharge duration for SHFFT episodes.
The proposal for the end of SHFFT
episodes was included in proposed
§ 512.240(c)(1). We sought comment on
our proposal to end SHFFT episodes.
The following is a summary of the
comments received and our responses.
Comment: A number of commenters
expressed support for the proposed 90day post-discharge episode duration for
the AMI, CABG, and SHFFT models.
These commenters reasoned that 90
days following discharge from an
inpatient hospitalization was the most
clinically appropriate length for the
proposed conditions and would
enhance the commitment of EPM
participants and their collaborators to
caring for patients over time. They
added that this duration would be
sufficiently long to capture many
complications of treating EPM clinical
conditions and engage multiple
providers in inpatient, outpatient, and
post-acute care provider settings. The
commenters believe that the proposed
episode length would move providers
closer to achieving long-term population
health management. Several
commenters pointed out that hospitals
are well-prepared to assume
responsibility for EPM episodes that
continue for 90 days after hospital
discharge.
Other commenters stated that the
proposed 90-day EPM episode duration
was too long, especially in the context
of the proposals to include a broad array
of related items services in EPM
episodes. In general, the commenters
who stated for a shorter episode
duration believe that during the early
stages of required bundled payment
models, it would be more reasonable for
hospitals to assume episode
performance risk for 30 days postdischarge than 90 days as proposed and
that CMS should adopt 30-days postdischarge as the standard EPM episode
duration permanently or temporarily,
such as for the first two model years,
and then reevaluate.
Several commenters contended that in
using an episode definition that
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includes 90-day post-discharge, CMS
was, in effect, making hospitals
managers of population health. These
commenters believe that hospitals lack
the resources, skill sets, and
infrastructure to engage in the mission
of managing population health, and
stated that the requirements are much
different and more complex and
demanding than what is need for
episode payments. Several commenters
reasoned that since the proposed quality
metrics for the EPMs were 30 days after
discharge and they believe that
hospitals are more effective managing
the first 30 days of an episode, the
episode duration should be shortened to
30 days so the quality and performance
metrics would be aligned.
A number of commenters requested
that CMS shorten the episode duration
to 30 days because 30 days is a more
appropriate duration for exacerbations
of existing, unrelated chronic conditions
to the condition that is the focus of the
episode. Some commenters claimed that
a post-surgical or post-event episode
duration under the AMI, CABG, and
SHFFT models longer than 30 days
poses a greater risk for variability due to
medical events outside the intended
scope of the model and control of the
hospital. They stated that this is
particularly true for ill patients who are
likely to have major complications or
comorbidities when admitted and are at
higher risk for developing new
complications post-discharge. The
commenters stated that because all the
proposed models are urgent or
emergent, rather than elective or timesensitive, this danger poses greater
concern than under other Innovation
Center episode payment models, such as
the CJR model and OCM. While such
comorbidities contributing to all-cause
readmission can be reasonably
controlled in the immediate and 30-day
post-operative or post-event period, the
commenters contended that the most
complex patients develop complications
after discharge, which are highly varied
and predominantly unrelated to the
quality of care they receive. Therefore,
they concluded that care for chronic
conditions and other non-anchor MS–
DRG-related conditions becomes much
more prevalent in days 31 to 90
following hospital discharge. One
commenter observed based on
experience in its hospitals that after 30
days, an over 30 percent increase in
readmissions to a hospital other than
the original facility occurred, creating a
need for additional strategies to
coordinate episode care after 30 days.
The commenters stated that hospitals do
not have the time, money, skill set or
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recourse to develop the infrastructure to
support episode care management
during the 31- to 90-day post-discharge
period. Finally, several commenters
observed that Medicare beneficiaries
may have more than one residence
during the year, creating challenges
with follow up for an episode that
extends 90 day following hospital
discharge.
Response: We appreciate the support
of many commenters for the proposed
90-day post-hospital discharge EPM
episode duration. We agree with the
commenters that the episode duration
should capture the majority of health
care services that are related to the
episode and be sufficiently long to
include many complications and followup care to the anchor hospitalization.
We believe that hospitalization is often
a sentinel event for Medicare
beneficiaries, representing an
opportunity for increased care
coordination and, in the case of the
EPMs, improved care management of
chronic conditions that may have led to
the hospitalization for the cardiac event
or cardiac or orthopedic surgery. This
episode duration provides EPM
participants with a substantial period of
time in which to work to improve the
quality and efficiency of EPM episode
performance for beneficiaries who are
hospitalized for the targeted conditions.
We have substantial BPCI Model 2
experience in testing AMI, PCI, CABG,
and SHFFT episodes that include
beneficiaries who are most similar to
those who would be included in the
proposed EPMs. Almost all BPCI Model
2 Awardees testing these episodes have
selected the 90-day episode duration,
compared to the 30-day and 60-day
alternative durations that are available
in BPCI Model 2. Ninety days posthospital discharge is also the episode
duration in the CJR model. Our goal in
the EPMs is to incentivize efficient, high
quality care that returns beneficiaries to
the community in the best health
possible, and we believe that a 90-day
post-discharge duration reflects a full
continuum of clinical services and
transition of care for average SHFFT,
AMI, and CABG model beneficiaries, at
which time the beneficiary’s functional
recovery and stabilization of medical
conditions are relatively complete so the
beneficiary is able to resume most usual
activities of daily living.
Similar to LEJR episodes under the
CJR model, in our analysis of episode
spending for the EPMs we observed the
concentration of Medicare postdischarge episode spending in the
earlier part of the episode following
discharge from the anchor
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287
hospitalization in all the EPMs.76
Specifically, in the first 30 days
following anchor hospitalization
discharge in AMI episodes, excluding
those AMI episodes with readmissions
for CABG for which we make a payment
adjustment under the AMI model as
discussed in section III.D.4.b.(2)(c) of
this final rule, we found 61 percent and
54 percent of post-discharge episode
spending for AMI MS–DRG-anchored
and PCI MS–DRG-anchored AMI
episodes, respectively. Similarly, in the
30 days following discharge, we
observed 68 percent and 69 percent of
post-discharge episode spending for
CABG and SHFFT episodes. For all of
the EPMs, about 60 to 70 percent of the
remaining post-discharge spending
occurred in days 31–60 post-discharge,
and one-third in days 61–90 postdischarge. Thus, while the 90-day postdischarge episode duration increases the
EPM participant’s financial risk
somewhat compared to episodes that
extend only 30 days, because we found
that significant services related to the
clinical condition that is the focus of the
models occurred during days 31–90
post-discharge, we believe there are
significant opportunities for improved
quality and efficiency in EPM episodes
after 30 days and extending through 90
days post-discharge from the anchor
hospitalization. If, as some commenters
speculated, a post-surgical or post-event
episode duration under the AMI, CABG,
and SHFFT models longer than 30 days
posed a significant risk of variability
primarily due to medical events that are
unrelated to the clinical condition that
is the focus of the EPM episode, we
would have expected to see an equal
percentage of post-discharge episode
spending in the periods of time from
days 31–60 and 61–90. That was not the
case in our analysis, because we
continued to see EPM episode spending
as a proportion of post-discharge
spending drop off in relation to
increasing time after discharge,
suggesting that the EPM episode
definitions are capturing related episode
spending that declines, as would be
expected, over the period of time postdischarge as the beneficiary recovers
and returns to the community.
While we understand that uncommon
events during the 90-day post-discharge
episode duration may occur for an
individual beneficiary, resulting in an
unanticipated or unavoidable need for
costly health care services, we believe
76 Episodes for AMI, CABG, and SHFFT
beneficiaries initiated by all U.S. IPPS hospitals not
in Maryland and constructed using standardized
Medicare FFS Parts A and B claims, as proposed in
the proposed rule, that began in CY 2012–2014.
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that our EPM episode definitions that
exclude unrelated items and services
and our payment policies, namely the
adjustment for high payment episodes
and stop-loss policies discussed in
sections III.D.3.d., III.D.7.b.(1), and
III.D.7.d. of this final rule, provide
sufficient protections for EPM
participants from undue financial
responsibility for the care of unrelated
clinical conditions as well as for
unusual circumstances. We also believe
that shorter episode durations may
incur a higher clinical risk for
beneficiaries if EPM participants delay
services beyond the EPM episode, and
the risk to beneficiaries of this response
by providers to episode payment can be
minimized by the longer 90-day episode
duration that we proposed for the EPMs.
We refer to sections III.G.4. through 6.
of this final rule for discussion of our
plans to monitor for access to care,
quality of care, and delayed care.
In response to the commenters
recommending a shorter episode
duration in the earlier stages of bundled
payment, as noted previously we have
several years of experience with BPCI
Model 2 where the majority of Awardee
have selected a 90-day episode duration
for episodes of a similar design to the
EPMs that target the same clinical
conditions. While entities choose to
participate in the BPC models, we have
also established a 90-day episode
duration in the CJR model, which is the
first episode payment model which has
a geographic basis. Thus, we do not
believe that it is necessary to adopt a
shorter episode duration for the EPMs
either permanently or temporarily.
Regarding those commenters who
believe that the 90-day post discharge
episode duration and broad episode
definitions would make hospitals
responsible for population health, we
note that the EPMs are not total cost-ofcare models. As discussed in section
III.C.3.b of this final rule, we exclude
items and services that are unrelated to
EPM episodes, namely those that are not
directly related to the EPM episode or
the quality or safety of the EPM episode
care that is included in the EPM
episode; for chronic conditions that are
generally not affected by the EPM
episode care; and for acute clinical
conditions not arising from existing
EPM episode-related chronic clinical
conditions or complications of EPM
episode care. We agree with the
commenters in favor of the proposed 90day post-discharge episode duration for
the EPMs who stated that the proposed
EPMs of this episode duration move
providers closer to long-term population
health management. Given the diversity
of commenters’ views on hospitals’
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readiness to assume responsibility for
episodes of the proposed duration, we
appreciate that EPM participants in
models where participation is required
are in various stages of readiness for
managing the quality and cost
performance of episode, based on their
prior experience, resources, and
infrastructure. We believe that all EPM
participants have substantial
opportunities to increase their capacity
to manage the quality and cost of EPM
episodes and achieve significant
financial rewards from good
performance, regardless of their starting
point. We note that many of the EPM
policies such as data sharing, financial
arrangements, the phase-in of two-sided
risk, and stop-loss limits afford
hospitals the opportunity to learn about
EPM episode care patterns, collaborate
with others who have expertise in care
redesign, and implement their initial
EPM care plans for their beneficiaries in
an initial environment of limited
financial risk.
We do not believe that the
measurement period for the quality
measures and the duration of the EPM
episodes must necessarily align,
although we note that we sought
comment in the EPM proposed rule
about potentially using quality measures
that examine patient outcomes over a
period that extends at least as long as
the EPM episode (81 FR 50901). We
proposed to use existing AMI and CABG
outcome measures that assess outcomes
over a 30-day period following
discharge, at least initially, because they
are in wide use and have gained
acceptance among hospitals and
because the AMI and CABG mortality
measures have been reviewed and
endorsed by the National Quality
Forum. However, we believe that 90
days is a period over which hospitals
have substantial ability to influence the
quality and efficiency of care that EPM
beneficiaries receive. Rather than
shorten EPM episodes to align with the
existing 30-day quality measure
timeframe as some commenters
recommended, we believe it would be
more appropriate to seek to adapt the
existing measures or to develop new
related measures to assess outcomes
over a longer timeframe, including
timeframes at least as long as the EPMs.
We refer to section III.E.4 of this final
rule for further discussion of our plans
regarding future quality measures that
could be incorporated into the EPM payfor performance methodologies.
Finally, we appreciate the perspective
of the commenters who believe that a
30-day episode duration would be more
appropriate because a longer episode
duration poses a greater risk for
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variability due to events outside the
intended scope of the model and control
of the hospital, including readmissions
to a different hospital, and that this risk
is higher for the EPMs than other
Innovation Center bundled payment
models due to the urgent or emergent
clinical conditions included in the
EPMs. We agree with the commenters
that the EPMs test different clinical
scenarios than the CJR model that
targets LEJR, which is primarily
elective, and that the complexity of
many EPM beneficiaries requires new
approaches to redesigning and
coordinating care for the 90 days posthospital discharge. While EPM
beneficiaries may be more likely to
develop a variety of complications
requiring more related services
following discharge than those in the
CJR model, we continue to believe that
complications most commonly have
patterns and bear a significant
relationship to the quality of care and
effectiveness of care coordination
following hospital discharge. Even
though some EPM beneficiaries may be
medically complex and fragile, we
continue to believe there are substantial
opportunities to improve the quality
and efficiency of their care under the
EPMs where EPM participants have
quality and cost performance
responsibility for episodes that extend
90-day post-discharge from the anchor
hospitalization. We also agree with the
commenters that EPM participants who
are required to participate in the EPMs
be protected from undue financial risk.
We refer to section III.D.4.b.(2) of this
final rule for further discussion of risk
adjustment under the EPMs.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposals in
§§ 512.240(a)(1), (b)(1), and (c)(1) for the
end of AMI, CABG, and SHFFT
episodes, respectively, based on an EPM
episode duration that extends 90 days
following discharge from the anchor
hospitalization, with modification to
revise § 512.240(a)(1) to eliminate
proposed paragraphs (a)(1)(i) and (ii)
and incorporate the 90-day postdischarge episode duration in the
general provision. We no longer need to
specify the episode duration separately
for an AMI episode that includes an
inpatient-to-inpatient transfer after an
AMI episode has been initiated because
we are not adopting the proposed
policies for chained anchor
hospitalizations. As discussed in section
III.C.4.a.(5). of this final rule, we are not
finalizing the AMI model transfer
episode initiation and attribution
proposal that would have required us to
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identify chained anchor
hospitalizations.
• Limits or adjustments to EPM
participants’ financial responsibility.
D. Methodology for Setting EPM Episode
Prices and Paying EPM Participants in
the AMI, CABG, and SHFFT Models
b. Key Terms for EPM Episode Pricing
and Payment
1. Background
a. Overview
We proposed that the AMI, CABG,
and SHFFT models would provide
incentives for EPM participants to work
with other health care providers and
suppliers to improve the quality and
efficiency of care for Medicare
beneficiaries by paying EPM
participants or holding them
responsible for repaying Medicare based
on EPM participants’ performance with
respect to the quality and spending for
AMI, CABG, and SHFFT episodes in a
manner similar to the CJR model. Given
the general similarity between the
design of the CJR model and these
EPMs, there is precedent for adopting
the general payment and pricing
parameters used under the CJR model,
with modification to appropriately pay
for EPM episodes that include the
different clinical conditions treated in
AMI, CABG, and SHFFT model
episodes. The following sections
describe our proposals for the:
• Performance year, retrospective
episode payments, and two-sided risk
EPMs.
• Adjustments to actual EPM-episode
payments and to historical episode
payments used to set episode prices.
• EPM episode price-setting
methodologies.
• Process for reconciliation.
• Adjustments for overlaps with other
Innovation Center models and CMS
programs.
For purposes of ease of understanding
of the technical discussion that follows
around EPM episode pricing and
payment, our proposed rule provided
the following definitions of terms that
were used in sections that precede their
technical definition and cross-references
to other sections of the proposed rule for
more detailed discussion of the policies
associated with these terms.
• Anchor hospitalization—
hospitalization that initiates an EPM
episode and has no subsequent
inpatient-to-inpatient transfer chained
anchor hospitalization.
• Chained anchor hospitalization—an
anchor hospitalization that initiates an
AMI model episode and has at least one
subsequent inpatient-to-inpatient
transfer.
• Anchor MS–DRG—MS–DRG
assigned to the first hospitalization
discharge, which initiates an EPM
episode.
• Price MS–DRG—for EPM episodes
without a chained anchor
hospitalization, the price MS–DRG is
the anchor MS–DRG. For AMI model
episodes with a chained anchor
hospitalization, the price MS–DRG is
the MS–DRG assigned to the AMI model
episode according to the hierarchy that
was described in III.D.4.b.(2)(i) of the
proposed rule.
• Episode benchmark price—dollar
amount assigned to EPM episodes based
on historical EPM-episode data (3 years
of historical Medicare payment data
grouped into EPM episodes according to
289
the EPM episode definitions as
discussed in sections III.C.3. and III.C.4.
of the proposed rule) prior to the
application of the effective discount
factor, as described throughout sections
III.D.4.b through e. of the proposed rule.
• CABG readmission AMI model
episode benchmark price—episode
benchmark price assigned to certain
AMI model episodes with price MS–
DRG 280–282 or 246–251 and with a
readmission for MS–DRG 231–236, as
described in sections III.D.4.b.(2)(c) and
III.D.4.e. of the proposed rule.
• Quality-adjusted target price—
dollar amount assigned to EPM episodes
as the result of reducing the episode
benchmark price by the EPM
participant’s effective discount factor
based on the EPM participant’s quality
performance, as described in sections
III.D.4.b.(10) and III.E.3.f. of the
proposed rule.
• Excess EPM-episode spending—
dollar amount corresponding to the
amount by which actual EPM-episode
payments for all EPM episodes
attributed to an EPM participant exceed
the quality-adjusted target prices for the
same EPM episodes, as discussed in
section III.D.2.c. of the proposed rule.
2. Performance Years, Retrospective
Episode Payments, and Two-Sided Risk
EPMs
a. Performance Period
Consistent with the methodology for
the CJR model, we proposed 5
performance years (PYs) for the EPMs,
which would include EPM episodes for
the periods displayed in the following
Table 9:
TABLE 9—PROPOSED PERFORMANCE YEARS FOR EPMS
Performance year
(PY)
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1
2
3
4
5
Calendar year
.................................
.................................
.................................
.................................
.................................
2017
2018
2019
2020
2021
EPM episodes included in performance year
EPM
EPM
EPM
EPM
EPM
As displayed in Table 9, some EPM
episodes that would begin in a given
calendar year may be captured in the
following performance year due to some
EPM episodes ending after December
31st of a given calendar year. For
example, EPM episodes beginning in
December 2017 and ending in March
2018 would be part of performance year
2. As we noted in our proposed rule, we
believe that the proposed period of time
for the EPMs, which generally aligns
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episodes
episodes
episodes
episodes
episodes
that
that
that
that
that
start on or after July 1, 2017 and end on or before December 31, 2017.
end between January 1, 2018 and December 31, 2018, inclusive.
end between January 1, 2019 and December 31, 2019, inclusive.
end between January 1, 2020 and December 31, 2020, inclusive.
end between January 1, 2021 and December 31, 2021, inclusive.
with the performance period for other
Innovation Center models, for example,
the CJR and Pioneer ACO models,
should be sufficient to test and gather
the data needed to evaluate the EPMs
(80 FR 73325). In contrast, we were
concerned whether an EPM with fewer
than 5 performance years would be
sufficient for these purposes.
We considered extending the first PY,
for example, to 18 months. As discussed
further in section III.D.2.c. of the
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proposed rule, however, we instead
proposed to delay the requirement for
participants to begin accepting
downside risk until the second quarter
of PY2. As such, EPM participants
would have a comparable transition
period to that of CJR participants with
respect to when they must accept
downside risk while still allowing us to
make timely reconciliation payments to
EPM participants as well as to most
effectively align EPM reconciliation
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with the reconciliation processes for
other models and programs with which
the EPMs overlap (for example, the
Shared Savings Program, Pioneer ACO
model, Comprehensive Primary Care
Initiative, and Oncology Care Model).
As stated in our proposed rule, we
believe that it is important to
synchronize the timing of reconciliation
for EPMs with other efforts that need
this information when making their
financial calculations. We sought
comment on this proposal.
The following is a summary of the
comments received and our responses.
Comment: Many commenters
requested that CMS delay
implementation of the models;
typically, for at least 6 months to a
year—or a year from the final rule’s
issuance—so that participants would
have a sufficient time to prepare for the
new models. Some commenters
recommended delaying the models
entirely until CMS had additional time
to consider evaluation results for BPCI
or the CJR model. Other commenters
recommended a phased-in approach for
implementing the models, for example,
by (1) first implementing the SHFFT
model no sooner than January 1, 2018
and then implementing the cardiac EPM
models no sooner than 6 months later as
well as additional time if the final rule
is delayed beyond January 1, 2018 or (2)
conversely delaying the SHFFT model,
given that hospitals are in the early
stages of building infrastructure for the
CJR model and having to do so for the
SHFFT model as well could be too great
a burden. A commenter recommended
that CMS delay the start date to January
1, 2018 as it would better align with
private payers’ regulatory and business
models, which are also developing and
rolling out bundled payment models. In
their view, this synchronization would
reduce burden by simplifying record
keeping requirements, performance
metric submission, and financial
tracking by both CMS and private
payers.
Among the reasons cited for a delay,
some commenters expressed concern
with the rapid pace of implementing
additional models—particularly,
geographic-based models, which a
number of commenters have said they
oppose. For example, commenters
expressed concerns that CMS was
moving forward with new models in the
absence of empirical results from the
CJR model or promising results from
BPCI. Specifically, results from the
evaluation of year 2 results for BPCI
showed no statistically significant
difference in Medicare payments and an
increase in mortality for the
cardiovascular surgical episodes
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between the BPCI participants (which
were voluntary), and comparison
groups. Further, while there was a
significant reduction in utilization of
institutional post-acute care settings,
there were instances where BPCI
patients exhibited less functional
improvement. As one commenter noted,
CMS has not yet been able to ensure that
the quality of care and beneficiary
outcomes under the model are at least
equivalent, if not better than, those in
traditional fee-for-service Medicare.
Commenters also pointed to the preimplementation efforts that would be
needed for participants to be successful
with episode payment bundles, which
they believe would take more time than
would be granted under the proposal.
For example, hospitals need more time
than proposed to better understand the
models’ requirements and clinical and
financial risk of their patient
populations; build the clinical, legal,
financial and quality infrastructure;
analyze and understand the clinical and
cost factors that affect their
performance; and identify changes to
care pattern to be successful. Moreover,
there is considerable variation in
hospital preparedness and capabilities
to implement these models without a
delay as well as challenges in doing so
while simultaneously fulfilling the
requirements of multiple models
including the CJR model, MACRA, and
the end of the grace period for ICD–10.
A commenter noted that, given the
broad-based clinical experience with
continuity-of-care across episodes,
appropriate workforce capacity and
technology infrastructure, and
significant investment by both the
public and private sectors needed to be
successful, the cardiac models could be
particularly challenging. Further, these
challenges could be especially acute for
small hospitals that often have limited
financial resources, have low case
volume across which to spread financial
experience, have high amounts of
uncompensated care or are located in
lower income geographic regions, do not
yet have experience with episode-based
payments, or lack existing networks
with physicians and other providers. In
addition to provider readiness, a
commenter questioned whether CMS
has the administrative and personal
resources to manage the complexities of
the newly proposed and expanded
models in a way that would meet
hospitals’ needs to be successful under
the models. Another commenter
believed that, despite CMS proposing
certain waivers under the models,
insufficient protections existed with
regard to regulatory and legal risk.
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Response: We appreciate the concerns
commenters expressed on our proposed
start date as well as their requests to
delay the proposed models. Our general
goals for the proposed models are to
improve care quality for Medicare
beneficiaries and efficiency in service
delivery to better control growth in
Medicare spending. Hence, we wish to
move forward in implementing the
proposed models as quickly as is
reasonably possible. Many commenters
expressed concerns about their
readiness to participate in the models
under our proposal; particularly, with
the requirement to assume downside
risk within 6 months of the models
being implemented. We understand
these concerns and share in hospitals’
desire to be successful in improving
care and increasing efficiencies under
the models so that they earn
reconciliation payments and Medicare
and its beneficiaries realize
improvements in care and efficiency.
Thus, while we are not proposing to
delay implementation of the models, as
discussed in section III.D.2.c. of this
final rule, we are modifying our
proposal requiring participants to
assume downside risk in the second
quarter of PY2 so that they would have
an additional 9 months of experience in
the models without assuming downside
risk. EPM participants would not be
required to assume downside risk for
episodes until PY3, but could
voluntarily elect to do so in PY2. We
believe that delaying the requirement
for participants to assume downside risk
under the models appropriately
balances our interests in implementing
the models in a timely way with the
concerns and interests of participants
with respect to their readiness to
participate successfully in the models as
well as accommodate to the proposed
requirements in conjunction with other
requirements under the Medicare
program. As such, we do not believe it
is also necessary to further delay or
phase-in the models. Likewise, we do
not believe it is necessary to delay our
models so that they are better aligned
with private payer models. We would
further note that, beginning in PY2, our
proposed models would already follow
the period suggested for this alignment
to occur.
We do not agree with commenters
that the models should be delayed until
additional BPCI or CJR model results are
considered or in light of the BPCI year
2 results. The currently proposed
models will test geographic-based
bundled payments with a broader, more
diverse, and different group of
participants or episodes than is the case
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with BPCI or the CJR model, which will
expand our understanding of these
models with a broader and more
complex array of conditions and
procedures. We also do not believe that
the unique challenges that could be
presented under the cardiac models is a
reason to delay the models. Rather,
among other things, we would expect
these models to assist us in empirically
identifying what challenges there may
be as well as the steps needed to
overcome them. We also share
commenters’ concerns that smaller
hospitals be successful under the
models. Accordingly, our proposed rule
included additional protections to limit
financial risk for certain hospitals,
including rural hospitals and sole
community hospitals, through more
generous stop loss thresholds, which we
finalized in section III.D.7.c.(1) of this
final rule. Also, as discussed further in
section III.D.7.c.(1) of this final rule, we
are extending these protections to
hospitals determined to have a low
volume of episodes under an EPM.
We appreciate the comment on
whether CMS is prepared
administratively and with respect to
personnel resources to implement the
models, and note that the proposed
models would not be implemented in
the absence of our readiness to do so.
Finally, we have considered and made
final a range of waivers of program rules
291
and provisions for financial
arrangements that we believe are
necessary and sufficient to facilitate
participation in the models through
allowing additional flexibilities in care
delivery and giving participants to the
tools to align the financial incentives of
other providers, suppliers, and ACOs
with the goals of the EPMs (see sections
III.I. and III.J. of this final rule).
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal, without
modification, to establish five
performance years beginning with EPM
episodes that start on or after July 1,
2017 as displayed in Table 10.
TABLE 10—FINAL PERFORMANCE YEARS FOR EPMS
Performance year
(PY)
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1
2
3
4
5
Calendar year
.................................
.................................
.................................
.................................
.................................
2017
2018
2019
2020
2021
EPM episodes included in performance year
EPM
EPM
EPM
EPM
EPM
b. Retrospective Payment Methodology
Consistent with the CJR model (80 FR
73329), we proposed to apply a
retrospective payment methodology to
the proposed EPMs (81 FR 50844).
Under this proposal, all providers and
suppliers caring for Medicare
beneficiaries in EPM episodes would
continue to bill and be paid as usual
under the applicable Medicare payment
systems. After the completion of an
EPM performance year, Medicare claims
for services furnished to EPM
beneficiaries would be grouped into
EPM episodes and aggregated, and EPM
participants’ actual EPM episodepayments would be compared to
quality-adjusted target prices (which
account for the level of EPM episode
quality), as described in section
III.D.5.a. of the proposed rule (81 FR
50864 through 50865). Based on an EPM
participant’s performance (taking into
account quality and spending), we
would determine if Medicare would
make a payment to the participant
(reconciliation payment), or if the
participant owes money to Medicare
(resulting in Medicare repayment).
We considered an alternative option
of paying for EPM episodes
prospectively by paying one lump sum
amount to the EPM participant for the
expected spending for the EPM episode
which extends 90 days post-hospitaldischarge. However, as was the case
when we established regulations for the
CJR model (80 FR 73329), we believed
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episodes
episodes
episodes
episodes
episodes
that
that
that
that
that
start on or after July 1, 2017 and end on or before December 31, 2017.
end between January 1, 2018 and December 31, 2018, inclusive.
end between January 1, 2019 and December 31, 2019, inclusive.
end between January 1, 2020 and December 31, 2020, inclusive.
end between January 1, 2021 and December 31, 2021, inclusive.
that such an option would be
challenging to implement at this time
given the payment infrastructure
changes for both EPM participants and
Medicare that would need to be
developed to pay and manage
prospective episode payments under
these EPMs. Moreover, we continued to
believe that a retrospective payment
approach can accomplish the objective
of testing episode payments in a broad
group of hospitals, including financial
incentives to streamline care delivery
around that episode, without requiring
core billing and payment changes by
providers and suppliers, which would
create substantial administrative
burden.
We sought comment on this proposal.
The following is a summary of the
comments received and our responses.
Comment: Most of the comments
supported CMS’ proposal to use a
retrospective payment methodology.
Commenters agreed with CMS’ view
that this would be the most
administratively feasible and
straightforward payment option since it
uses the existing payment system
infrastructure and processes. Some of
these commenters reported that
alternatively applying a prospective
payment methodology, which would
make one lump sum payment to the
hospital for the episode, would be
challenging to implement given the
administrative and infrastructure
changes it would entail for hospitals,
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other participating providers and
Medicare. One commenter expressed
concern that our proposed models
would, in fact, require all payments be
made to the responsible hospital so that
other providers would have to submit
bills for services they provided under an
EPM episode to that hospital, which the
commenter believed could result in both
decreased access to care and increased
administrative complexity.
Response: We appreciate the
comments we received that were in
support of our proposed retrospective
payment methodology, and concur with
commenters’ views on some of the
benefits of this model. We would clarify
that, as stated previously in this section,
all providers and suppliers caring for
Medicare beneficiaries in EPM episodes
would continue to bill and be paid as
usual under the applicable Medicare
payment systems. As such, providers
would submit claims for payment as
they always have and would not submit
claims to the responsible hospital.
Comment: While not opposing the
proposal, a commenter expressed the
view that a retrospective model should
be viewed as a stepping stone toward
rather than the destination to requiring
greater levels of financial risk. In their
view, disadvantages of a retrospective
model include their potential to reduce
spending within an episode of care but
not the volume of the episodes
themselves, which could encourage a
greater number of bundled procedures;
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fragmentation of care delivery due to the
existence of multiple bundled payment
programs designed around different
disease states or procedures; and the
potential that the considerable cost and
effort expended to organize people and
systems around each bundled episode
could cause the total cost of these
programs combined to be higher than
the cost associated with operating a
single program covering the full
population and the full spectrum of
care. As such, the commenter supported
the proposed bundled payments for a
limited time and for the purpose of
stimulating efforts to full population
based efforts.
Response: We understand the
commenter’s view that bundled
payments could be a stepping stone
toward other models that establish
greater risk for providers and recognize
the various limitations of a fee-forservice system with respect to higher
volume of services and less coordinated
delivery of care. In contrast to the
commenter, however, we believe in and
hence are empirically testing within our
proposed models the potential to
improve upon these dimensions as well
as assist in lowering the cost of services
within a fee-for-service rather than
capitated framework.
Comment: Some commenters opposed
the proposed retrospective
methodology. For example, a
commenter reported their view that the
proposed retrospective payment model
would limit the possibility for real,
innovative care redesign because it (1)
offered no upfront incentive dollars to
invest in new care delivery models and
services that could deliver true value
and (2) confined innovation care
redesign by what the FFS structure will
reimburse. That is, while participants
would be held financially accountable
for ensuring that care is delivered below
the quality-adjusted target price, they
could do little to affect the costs for the
episode within their own setting as they
continue to receive a MS–DRG payment
for the diagnosis regardless of whether
the patient stays a longer or shorter
period of time, additional services are
offered, or care coordination is
provided. Thus, if a participant seeks to
reduce costs, it is limited to reducing
readmissions, improving care
transitions, or reducing post-acute care
costs—either by reducing the length of
stay within a SNF (as it is paid on a per
diem) or through substitutions of care
(for example, directly discharging the
patient home with or without services).
In this commenter’s view, significant
care redesign would be better facilitated
through providing a group of provider
partners with a prospective payment.
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Similarly, a commenter suggested that
participants are impeded in their ability
to plan for the delivery of services if
they do not know how much money
will be available to support those
services. As such, participants should
have a risk-adjusted budget for the
condition or episode in advance rather
than after care has already been
delivered. Further, payment amounts
should be based on the actual costs of
all of the services being delivered, not
just the amounts that would have been
paid under the fee-for-service system for
the subset of services that would have
been separately billable. As such, the
commenter recommended that
participants and their collaborators be
paid for high-value services that are not
currently billable as part of conditionbased and episode-based payment
models if providers have agreed to be
accountable for overall spending related
to a condition or episode.
Another commenter recommended
that CMS determine payment
benchmarks through negotiated rates or
competitive bids (rather than fee-forservice claims) as it would foster more
rapid transformation in cost and
resource use as well as encourage
competition among providers to achieve
the best outcomes for the lowest cost. In
their view, a prospective negotiated rate
would offer providers more opportunity
to innovate in how they deploy
professional staff, choose technology,
and engage with outpatient and homebased services. Also, a prospectively
negotiated case rate would foster
collaboration among all clinicians
involved in patient care and provide
predictable pricing.
Response: We appreciate the concerns
and challenges raised by these
commenters, but are not persuaded to
change our methodology. Rather, we
believe that participants are capable of
innovative care redesign in the absence
of upfront incentives dollars and within
the constraints of fee-for-service
Medicare payment requirements. While
our proposal did not provide
participants with an up-front budget or
a capitated payment amount, we would
be providing them detailed information
on their benchmark and likely qualityadjusted target prices as well as their
financial performance both historically
and during their participation in the
models (see section III.K. of this final
rule). We believe this information
should be sufficient to enable
participants’ abilities to assess their
performance as well as determine and
plan changes in their practices to make
them successful. Also, where
appropriate, we have offered
participants improved flexibilities
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under the models by waiving certain
Medicare requirements and allowing for
financial arrangements, which should
facilitate their participation under the
models (see sections III.I. and III.J. of
this final rule). To the extent, we
identify additional adjustments, we
could consider them through future
rulemaking. Finally, while we wish to
explore and test a range of payment
models, which could include capitated
or competitive bidding models, the
purpose of the proposed models is to
examine ways in which to improve
health care quality and reduce costs in
a fee-for-service framework.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal, without
modification to implement a
retrospective payment methodology.
Also, we would like to clarify that when
referring to Medicare claims data for
services furnished to EPM beneficiaries,
as we have stated immediately here and
throughout this section, we mean any
payment from the Part A or Part B trust
fund on behalf of a beneficiary that is
not specifically excluded as specified in
section III.C. or III.D.6 of this final rule.
Consistent with this, we have made
conforming changes to our regulatory
text—specifically, to our definition of
actual episode payments as well as to
§ 512.305(c)(1) and § 512.307(a)(1).
c. Two-Sided Risk EPMs
As we did for the CJR model (80 FR
73229 through 7333), we proposed to
establish two-sided risk for EPM
participants (81 FR 50844). Under this
proposal, for each of performance years
1 through 5, we would make EPMepisode reconciliation payments to EPM
participants that achieve reduced actual
EPM payments relative to their qualityadjusted target prices. Likewise,
beginning with episodes ending in the
second quarter of performance year 2
and extending through each of
performance years 3 through 5, we
would hold EPM participants
responsible for repaying Medicare when
their actual EPM-episode payments
exceed their quality-adjusted target
prices. As such, our proposal differed
from CJR in that we proposed a
modestly shorter period in which EPM
participants would accept downside
risk in order to allow them a comparable
transition period to that of CJR
participants in which to do so.
Accordingly, we referred to the two
portions of performance year 2 as either
having no downside risk (NDR) or
having downside risk (DR);
specifically—
• Performance Year 2 (NDR) or PY 2
(NDR) for the first quarter, that is
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January 1, 2018 to March 31, 2018, in
which EPM participants assume no
downside risk and therefore would have
no Medicare repayment responsibility;
and
• Performance Year 2 (DR) or PY 2
(DR) for the second, third and fourth
quarters, that is April 1, 2018 to
December 31, 2018, in which EPM
participants assume downside risk and
would have Medicare repayment
responsibility.
Our proposed rule noted our
continued belief that our proposal to
establish two-sided risk would provide
appropriate incentives for EPM
participants to improve their care
quality and efficiency under the EPMs,
and that we would diminish these
incentives if we instead proposed to
establish one-sided risk, in which an
EPM participant could qualify for a
reconciliation payment but not be held
responsible for Medicare repayments. In
recognition that EPM participants may
need to make infrastructure, care
coordination and delivery, and financial
preparations for the EPMs, which can
take several months or longer to
implement, we thought that it was
reasonable to delay EPM participant
responsibility for repaying excess EPMepisode spending in performance year 1
to more strongly align EPM-participant
incentives with care quality. Thus,
similar to what we did for the CJR
model, we proposed to phase-in this
repayment responsibility beginning in
the second quarter of EPM performance
year 2 as displayed in Table 11 (81 FR
50844 through 50845).
TABLE 11—PROPOSED STOP-LOSS THRESHOLDS AND DISCOUNT PERCENTAGE RANGES FOR MEDICARE REPAYMENTS BY
PY
Performance year
Stop–loss threshold .................................
PY2
(DR)
(%)
PY2
(NDR)
PY1
n/a as no downside risk in PY1
or first quarter of PY2
PY3
(%)
PY4
(%)
PY5
(%)
10
20
20
0.5–2.0
Discount percentage (range) for Repayment, Depending on Quality Category
5
0.5–2.0
1.5–3.0
1.5–3.0
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* Stop-loss thresholds for certain hospitals, including rural and sole-community hospitals are 3% for PY2 (DR) and 5% for PY3–PY5.
We refer to section III.E.3.f. of this
final rule for additional information on
the effective discount factors used to
calculate quality-adjusted target prices,
as well as the quality categories that
determine an EPM participant’s
effective discount factor that would be
applied to the EPM benchmark episode
price at reconciliation to calculate the
repayment amount during the phase-in
period under the models.
We sought comment on this proposal.
The following is a summary of the
comments received and our responses.
Comment: A number of commenters
supported CMS’ proposal to phase-in
downside risk noting that doing so
would allow providers with little or
limited experience and who were not
ready to take on risk additional time to
prepare to do so. However, nearly all of
the commenters on this proposal urged
CMS to extend the period of time during
which participants would not be subject
to downside risk as 6 months would not
be an adequate timeframe in which to
begin managing episodes that will be
subject to downside risk. A number of
commenters noted that because of the
way that episodes are defined during a
performance year, participants would
actually have only 6 months before
episodes that will incur downside risk
begin. This is because the models would
begin on July 1, 2017 and downside risk
would begin for episodes ending April
1, 2018 and later. However, episodes
that end April 1, 2018 would have
begun over 90 days earlier, or prior to
January 1, 2018. Therefore, participants
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would actually only have from July 1,
2017 until about January 1, 2018 before
episodes that will incur downside
begin.
Most of the commenters requested a
12-month period during which
participants would not be required to
assume downside risk with some
commenters requesting longer periods,
for example, up to 2 years. In some
cases, commenters requested that CMS
delay the requirement to assume
downside risk, but to allow participants
flexibility to assume risk earlier if they
wished to do so. A commenter
requested that CMS stagger downside
risk across the models, for example,
allow a longer period without downside
risk for AMI episodes than for CABG
episodes as the commenter believed
there was greater complexity and
uncertainty associated with the former
than the latter. Additionally, several
commenters opposed the proposal to
require downside risk altogether or
asking that CMS make this requirement
contingent upon also further riskadjusting target prices and financial
performance data.
The reasons offered for delaying
downside risk often paralleled those for
delaying the models in general—that is,
additional time is needed to develop
infrastructure and expertise with the
models. Some commenters raised
concerns about the effects of the
proposal on beneficiary access;
particularly, for smaller hospitals and
academic medical centers. As such, a
commenter expressed support for CMS’
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plans to monitor access and
recommended that CMS publish data
and consider alternatives if this is found
among complicated AMI or CABG cases.
A commenter suggested that CMS
completely waive downside risk for
certain protected hospitals such as
SCHs, MDHs, RRCs, and low-volume
hospitals. Another commenter stated
that participants should not have to take
on additional risk given they are already
facing payment reductions through
other efforts such as those for the HRRP.
If participants must face downside risk
through the proposed models, the
commenter requested that CMS exclude
conditions under the model from the
HRRP. Some commenters pointed to
delays in receiving performance data
from CMS as well as time need to
review these data needed to assist them
in assessing and adjusting care patterns.
Commenters also noted that because not
all participants have had experience
with bundled payment models, they are
likely not ready to assume downside
risk.
In addition to comments requesting
that CMS delay downside risk,
commenters also requested that EPM
participants be permitted to voluntarily
adopt downside risk sooner, for
example, to fulfill one of the
requirements to qualify as participating
in an Advanced APM.
Response: We appreciate comments
supporting our proposal to phase-in
downside risk. We are also persuaded
by commenters that delaying the date by
which participants would be required to
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assume downside risk would improve
participants’ ability to successfully
achieve the goals of the models.
Accordingly, we are revising our
proposal so that participants in the
proposed models would not be required
to assume downside risk until PY3—
that is, episodes ending on or after
January 1, 2019, with anchor discharges
that occur on or after October 4, 2018.
We believe that this delay period
appropriately balances participants’
desire for additional experience under
the models in the absence of downside
risk with our desire to establish
appropriate incentives for improved
care quality and cost control. Given we
believe this delay period is sufficient for
all models, we do not believe it
necessary to stagger downside risk
separately by model. We also disagree
with comments opposing our proposal
to require downside risk or asking that
CMS make this requirement contingent
upon our also further risk-adjusting
target prices and financial performance
data. First, we believe downside risk is
necessary for purposes of establishing
appropriate provider incentives.
Second, as discussed in section
III.D.4.b.(2). of this final rule, we plan to
explore additional risk-adjustment
options that could be implemented
beginning in PY3 and would thus apply
to episodes that would be subject to
downside risk for all participants.
While we are delaying the
requirement to assume downside risk
under the models, we have decided to
allow EPM participants, including those
seeking to qualify as participating in an
Advanced APM, to voluntarily begin to
assume downside risk for episodes
ending on or after January 1, 2018, with
anchor discharges that occur on or after
October 4, 2017. Table 12 presents our
final policies for phasing-in downside
risk for all participants, along with
associated stop-loss limits and discount
percentages, for participants that
voluntarily assume risk on this
accelerated schedule.
We appreciate the concerns raised on
the potential effects of our proposal on
beneficiary access to care, and would
note that we have made final a range of
quality measures (see section III.E. of
this final rule), monitoring activities
(see section III.G. of this final rule), and
compliance efforts (see section III.F. of
this final rule) that would address
beneficiary access issues. We disagree
with the suggestions to waive downside
risk for certain protected hospitals such
as SCHs, MDHs, RRCs, and low-volume
hospitals or given that hospitals are
already facing payment reductions
through other efforts. We believe that
the additional protections we included,
which limit total financial risk under
the models for these protected hospitals,
are sufficient (see section III.D.7.c.(2). of
this final rule). We also recognize that
while a participant could experience
payment reductions under both the
proposed models and the HRRP, we
disagree that they should be held
harmless from either of these potential
reductions. The payment reductions
participants would potentially face
under the proposed models are not
dissimilar to the potential reductions
hospitals already simultaneously face
for programs such as the HRRP, HAC,
and EHR incentives without exemption.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal, with
modification, to phase-in downside risk.
Accordingly, we are delaying the
requirement to assume downside risk by
9 months so that episodes ending on or
after January 1, 2019 would assume
downside risk as compared to our
proposal that would have required this
for episodes that ended on or after April
1, 2018 and beyond. Also, we are
allowing participants to voluntarily
elect downside risk for episodes ending
on or after January 1, 2018. Table 12
presents our final policies on this in
conjunction with modified stop-loss
thresholds and discount percentages by
performance year. These final policies
are further discussed in sections
III.D.7.b.(1), III.D.7.c.(1) and III.E.3.f of
this final rule, respectively.
TABLE 12—FINAL STOP-LOSS THRESHOLDS AND DISCOUNT PERCENTAGE RANGES FOR MEDICARE REPAYMENTS BY PY
PY2
(%)
PY1
PY3
(%)
PY4
(%)
PY5
(%)
Downside Risk for All Participants—DR effective for episodes ending on or after 1/1/2019
(anchor discharges occurring on or after 10/4/2018)
Stop-loss threshold ..............................................................
n/a as no downside risk in PY1
and PY2 without election of
voluntary downside risk for
PY2
10
20
3
5
5
0.5–2.0
Stop-loss threshold for certain hospitals * ...........................
Discount percentage (range) for Repayment, Depending
on Quality Category .........................................................
5
0.5–2.0
1.5–3.0
Voluntary Downside Risk—DR effective for episodes ending on or after 1/1/2018
(anchor discharges occurring on or after 10/4/2017)
Stop-loss threshold ..............................................................
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Stop-loss threshold for certain hospitals * ...........................
Discount percentage (range) for Repayment, Depending
on Quality Category .........................................................
n/a as no
downside risk
in PY1
........................
5
5
10
20
3
3
5
5
........................
0.5–2.0
0.5–2.0
0.5–2.0
1.5–3.0
* Including rural and sole-community hospitals, rural referral centers, Medicare Dependent Hospitals and hospitals determined to be EPM volume protection hospitals within an EPM.
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3. Adjustments to Actual EPM-Episode
Payments and to Historical Episode
Payments Used To Set Episode Prices
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a. Overview
Using Medicare payments for Parts A
and B claims for services included in
the EPM episode definitions, we
proposed to calculate historical episode
payments (3 years of historical Medicare
payment data grouped into EPM
episodes), EPM-quality-adjusted target
prices, and actual EPM-episode
payments according to the EPM episode
definitions as discussed in sections
III.C.3. and III.C.4. of the proposed rule
(81 FR 50829 through 50843) as we did
for the CJR model. As was the case for
the CJR model (80 FR 73330 through
73336), we also proposed to include
certain payment adjustments in the
EPMs for: (1) Special payment
provisions under existing Medicare
payment systems; (2) payments for
services that straddle episodes; and (3)
high payment episodes (81 FR 50846).
We also proposed to additionally
include an adjustment for reconciliation
payments and Medicare repayments
when updating EPM participant episode
benchmark and quality-adjusted target
prices (81 FR 50847). We refer to section
III.D.6. of the proposed rule for
discussion of adjustments for overlaps
with other Innovation Center models
and CMS programs (81 FR 50867
through 50872).
b. Special Payment Provisions
Many of the existing Medicare
payment systems have special payment
provisions that have been created by
regulation or statute to improve quality
and efficiency in service delivery. IPPS
hospitals are subject to incentives under
the HRRP, the HVBP Program, the
Hospital-Acquired Condition (HAC)
Reduction Program, and the HIQR
Program and Outpatient Quality
Reporting (OQR) Program. IPPS
hospitals and CAHs are subject to the
Medicare Electronic Health Record
(EHR) Incentive Program. Additionally,
the majority of IPPS hospitals receive
additional payments for Medicare
Disproportionate Share Hospital (DSH)
and Uncompensated Care, and IPPS
teaching hospitals can receive
additional payments for Graduate
Medical Education (GME) and Indirect
Medical Education (IME). IPPS hospitals
that meet certain requirements related to
low volume Medicare discharges and
distance from another hospital receive a
low volume add-on payment. Also,
some IPPS hospitals qualify to be sole
community hospitals (SCHs) or
Medicare Dependent Hospitals (MDHs),
and they may receive enhanced
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payments based on cost-based hospitalspecific rates for services; whether a
SCH or MDH receives enhanced
payments may vary year to year, in
accordance with § 419.43(g) and
§ 412.108(g), respectively.
Medicare payments to providers of
post-acute care services, including IRFs,
SNFs, IPFs, HHAs, LTCHs, and hospice
facilities, are conditioned, in part, on
whether the provider satisfactorily
reports certain specified data to CMS:
Inpatient Rehabilitation Facility Quality
Reporting Program (IRF QRP); Skilled
Nursing Facility Quality Reporting
Program (SNF QRP); Inpatient
Psychiatric Facility Quality Reporting
Program (IPF QRP); Home Health
Quality Reporting Program (HH QRP);
Long-Term Care Hospital Quality
Reporting Program (LTCH QRP); and
Hospice Quality Reporting Program.
Additionally, IRFs located in rural areas
receive rural add-on payments, IRFs
serving higher proportions of lowincome beneficiaries receive increased
payments according to their low-income
percentage (LIP), and IRFs with teaching
programs receive increased payments to
reflect their teaching status. SNFs
receive higher payments for treating
beneficiaries with human
immunodeficiency virus (HIV). HHAs
located in rural areas also receive rural
add-on payments.
Ambulatory Surgical Centers (ASCs)
have their own Quality Reporting
Program (ASC QRP). Physicians also
have a set of special payment provisions
based on quality and reporting:
Medicare EHR Incentive Program for
Eligible Professionals; Physician Quality
Reporting System (PQRS); and
Physician Value-based Modifier
Program.
Consistent with how we determine
payments under the CJR model (80 FR
73333), we proposed to adjust both the
actual and historical EPM-episode
payments used to set EPM-episode
benchmark and quality-adjusted target
prices by excluding these special
payments from EPM-episode
calculations using the CMS Price
Standardization methodology (81 FR
50846). Our proposed rule noted our
view that in applying this methodology
to exclude these payments from our
calculations, we would best maintain
appropriate incentives for both the
EPMs and the existing incentive
programs. Also, not excluding add-on
payments based on the characteristics of
providers caring for EPM beneficiaries,
such as more indigent patients, having
low Medicare hospital volume, being
located in a rural area, supporting
greater levels of physician training, and
having a greater proportion of
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295
beneficiaries with HIV, from actual
EPM-episode payments could
inappropriately result in certain EPM
participants that receive more add-on
payments having worse episode
payment performance compared to
quality-adjusted target prices than what
their performance would otherwise have
been. Additionally, not excluding
enhanced payments for MDHs and SCHs
could result in higher or lower qualityadjusted target prices just because EPM
participants received their enhanced
payments in 1 historical year but not the
other, regardless of actual utilization.
We also noted that excluding special
payments would ensure an EPM
participant’s actual episode payment
performance is not artificially improved
or worsened because of payment
reduction penalties or incentives or
enhanced or add-on payments, the
effects of which we were not intending
to test under the models. In addition to
the various incentives, enhanced
payments, and add-on payments, we
noted that sequestration came into effect
for Medicare payments for discharges on
or after April 1, 2013, per the Budget
Control Act of 2011 and delayed by the
American Taxpayer Relief Act of 2012.
Sequestration applies a 2-percent
reduction to Medicare payment for most
Medicare FFS services.
For more information on the CMS
Price (Payment) Standardization
Detailed Methodology, we referred to
the QualityNet Web site at https://
www.qualitynet.org/dcs/
ContentServer?c=Page&pagename=
QnetPublic%2FPage%2FQnet
Tier4&cid=1228772057350 and to 80 FR
73331. Accordingly, we proposed to
exclude these special payments from
EPM-episode calculations using the
CMS Price Standardization
methodology at § 512.300(e)(2). We
sought comment on our proposal to
exclude special payments using the
CMS Price Standardization
methodology.
The following is a summary of the
comments received and our responses.
Comment: Commenters generally
supported the proposal to adjust actual
and target spending amounts for various
special payments such as IME and DSH.
Response: We appreciate the
comments we received supporting our
proposal to exclude special payments
from EPM-episode calculations using
the CMS Price Standardization
methodology. We wish to clarify that
like CJR, we will follow the CMS Price
Standardization methodology with
modifications as necessary to be
consistent with our episode definition
in section III.C of this final rule and to
ensure timely reporting of reconciliation
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results, for the performance year
reconciliations, which begin 2 months
after the conclusion of a performance
year. We will account for the
information available at the time due to
claims run-out, payment system
updates, and the calculations necessary
to fully implement the standardization
methodology. We will utilize the
methodology, consistent with our
episode definition, for the target price
calculations and subsequent
reconciliation calculations 14 months
after the conclusion of the performance
year, in which we incorporate full
claims run-out and further account for
overlap with other models. This
approach will provide feedback and
reconciliation payments, as available, to
hospitals in a timely manner and as
accurately as feasible, while ensuring
the standardization approach is utilized
for the subsequent reconciliation
calculation for a performance year.
Comment: Commenters requested
more clarity on whether IPPS capital
payments are included, and requested
that we exclude these costs. A
commenter noted that these capital
costs are not included under the BPCI
models, hospitals need stability in
capital cost reimbursement to plan for
major capital expenditures, and thus
these costs should not be placed at risk
because of models affecting only
cardiovascular and orthopedic services.
Response: To clarify, as is the case
with CJR, IPPS capital payments will be
included in EPM-episode calculations.
As we stated in the CJR Final Rule (80
FR 73333), these payments are included
in Medicare FFS payments, which we
use to calculate benchmark and actual
expenditures. Further, including IPPS
capital payments affords participants an
opportunity to achieve greater
reconciliation payments if they are able
to achieve efficiencies for the costs that
the capital portion of IPPS payments
would cover, which may or may not
actually be capital costs.
Comment: A commenter requested
that CMS exclude outlier payments
EPM-episode calculations. The
commenter expressed concern that
because CMS proposed a limited riskadjustment methodology, hospitals that
treat the least healthy beneficiaries such
as academic medical centers would be
penalized for longer lengths of stay that
result in receiving outlier payments for
the index admission, particularly as
financial targets transition to regional
pricing.
Response: We disagree that outlier
payments should be excluded from our
calculation. First, we expect the models
to encourage more efficient care that
should result in lower costs and
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potentially the frequency for which
outlier payments are needed. Second, as
discussed in section III.D.3.d. of this
final rule, we are finalizing policies to
cap high-cost episodes with payments 2
standard deviations or more above the
mean calculated at the regional level for
purposes of determining benchmark
prices and actual expenditures, which
should assist in protecting participants
from higher costs associated with outlier
payments. Third, as discussed in section
III.D.4.b.(2). of this final rule, we will be
exploring options to further risk-adjust
costs and payments under the models
with the goal of making them effective
for episodes ending after January 1,
2019, with anchor discharges occurring
on or after October 4, 2018. These
further adjustments for risk would offer
additional financial protections to
participants with high-cost episodes.
Comment: Several commenters
recommended that costs for chronic care
management, cardiac rehabilitation, and
intensive cardiac rehabilitation services
be excluded from payment calculations.
With regard to the former, the
commenter noted that chronic care
management services were not paid
under Medicare until January of 2015
and therefore was not a payable service
during two of the years used to set target
prices for the first two performance
year. Further, in this commenter’s view,
many physicians currently are not
billing for these services, but the
commenter anticipates the volume will
increase. With regard to the latter,
commenters noted that if the proposed
efforts to encourage CR utilization are
successful, spending for CR/ICR services
in AMI and CABG episodes would
increase and could cause participants’
spending to exceed their targets making
them either ineligible to receive
reconciliation payments or at risk for
making Medicare repayments. As such,
this would penalize hospitals for
improving CR/ICR utilization, which
would impede, if not completely defeat,
CMS’ efforts to encourage CR and ICR
utilization. Accordingly, these
commenters recommended that the cost
of CR and ICR services be excluded from
episode payment calculations.
Response: As we noted in section
III.C.3.b. of this final rule, we do not
believe that it would be appropriate to
exclude other specific Part B services,
including chronic are management
services, cardiac rehabilitation,
intensive cardiac rehabilitation services
that are related to the clinical conditions
that are the basis for EPM episodes, just
because they are underrepresented in
the baseline period upon which
benchmark episode prices are set.
Likewise, we do not believe it is
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appropriate to exclude the costs of these
included services from our financial
calculations. To the extent that care
redesign under the EPMs increases
utilization of these services to improve
episode quality and efficiency, periodic
updates to the 3 years of historical data
used to establish EPM-episode
benchmark prices, as is discussed in
section III.D.4.b.(3) of this final rule,
would result in greater representation of
these services that reflect more recent
care patterns.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal, without
modification, to exclude certain special
payments from EPM-episode
calculations using the CMS Price
Standardization methodology. Our final
policy for excluding special payments is
included in § 512.300(e)(2).
c. Services That Straddle Episodes
A service that straddles an EPM
episode is one that begins before the
start of or continues beyond the end of
an EPM episode that extends 90 days
post-hospital discharge. Under the CJR
model, we prorate payments so that they
include only the portion of the payment
that is included in the CJR model
episode, using separate approaches to
prorate payments under each payment
system, for example, IPPS, non-IPPS
and other inpatient services, and home
health services (80 FR 73333 through
73335). We proposed to apply the CJR
model methodologies for prorating
payments when calculating actual EPMepisode payments and when calculating
historical EPM-episode payments used
to set EPM-episode benchmark and
quality-adjusted target prices (81 FR
50846). We believed these
methodologies would most accurately
account for spending within EPM
episodes under the EPMs. The
methodologies for prorating payments
under the EPMs were included in
§ 512.300(f). We sought comment on our
proposed methodologies for prorating
payments.
The following is a summary of the
comments received and our responses.
Comment: We received comments
requesting greater clarity on how we
would prorate payments for services
that straddle episodes. We also received
a comment requesting greater clarity for
‘‘prorated’’ payments for ‘‘straddled’’
episodes with the presence of an AMI
diagnosis treated with CABG.
Response: Following are the steps we
use for the CJR model that we proposed
to apply when prorating payments
under the proposed EPMs, and that
were specifically cited in our proposed
rule (80 FR 73333 through 73335).
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These steps have been updated to reflect
our methodology as applied to an AMI
episode involving a CABG.
In general, assuming we have a
beneficiary in an EPM episode who is
admitted to a SNF for 15 days,
beginning on Day 86 post-discharge
from the anchor EPM hospitalization,
the first 5 days of the admission would
fall within the episode, while the
subsequent 10 days would fall outside
of the episode. Under our proposal, to
the extent that a Medicare payment for
included episode services spans a
period of care that extends beyond the
episode, these payments would be
prorated so that only the portion
attributable to care during the episode is
attributed to the episode payment when
calculating actual Medicare payment for
the episode.
For non-IPPS inpatient hospital (for
example, CAH) and inpatient post-acute
care (for example, SNF, IRF, LTCH, IPF)
services, we would prorate payments
based on the percentage of actual length
of stay (in days) that falls within the
episode window. Prorated payments
would also be similarly allocated to the
30-day post-episode payment
calculation in section III.D.7.e. of this
final rule. In the previous example, onethird of the days in the 15-day length of
stay would fall within the episode
window, so under the proposed
approach, one-third of the SNF payment
would be included in the episode
payment calculation, and the remaining
two-thirds (because the entirety of the
remaining payments fall within the 30
days after the episode ended) would be
included in the post-episode payment
calculation.
For HHA services that extend beyond
the episode, the payment proration
would be based on the percentage of
days, starting with the first billable
service date (‘‘start of care date’’) and
through and including the last billable
service date, that fall within EPM
episode. Prorated payments would also
be similarly allocated to the 30-day
post-episode payment calculation in
section III.D.7.e. of this final rule. For
example, if the patient started receiving
services from an HHA on day 86 after
discharge from the anchor
hospitalization and the last billable
home health service date was 55 days
from the start of home health care date,
the HHA claim payment amount would
be divided by 55 and then multiplied by
the days (5) that fell within the EPM
episode. The resulting, prorated HHA
claim payment amount would be
considered part of the EPM episode.
Services for the prorated HHA service
would also span the entirety of the 30
days after the EPM episode spends, so
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the result of the following calculation
would be included in the 30-day postepisode payment calculation: HHA
claim payment amount divided by 55
and then multiplied by 30 days (the
number of days in the 30-day postepisode period that fall within the
prorated HHA service dates).
There may also be instances where
home health services begin prior to the
EPM episode start date, but end during
the EPM episode. In such instances, we
would also prorate HHA payments
based on the percentage of days that fell
within the episode. Because these
services end during the EPM episode,
prorated payments for these services
would not be included in the 30-day
post-episode payment calculation
discussed in section III.D.7.e. of this
final rule. For example, if the patient’s
start of care date for a home health 60day claim was February 1, the anchor
hospitalization was March 1 through
March 4 (with the EPM episode
continuing for 90 days after March 4),
and the patient resumed home care on
March 5 with the 60-day home health
claim ending on April 1 (that is, April
1 was the last billable service date), we
would divide the 60-day home health
claim payment amount by 60 and then
multiply that amount by the days from
the EPM admission through April 1 (32
days) to prorate the HHA payment. This
proposed prorating method for HHA
claims is consistent with how partial
episode payments (PEP) are paid for on
home health claims.
For IPPS services that extend beyond
the episode (for example, readmissions
included in the episode definition), we
would separately prorate the IPPS claim
amount from episode target price and
actual episode payment calculations as
was made final in the final CJR rule (80
FR 73334 through 73335), called the
normal MS–DRG payment amount for
purposes of this final rule. The normal
MS–DRG payment amount would be
pro-rated based on the geometric mean
length of stay, comparable to the
calculation under the IPPS post-acute
care transfer policy at § 412.4(f) and as
published on an annual basis in Table
5 of the IPPS/LTCH PPS Final Rules.
Consistent with the IPPS post-acute care
transfer policy, the first day for a subset
of MS–DRGs (indicated in Table 5 of the
IPPS/LTCH PPS Final Rules) would be
doubly weighted to count as 2 days to
account for likely higher hospital costs
incurred at the beginning of an
admission. If the actual length of stay
that occurred during the episode is
equal to or greater than the MS–DRG
geometric mean, the normal MS–DRG
payment would be fully allocated to the
episode. If the actual length of stay that
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297
occurred during the episode is less than
the geometric mean, the normal MS–
DRG payment amount would be
allocated to the episode based on the
number of inpatient days that fall
within the episode. If the full amount is
not allocated to the episode, any
remainder amount would be allocated to
the 30 day post-episode payment
calculation discussed in section
III.D.7.e. of this final rule. The proposed
approach for prorating the normal MS–
DRG payment amount is consistent with
the IPPS transfer per diem methodology.
More specifically, if a beneficiary has
a readmission for MS–DRG 234—
coronary bypass with cardiac
catheterization without major
complications or comorbidities—into an
IPPS hospital on the 89th day after
discharge from an EPM anchor
hospitalization, and is subsequently
discharged after a length of stay of 5
days, Medicare payment for this
readmission would be prorated for
inclusion in the episode. Based on Table
5 of the IPPS/LTCH PPS Final Rule for
FY 2017, the geometric mean for MS–
DRG 234 is 8 days, and this MS–DRG is
indicated for double-weighting the first
day for proration. This readmission has
only 2 days that falls within the
episode, which is less than the MS–DRG
234 geometric mean of 8 days.
Therefore, the normal MS–DRG
payment amount associated with this
readmission would be divided by 8 (the
geometric mean) and multiplied by 3
(the first day is counted as 2 days, and
the second day contributes the third
day), and the resulting amount is
attributed to the episode. The remaining
five-eighths would be captured in the
post-episode spending calculation
discussed in section III.D.7.e. of this
final rule. If the readmission occurred
on the 82nd day after discharge from the
EPM anchor hospitalization, and the
length of stay was 10 days, the normal
MS–DRG payment amount for the
admission would be included in the
episode without proration because
length of stay for the readmission falling
within the episode (9 days) is greater
than or equal to the geometric mean (8
days) for the MS–DRG. We would also
clarify that, consistent with how we
would prorate payments for services
that extend beyond the episode when
establishing benchmark prices for an
AMI episode without a CABG, in
instances of an AMI episode with CABG
readmissions, we would establish the
benchmark price based on prorated
amounts for both the AMI episode and
the CABG readmission.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal, without
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modification, to prorate payments for
services that straddle episodes. Our
final policy for prorating payments is
included in § 512.300(f).
d. High-Payment EPM Episodes
For the CJR model, we defined a highpayment episode as an episode with
payments 2 standard deviations or more
above the mean calculated at the
regional level (80 FR 73336 through
73337). As with the CJR model, we
proposed to apply a high-payment
episode ceiling when calculating actual
EPM-episode payments and when
calculating historical EPM-episode
payments used to set EPM-episode
benchmark and quality-adjusted target
prices (81 FR 50846). We proposed to
apply the ceiling according to the
following groupings that align with our
proposed EPM price-setting
methodology.
First, for SHFFT model episodes, we
proposed to calculate and apply the
ceiling separately for each SHFFT price
MS–DRG at the regional level.
Second, for AMI model episodes with
price MS–DRGs 280–282 or 246–251
without readmission for CABG MS–
DRGs, we proposed to calculate and
apply the ceiling separately for each
price MS–DRG at the regional level.
Third, for CABG model episodes, we
proposed to apply ceilings separately to
the payments that occurred during the
anchor hospitalization of the CABG
model episode and to the payments that
occurred after the anchor
hospitalization. For the anchor
hospitalization portion of CABG model
episodes, we proposed to calculate and
apply the ceiling separately by each
price MS–DRG in 231–236 at the
regional level. For the post-anchor
hospitalization portion, we proposed to
calculate and apply the ceiling
separately for the following groupings at
the regional level:
• With AMI ICD–CM diagnosis code
on the anchor inpatient claim and price
MS–DRG with major complication or
comorbidity (231, 233, or 235).
• With AMI ICD–CM diagnosis code
on the anchor inpatient claim and price
MS–DRG without major complication or
comorbidity (232, 234, or 236).
• Without AMI ICD–CM diagnosis
code on the anchor inpatient claim and
price MS–DRG with major complication
or comorbidity (231, 233, or 235).
• Without AMI ICD–CM diagnosis
code on the anchor inpatient claim and
price MS–DRG without major
complication or comorbidity (232, 234,
or 236).
Fourth, for AMI model episodes with
price MS–DRG 231–236, we proposed to
apply ceilings separately to the
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payments that occurred during the
chained anchor hospitalization and to
the payments that occurred after the
chained anchor hospitalization. For the
anchor hospitalization portion of the
episode, we proposed to apply the
regional level ceiling calculated for the
anchor hospitalization portion of a
CABG model episode for the
corresponding price MS–DRG, as
described previously. For the postanchor hospitalization portion of the
episode, we proposed to apply the
regional level ceiling calculated for the
post-anchor hospitalization portion of a
CABG model episode for the
corresponding price MS–DRG with AMI
diagnosis.
Fifth, for AMI model episodes with
price MS–DRG 280–282 or 246–251 and
with readmission for CABG MS–DRGs,
we proposed to apply the ceiling
separately to the payments during the
CABG readmission and all other
payments during the episode. For
payments during the CABG readmission
portion of the AMI model episode we
proposed to apply the regional level
ceiling calculated for the anchor
hospitalization portion of a CABG
model episode for the corresponding
CABG readmission MS–DRG, as
described previously. For all other
payments during the AMI model
episode, we proposed to apply the
regional level ceiling calculated for AMI
model episodes with price MS–DRG
280–282 or 246–251 and without
readmission for CABG MS–DRGs
corresponding to the AMI price MS–
DRG.
We believed that the proposed ceiling
would protect EPM participants from
variable repayment risk for especiallyhigh payment EPM episodes where the
clinical scenarios for these cases each
year may differ significantly and
unpredictably.
The proposal for capping high
payment EPM episodes were included
in § 512.300(e)(1). We sought comment
on our proposal to cap high payment
EPM episodes.
The following is a summary of the
comments received and our responses.
Comment: Commenters supported the
proposal for capping high payment
episodes. A commenter noted that the
proposal does not separately address an
episode where Medicare accepts a
beneficiary’s appeal of Medicare
Provider Non-Coverage after the
discharging physician determined not to
certify that patient for care. The
commenter noted that under such a
scenario, in contradiction with the
hospital’s clinical judgment on
appropriate level of care, the proposed
policy would not cap spending unless it
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reached the proposed threshold. The
commenter recommended that CMS
create additional flexibilities or
protections for hospitals where a
Medicare appeal overturns a hospital’s
decision that is based on clinicallydirected, evidence-based discharge
criteria.
Response: We appreciate comments in
support of our proposal to cap high
payment EPM episodes. We disagree
with the suggestion to include
protections in addition to what we have
proposed to address scenarios where a
Medicare appeal contradicting a
hospital’s discharge decision increases
the costs of an episode. We believe our
proposal offers sufficient protection
under such circumstances. Further, if a
hospital’s discharge decision was
overturned upon appeal, we would have
to believe the final decision was correct
and any additional costs that resulted
from the appeal would be appropriately
included as an episode cost.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal, with
modification, to cap high payment EPM
episodes. Specifically, we are not
finalizing our proposal to apply ceilings
separately to the payments that occurred
during the chained anchor
hospitalization and to the payments that
occurred after the chained anchor
hospitalization with respect to AMI
model episodes with MS–DRG 231–236,
and instead will simply apply ceilings
separately for each MS–DRG at the
regional level as we would with MS–
DRGs 280–282 or 246–251 without
readmission for CABG MS–DRGs. Our
final policy for capping high payment
EPM episodes is included in
§ 512.300(e)(1).
e. Treatment of Reconciliation Payments
and Medicare Repayments When
Calculating Historical EPM-Episode
Payments To Update EPM-Episode
Benchmark and Quality-Adjusted Target
Prices
For the CJR model, we exclude CJR
model reconciliation payments and
Medicare repayments from the
expenditure data used to update
historical claims when calculating CJR
model target prices, although we
received comments on the proposed
rule encouraging us to include these
payments. For example, commenters
supported their inclusion because CJRparticipating hospitals otherwise would
be providing care coordination services
that would not be paid directly or
accounted for under applicable
Medicare FFS payments systems and
thus might be funded through
reconciliation payments. Further, by
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excluding reconciliation payments from
the calculations, commenters suggested
that we may underestimate their actual
resource costs when updating target
prices for the care necessary during
episodes. The CJR Final Rule discussed
our view that including reconciliation
payments would have the effect of
Medicare paying CJR model participant
hospitals their target prices, regardless
of whether such participant was below,
above, or met their episode target price.
We also noted that we had not
discussed any alternatives in the CJR
model proposed rule, and that we might
consider including these payments in
updating historical claims through
future rulemaking (80 FR 73332).
After further consideration, we
proposed to include both reconciliation
payments and Medicare repayments
when calculating historical EPMepisode payments to update EPMepisode benchmark and quality-adjusted
target prices (81 FR 50847). We
concurred with the views expressed by
commenters on the CJR model proposed
rule that including these payments
would more fully recognize the total
resource costs of care under an EPM
than would their exclusion. As
indicated in section V.B. of the
proposed rule (81 FR 50950 through
50951), we also proposed to modify our
policy for the CJR model to also include
reconciliation payments and Medicare
repayments when updating target prices
under that model. We also considered
an option where we would include only
reconciliation payments when updating
but not Medicare repayments; however,
we believed this option would not
achieve our intention of more fully
capturing the costs of care under the
EPM. We further noted that the
inclusion of both reconciliation
payments and Medicare repayments
could have differential effects on an
EPM participant’s benchmark and
quality-adjusted target prices based on
whether or not it received a
reconciliation payment or made a
Medicare repayment. For example, all
else equal, including an EPM
reconciliation payment when updating
an EPM participant’s EPM-episode
benchmark and quality-adjusted target
prices would modestly increase the
quality-adjusted target prices in
performance years 3 through 5 in
comparison to not including the
reconciliation payment. Conversely, all
else equal, including a Medicare
repayment when updating an EPM
participant’s EPM-episode benchmark
and quality-adjusted target prices would
reduce the next performance year’s
quality-adjusted target price in
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comparison to not including the
Medicare repayment. Following
analogous logic, we also proposed to
include BPCI Net Payment
Reconciliation Amounts in our
calculations when updating EPMepisode benchmark and quality-adjusted
target prices. We noted, however, that
the effects of these proposals would
largely be confined to PY3 of the EPMs
and diminish as EPM-participant
historical EPM-episode updates are
eventually determined based on
regional payments in subsequent years
of the EPMs. This is because the net
sum of EPM reconciliation payments,
Medicare repayments, and BPCI Net
Payment Reconciliation Amounts would
represent a small portion of the total
historical EPM-episode payments
captured in regional pricing.
When updating EPM-episode
benchmark and quality adjusted target
prices for CABG model episodes, we
proposed to apportion EPM
reconciliation payments and BPCI Net
Reconciliation Payment Amounts
proportionally to the anchor
hospitalization and post-anchor
hospitalization portions of CABG model
historical episodes. We also proposed to
calculate the proportions based on
regional average historical episode
payments that occurred during the
anchor hospitalization portion of CABG
model episodes and regional average
historical episode payments that
occurred during the post-anchor anchor
hospitalization portion of CABG model
episodes that were initiated during the
3 historical years. This aligns with the
general proposal to calculate the CABG
model-episode benchmark price as the
sum of the corresponding CABG anchor
hospitalization benchmark price and the
corresponding CABG post-anchor
hospitalization benchmark price, as
discussed in III.D.4.b.(2)(ii) and
III.D.4.d. of the proposed rule.
The proposal to include both
reconciliation payments and Medicare
repayments when calculating historical
EPM-episode payments to update EPMepisode benchmark and quality-adjusted
target prices was included in
§ 512.300(c)(8). We sought comment on
our proposal to include both
reconciliation payments and Medicare
repayments when calculating historical
EPM-episode payments to update EPMepisode benchmark and quality-adjusted
target prices.
The following is a summary of the
comments received and our responses.
Comment: Multiple commenters
supported the proposal to include
reconciliation payments when
calculating target prices in order to more
fully recognize the costs of care under
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299
the models. A number of commenters
expressed the view that the proposal
will help avoid participants from
constantly competing against their prior
success and better ensure that target
prices decrease at a slower rate, which
is critical for those providers that are
already efficient, allow more viable
financial targets for the participating
providers that are better aligned with
effective patient care. A commenter
requested that CMS include these
reconciliation payments and
repayments in PY2 rather than PY3.
Another commenter requested that CMS
exclude Medicare repayments given that
the targets would fall for hospitals that
increased their spending to improve
care, which then caused them to exceed
their target prices.
Response: We appreciate the
comments supporting our proposal to
include reconciliation and Medicare
repayments when calculating historical
EPM-episode payments to update EPMepisode benchmark and quality-adjusted
target prices. We disagree with
comments suggesting that we accelerate
their inclusion to PY2 or to exclude
Medicare repayments for these
purposes. We would further note that
since the historical data for determining
PY1 and PY2 benchmarks is based on
2013 to 2015 expenditure data, the
effects of a reconciliation determination
for PY1, which is based on 2017
expenditure data, would not pertain to
the data used to determine target prices
for PY2. Moreover, given that
reconciliation determinations are made
2 months after the completion of a
performance year, it would not be
possible to apply the PY1 reconciliation
results to the PY2 benchmark data even
if we were to adjust our timeframe for
determining historical payments.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal, without
modification, to include both
reconciliation payments and Medicare
repayments when calculating historical
EPM-episode payments to update EPMepisode benchmark and quality-adjusted
target prices. The final policy for
including reconciliation payments and
Medicare repayments is included in
§ 512.300(c)(8).
4. EPM-Episode Price-Setting
Methodologies
a. Overview
Whether an EPM participant receives
a reconciliation payment or is made
responsible to repay Medicare under the
EPM is based on the EPM participant’s
actual EPM-episode payments relative
to quality-adjusted target prices, as well
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as the EPM participant’s eligibility for
reconciliation payment based on
acceptable, good, or excellent quality
performance. While our proposals for
relating EPM participant quality
performance to EPM payments were
further discussed in section III.E.3.f of
the proposed rule (81 FR 50887 through
50893), this section of the proposed rule
discussed the approach to establishing
EPM-episode benchmark and qualityadjusted target prices (81 FR 50847
through 50864).
For the purposes of price-setting, any
references in our proposed rule to AMI
ICD–CM diagnosis codes meant those
ICD–9–CM and ICD–10–CM diagnosis
codes for historical EPM episodes or
ICD–10–CM diagnosis codes for EPM
episodes during the EPM performance
years that can be found in the specific
EPM episode definitions parameters
spreadsheet. Also, for the purposes of
price-setting, any references in the
proposed rule to intracardiac ICD–CM
procedure codes meant those ICD–9–CM
procedure codes for historical EPM
episodes that can be found in the
specific EPM episode definitions
parameters spreadsheet. The EPM
episode definitions parameters
spreadsheets are posted on the CMS
Web site at https://innovation.cms.gov/
inititatives/epm.
We proposed to establish EPMepisode benchmark and quality-adjusted
target prices for each EPM participant
based on the following MS–DRGs and
diagnoses included in the AMI, CABG,
and SHFFT models as discussed in
sections III.C.3 and III.C.4. of the
proposed rule:
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(1) AMI model
• AMI MS–DRGs —
++ 280 (Acute myocardial infarction,
discharged alive with MCC);
++ 281 (Acute myocardial infarction,
discharged alive with CC);
++ 282 (Acute myocardial infarction,
discharged alive without CC/MCC); and
• PCI MS–DRGs, when the claim
includes an AMI ICD–CM diagnosis
code in the principal or secondary
position on the inpatient claim and
when the claim does not include an
intracardiac ICD–CM procedure code in
any position on the inpatient claim—
++ 246 (Perc cardiovasc proc with
drug-eluting stent with MCC or 4+
vessels/stents);
++ 247 (Perc cardiovasc proc with
drug-eluting stent without MCC);
++ 248 (Perc cardiovasc proc with
non-drug-eluting stent with MCC or 4+
vessels/stents);
++ 249 (Perc cardiovasc proc with
non-drug-eluting stent without MCC);
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++ 250 (Perc cardiovasc proc without
coronary artery stent with MCC); and
++ 251 (Perc cardiovasc proc without
coronary artery stent without MCC).
(2) CABG model DRGs—
• 231 (Coronary bypass with PTCA
with MCC);
• 232 (Coronary bypass with PTCA
without MCC);
• 233 (Coronary bypass with cardiac
cath with MCC);
• 234 (Coronary bypass with cardiac
cath without MCC);
• 235 (Coronary bypass without
cardiac cath with MCC); and
• 236 (Coronary bypass without
cardiac cath without MCC).
(3) SHFFT model DRGs—
• 480 (Hip and femur procedures
except major joint with MCC);
• 481 (Hip and femur procedures
except major joint with CC); and
• 482 (Hip and femur procedures
except major joint without CC or MCC).
We proposed to generally apply the
CJR model methodology to set EPMepisode benchmark and quality-adjusted
target prices (80 FR 73337 through
73338), with the addition of some
adjustments based on the specific
clinical conditions and care patterns for
EPM episodes included in the AMI,
CABG, and SHFFT models. The pricesetting methodology incorporated the
following features:
• Set different EPM benchmark and
quality-adjusted target prices for EPM
episodes based on the assigned price
MS–DRG in one of the included MS–
DRGs to account for patient and clinical
variations that impact EPM participants’
costs of providing care. Inpatient claims
with PCI MS–DRGs 246–251 that
contain an intracardiac ICD–CM
procedure code in any position would
not anchor an historical episode, nor be
considered when assigning a price MS–
DRG. This is because beginning in FY
2016, inpatient claims containing an
intracardiac ICD–10–CM procedure
code in any position no longer map to
MS–DRGs 246–251.
• Adjust EPM benchmark and
quality-adjusted target prices for certain
EPM episodes involving chained anchor
hospitalizations, specific readmissions,
or the presence of an AMI ICD–CM
diagnosis code for CABG MS–DRGs.
• Use 3 years of historical Medicare
FFS payment data grouped into EPM
episodes according to the EPM episode
definitions in sections III.C.3 and III.C.4.
of the proposed rule, termed historical
EPM episodes and historical EPMepisode payments. The specific set of 3
historical years would be updated every
other performance year.
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• Apply Medicare payment system
(for example, IPPS, OPPS, IRF PPS,
SNF, MPFS.) updates to the historical
EPM-episode data to ensure we
incentivize EPM participants based on
historical utilization and practice
patterns, not Medicare payment system
rate changes that are beyond such
participants’ control. Because different
Medicare payment system updates
become effective at two different times
of the year, we would calculate one set
of EPM-benchmark and quality-adjusted
target prices for EPM episodes initiated
between January 1 and September 30
and another set for EPM episodes
initiated between October 1 and
December 31.
• Blend together EPM-participant
hospital-specific and regional historical
EPM-episode payments, transitioning
from primarily hospital-specific to
completely regional pricing over the
course of the 5 performance years, to
incentivize both historically-efficient
and less-efficient EPM participants to
furnish high quality, efficient care in all
years of the EPM Regions would be
defined as each of the nine U.S. Census
divisions.
• Normalize for hospital-specific
wage-adjustment variations in Medicare
payment systems when combining
hospital-specific and regional historical
EPM episodes.
• Pool together EPM episodes by
groups of price MS–DRGs to allow a
greater volume of historical cases and
allow us to set more stable prices.
• Apply an effective discount factor
on EPM-episode benchmark prices to
serve as Medicare’s portion of reduced
expenditures from the EPM episode,
with any remaining portion of reduced
Medicare spending below the qualityadjusted target price potentially
available as reconciliation payments to
the EPM participant where the anchor
hospitalization occurred.
• Further discussion on each of the
features and sequential steps to
calculate EPM-episode benchmark and
quality-adjusted target prices can be
found in sections III.D.4.b through e. of
both our proposed rule and this final
rule.
We also proposed to calculate and
communicate EPM-episode benchmark
and quality-adjusted target prices to
EPM participants prior to the
performance period in which the prices
apply (that is, prior to January 1, 2018,
for prices covering EPM episodes that
start between January 1, 2018, and
September 30, 2018; prior to October 1,
2018, for prices covering EPM episodes
that start between October 1, 2018, and
December 31, 2018). We stated our
belief that prospectively communicating
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EPM-episode benchmark and qualityadjusted target prices to EPM
participants would help them make
infrastructure, care coordination and
delivery, and financial refinements they
may deem appropriate to prepare for the
new episode target prices under the
model.
The proposal to prospectively
communicate quality-adjusted target
prices was included in § 512.300(c)(9).
We sought comment on our proposal to
prospectively communicate these
prices.
The following is a summary of the
comments received and our responses.
Comment: Commenters supported the
proposal to establish and prospectively
communicate benchmark and qualityadjusted target prices. Commenters also
expressed concerns about how far in
advance the information would be made
available and the level of detail that
would be included in the information.
Commenters indicated that knowing the
target price prior to the relevant
performance period is essential for
participants to be able to implement
efficient care redesigns linked explicitly
to established payment rates. As such,
commenters requested that CMS
provide this information 60 to 90 days
prior to the start of the relevant
performance period. Other commenters
requested that CMS make all of the
components necessary to calculate the
target price for both the CJR model and
proposed EPMs available to participants
so they can verify that CMS accurately
calculated the target price as some CJR
participants have reported an inability
to replicate the target price calculation
due to CMS’ use of ‘‘black box’’ inputs
for certain national factors.
Response: We appreciate the
comments and support we received for
our proposal to prospectively
communicate benchmark and qualityadjusted target prices, agree with
commenters on the importance of
having this information in advance of
each performance year, and intend to
make as much information available as
we deem appropriate to participants as
far in advance of the models’
implementation as is possible.
Comment: Several commenters
recommended that CMS annually
reevaluate and update the price-setting
assumptions through a notice and
comment process. One of these
commenters reported that the proposal
to make historical claims data available
before implementation of the models
would still not give hospitals an
opportunity to comment on problems
with the methodology until after the
models had begun. Another commenter
based their request on significant and
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unexplained changes in prices reported
under BPCI and the Pioneer ACO
model.
Response: We appreciate these
comments and suggestions. We believe
the information we provided in both our
proposed and this final rule is
sufficiently detailed for participants to
understand our assumptions and
methodology for setting target prices. In
the event we intend to materially
change our price-setting assumptions or
methodology, we would make those
proposed changes available through a
notice and comment process.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal, without
modification, to prospectively
communicate quality-adjusted target
prices.
b. EPM-Episode Benchmark and
Quality-Adjusted Target Price Features
(1) Risk-Stratifying EPM-Episode
Benchmark Prices Based on MS–DRG
and Diagnosis
To account for some of the clinical
and resource variations that would be
expected to occur under the EPMs, we
proposed generally to apply the episode
pricing methodology that was applied to
the CJR model to develop the EPMepisode benchmark prices, which we
referred to as the standard EPM-episode
benchmark price (81 FR 50848). In
addition, for each EPM participant, we
proposed to risk-stratify and establish
special EPM-episode benchmark prices
for episodes in different pricing
scenarios as described in this section, as
well as sections III.D.4.c. through e. of
the proposed rule (81 FR 50848 through
50864). For purposes of the proposed
rule, risk-stratification meant the
methodology for developing the EPMepisode benchmark price that accounts
for clinical and resource variation in
historical EPM episodes so that the
quality-adjusted target price (calculated
from the EPM-episode benchmark price)
can be compared to actual EPM episode
payments for EPM beneficiaries with
similar care needs to those in historical
EPM episodes.
For the SHFFT model, we proposed to
set the price MS–DRG equal to the
anchor MS–DRG. We proposed to
calculate standard SHFFT modelepisode benchmark prices based on
price MS–DRGs following the general
payment methodology that was applied
to the CJR model (80 FR 73337 through
73358) with risk stratification according
to the anchor MS–DRG.
Similarly, for AMI model episodes
without chained anchor hospitalizations
and without readmissions for CABG
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301
MS–DRGs, we proposed to set the price
MS–DRG equal to the anchor MS–DRG.
We proposed to calculate standard AMI
model-episode benchmark prices based
on price MS–DRGs following the
general payment methodology that was
applied to the CJR model (80 FR 73337
through 73358) with risk stratification
according to the anchor MS–DRG. We
proposed to apply the CJR model
payment methodology separately to
AMI model episodes with anchor AMI
MS–DRGs 280 through 282 and anchor
PCI MS–DRGs 246 through 251 with a
corresponding AMI ICD–CM diagnosis
code on the inpatient claim for the
anchor hospitalization and without an
intracardiac ICD–CM procedure code in
any position on the inpatient claim for
the anchor hospitalization.
For episodes in the AMI model with
chained anchor hospitalizations and no
readmissions for CABG MS–DRGs, we
proposed to set the price MS–DRG
based on the hierarchy described in
section III.D.4.b.(2)(a) and to calculate
AMI model-episode benchmark prices
based on price MS–DRGs as described
in sections III.D.4.b.(2)(a) and III.D.4.c.
of the proposed rule.
For AMI model episodes without
chained anchor hospitalizations and
with readmissions for CABG MS–DRGs,
we proposed to set the price MS–DRG
as the anchor MS–DRG and to calculate
CABG readmission AMI model-episode
benchmark prices as described in
sections III.D.4.b.(2)(b), III.D.4.b.(2)(c),
and III.D.4.e of the proposed rule.
For AMI model episodes with chained
anchor hospitalizations that do not
include CABG MS–DRGs and with
readmissions for CABG MS–DRGs, we
proposed to set the price MS–DRG
based on the hierarchy described in
section III.D.4.b.(2)(a) and to calculate
CABG readmission AMI model-episode
benchmark prices as described in
sections III.D.4.b.(2)(b), III.D.4.b.(2)(c),
and III.D.4.e. of the proposed rule.
For CABG model episodes, we
proposed to set the price MS–DRG as
the anchor MS–DRG and to calculate
CABG model-episode benchmark prices
as the sum of the CABG anchor
hospitalization portion price and the
CABG post-anchor hospitalization
portion price, which would be
calculated by applying the general
payment methodology that was applied
to the CJR model (80 FR 73337 through
73358) separately to the expenditures
that occurred during the anchor
hospitalization of the CABG model
episode and to the expenditures that
occurred after the anchor
hospitalization as discussed in sections
III.D.4.b.(2)(b) and III.D.4.d. of the
proposed rule.
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Finally, we proposed that after
assigning an EPM-episode benchmark
price to each EPM episode, the EPMepisode quality-adjusted target price
would be the EPM-episode benchmark
price reduced by the effective discount
factor for the corresponding EPM that
corresponds to the EPM participant’s
quality category, as discussed in
sections III.D.4.b.(10) and III.E.3.f. of the
proposed rule.
The following is a summary of the
comments received and our responses.
Comment: One commenter
commended CMS for attempting to
create a target price methodology that
accounts for the variations in episode
spending that are characteristic of these
specific clinical scenarios while other
commenters noted that the complexity
of the proposals made it difficult to
evaluate them. Several commenters
disagreed with the proposal to base
prices on MS–DRGs or anticipated that
they could result in unintended
consequences. For example,
commenters noted concerns that it
would be challenging to generate
sufficient savings where a sizeable
portion of episode costs are embedded
in the MS–DRG costs attributed to the
initial hospitalization and cannot be
changed by hospitals’ performance.
Other commenters noted that the higher
payments associated with higherweighted MS–DRGs could serve as a
disincentive to participants from
making quality improvements or to
reduce complications because they
would be paid more when there are
complications that raise the MS–DRG,
but paid less when quality
improvements they made resulted in a
lower cost MS–DRG where only CMS
rather than the hospital benefitted from
the reduced costs. Likewise, several
commenters claimed that participant
coding behavior could result in similar
unintended consequences. As such,
several commenters recommended that
CMS consider a price-setting
methodology that removes the MS–DRG
payment from the target price or
mitigates coding effects from the
calculations or differentially weights
cost components that would be ‘‘locked
in’’ to the episode spending.
Response: The purpose of our models
is to test EPMs within the existing
parameters and payment systems of FFS
Medicare. As we noted in section
III.A.1.c. of this final rule, issues such
as those commenters raised are
generally present for every episode
payment model that sets a price
Medicare will pay for an episode-ofcare. While our models are not intended
to change these existing FFS payment
systems, we intend that by
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incorporating both the MS–DRG
payment and Part B services furnished
during the anchor inpatient
hospitalization, the EPMs will create
incentives for increased care
coordination and efficient care delivery
from the time of inpatient admission
through 90 days after discharge.
Moreover, we hope the EPMs can
identify the effectiveness of a bundled
payment model within those parameters
as well as the factors that could impede
success. As discussed further in sections
III.G.4. through III.G.6. of this final rule,
we will monitor access to care, the
quality of care, and delayed care under
the EPMs and may take actions against
EPM participants if we find evidence
that supports concerns in these areas. In
addition, the evaluation as discussed in
section IV. of this final rule will analyze
beneficiary outcomes and their
relationship to clinical pathways under
the EPMs.
Comment: Several commenters
addressed EPM payments under the
SHFFT model. One commenter noted
that the proposed SHFFT model would
include beneficiaries discharged under
hip and femur procedures except major
joint replacement MS–DRGs (480–482),
representing IPPS admissions for hip
fixation procedures in the setting of hip
fractures. As these procedures are
emergent rather than elective, they
would have more risk to manage than
would an elective LEJR and would more
often require a SNF stay and non-weight
bearing status for weeks, which results
in higher costs than for an elective
procedure. The commenter questioned
whether such non-elective procedures
would have a higher benchmark price
and expressed concerns that bundled
payment models are potentially less
successful for non-elective procedures
which they believe require more time
for planning and rehabilitation.
Other commenters suggested that the
differences in severity and fracture type
for episodes under the SHFFT model are
not adequately represented by the three
MS–DRGs we proposed. One of these
commenters requested additional
separate target prices as CMS had done
for the CJR model, which would serve
as a rough form of risk-adjustment and
would make it easier for hospitals to
devise protocols and strategies best
suited to fracture type. Another
commenter suggested that since patients
who experience SHFFT episodes often
require lengthier and more complicated
care, and typically require longer postacute care than those receiving joint
replacement, the calculation of target
prices should also take into account the
proportion of SHFFT episodes included
in the bundle in order to most
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accurately capture the risk of SHFFT
episodes. One commenter
recommended that CMS adopt transfer
mechanisms within the SHFFT model,
including price adjustments, which are
similar to those proposed for inpatientto-inpatient hospital transfers under the
AMI model but that the receiving
hospital would bear the risk if a SHFFT
patient is transferred to that hospital.
Response: We proposed to set prices
based on anchor MS–DRGs, which
implicitly adjust payments based on
their relative weights with respect to the
IPPS resources required for that MS–
DRG. For example, average episode
expenditures for historical SHFFT
episodes increases from roughly $36,000
in episodes with anchor MS–DRG 482 to
more than $52,000 for episodes with
anchor MS–DRG 480.77 Further, our
benchmark prices would reflect the
historic costs of post-acute care
associated with these MS–DRGs. If
historic post-acute care costs for the
emergent MS–DRG are higher than those
for a similar elective MS–DRG, then
those higher resources would be
reflected in and produce a larger
increase in the benchmark amount than
would be the case for the elective
procedure. We would also note that as
discussed in section III.D.4.b.(2) which
follows, we will be exploring additional
options to adjust benchmark prices and
performance payments to better account
for cost variation associated with risk.
These adjustments, which we intend to
be effective beginning in PY3, should
further account for some of the potential
variation in costs across episodes as has
been highlighted. We disagree with the
view that a bundled payment would be
any less effective with an emergent than
an elective procedure. Our proposed
models are intended to encourage
changes and improvements in
participants’ care practices, in general,
with respect to the episodes covered
under the models, which we believe
would apply regardless of whether the
episode is elective or emergent.
As discussed in section III.D.4.b.2.(a),
we are not finalizing our proposal with
regard to inpatient-to-inpatient transfers
for AMI episodes. For AMI model
episodes alone, we will cancel the AMI
episode that begins at the initial treating
hospital when an inpatient-to-inpatient
transfer occurs during the anchor
hospitalization. For CABG and SHFFT
model episodes, once the episode begins
and an inpatient-to-inpatient transfer
occurs, the episode will continue and
77 Episodes for SHFFT model beneficiaries
initiated by all U.S. IPPS hospitals and constructed
using standardized Medicare FFS Parts A and B
claims, as proposed in this rule that began in CYs
2012–2014.
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the hospitalization at the transfer
hospital will be included or excluded
from the CABG or SHFFFT episode
based on whether or not the MS–DRG
for the admission at the transfer hospital
is excluded from the CABG or SHFFT
episode definition.
Comment: One commenter stated that
the proposed EPMs do not adequately
account for research and teaching
functions and that CMS should adjust
payments to account for the overhead
associated with these functions.
Response: We disagree that our
proposed models should include
additional payment adjustments for
research and teaching function beyond
the payments Medicare already makes
for these purposes under the IPPS. In
contrast, we believe that participants
should seek improved care quality and
efficiencies as broadly as is possible,
including any that can be attained with
research or teaching activities.
Comment: A commenter noted their
view that all providers should have EHR
capability, including the ability to share
EHR data across sites of service in order
to speed decision-making and eliminate
duplication of effort. The commenter
suggested that CMS include incentive
funds to assist post-acute care providers
in implementing a robust EHR system
and tools to share the data with other
providers. Similarly, a commenter
suggested that the proposed models will
require technology and services for
monitoring care during a post-acute care
stay, and that CMS should incentivize
the use of such technology and services.
The commenter recommended that CMS
should pay for remote patient
monitoring using the CPT-code 94040,
which is similar to what is done in
certain state models.
Response: We agree that EHR
capability and monitoring technologies
can be useful tools toward improving
care coordination and care quality;
however, our models are based on
incentives to improve care quality and
efficiency, with a goal of improving
control of cost growth. We do not
believe that adding funding to
encourage further adoption of
technologies under the models is
consistent with our goals. However, we
would note that to the extent a
participant establishes sharing
arrangements with post-acute care
collaborators under the models, those
collaborators could choose to use such
shared funds for purposes of improving
their EHR or monitoring capacities.
Comment: As discussed in section
III.C.3.b. of this final rule, one
commenter pointed to evidence
demonstrating that the use of drugeluting stents (DESs) results in better
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long-term outcomes in many patients
and fewer repeat procedures for in-stent
restenosis than do less costly non-drug
eluting stents. The commenter
expressed concern that while the costs
of these more expensive stents would be
captured in the episode cost calculation,
the long-term benefit for patients both in
terms of outcomes and costs would not
be fully captured in the 90-day postdischarge episode period and hence
discourage the appropriate use of DES
by causing fewer patients to receive
them, resulting in poorer outcomes and
increased cost growth. The commenter
requested that CMS consider various
means so to ensure the 90-day postdischarge episode target price does not
discourage the longer term outcomes
that are better for Medicare beneficiaries
and potentially overall savings for CMS.
Another commenter requested an
adjustment or additional financial
protection for costs associated with the
implantation of an Implantable
Cardioverter Defibrillator (ICD) given
strong empirical support and its Class I
recommendation for prevention of
sudden cardiac death for certain
patients.
Similarly, another commenter
recommended that CMS include a
payment adjustment such as an
additional outlier or add-on payment for
using new technology, having higher
cost cases, or adopting a breakthrough/
high cost treatment in advance of other
providers.
Finally, one commenter
recommended that CMS coordinate with
the device industry to create a process
wherein the use and associated cost of
new technologies can be added to
episodes of care definitions on a routine
basis and modify the proposal to ensure
that providers have financial incentives
to provide optimal care for high-risk
patients with severe coronary artery
disease even if the initial treatment
episode has a higher cost. The
commenter expressed concern that
insufficient data were available at this
time to inform a clinical guideline
recommendation with regard to the
optimal timing of non-culprit vessel
PCI, and the proposed payment bundles
could encourage procedures that may
not provide the best clinical outcomes
for Medicare beneficiaries but instead
have financial benefits with respect to
the target price. As guidelines change
based on available data, CMS should
consider potential adjustments to
reconciliation to the episodes quality
adjusted target prices based on
guideline changes.
Response: As we noted in section
III.C.3.b. of this final rule, Medicare
payment for coronary stents, whether
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303
bare metal or DES, used during a PCI
performed during a hospitalization are
included in the IPPS payment for the
inpatient hospitalization. While they are
not paid separately by Medicare,
payment for the required resources
would be included in AMI episodes
because the IPPS services for the anchor
hospitalization are included in the
episodes. We propose to risk-stratify
EPM-episode prices based on MS–DRG
as discussed in section III.D.4.b.(1) of
this final rule and there are separate
MS–DRGs for PCIs that use DES (246
and 247) and non-DES (248 and 249) for
which there would be separate AMI
episode prices. Therefore, we do not
believe that the financial incentives
under the AMI model encourage the use
of any specific coronary stent because
the episode prices take into
consideration the IPPS payment for the
specific MS–DRG that applies to the
AMI model beneficiary. We do not
expect the AMI model to discourage the
appropriate use of DES. We would also
note, as stated in section III.D.4.b.(2), we
will be exploring additional
mechanisms to risk adjust payments
that should become available beginning
in PY3. We believe that these
adjustments will provide participants
further protections that should help
mitigate the concerns commenters
raised.
Likewise, we do not agree with
comments requesting payments in
addition to those currently made
available when participants adopt
specific or new technologies, provide
services for high-cost cases, or adopt
breakthrough technologies. The
purposes of the proposed models are to
improve care quality and efficiency
while better controlling Medicare cost
growth within a FFS framework. As
such, the models seek to achieve these
goals to the greatest extent possible
within the regulatory framework that
applies within FFS Medicare, and are
not intended to create new or substitute
payment mechanisms or processes for
establishing new payments under FFS
Medicare.
Comment: A commenter
recommended that when establishing
episode target payments, price
calculations should incorporate clinical
practice guidelines and appropriate use
criteria that are endorsed by all
stakeholders to ensure that patients are
not receiving inadequate care.
Response: We disagree with the
recommendation that prices should
include clinical practice guidelines as,
to the contrary, they are based on
Medicare FFS payments and their
historical utilization for services
included in the EPMs, and should not
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include specifications reflecting
normative criteria regarding clinical
practice guidelines, which could be
overly prescriptive for EPM participants
and provides and suppliers treating
EPM beneficiaries. That said, we would
assume that EPM participants would be
following clinical practice guidelines as
we would expect should also be the case
for services and paid under the
Medicare FFS program.
Comment: We received a comment
suggesting that CMS make payment
adjustments for cases where a
beneficiary receives the majority of their
post-acute care in a different MSA from
the MSA in which the anchor
hospitalization occurred. The
commenter presented an example where
a beneficiary with an anchor
hospitalization in Massachusetts
receives post-acute care in Florida. In
their view, the MSA in Florida could
have higher service utilization and
spending than the Massachusetts MSA
given different care practices. Further,
the commenter believed it was unlikely
that the hospital in Massachusetts could
have influence on a provider in another
distant MSA. The commenter
recommended a payment adjustment to
both avoid penalizing hospitals in the
initiating MSA and to help in not
deterring tertiary care facilities from
accepting patients that could not receive
necessary care in their own distant
MSA.
Response: As noted in section
III.C.4.a. of this final rule, we recognize
that in occasional circumstances, EPM
participants may have limited ability to
coordinate care, but that we generally
expect that much of the subsequent
coordination of post-acute care services
and other related services for EPM
beneficiaries during the 90 days postdischarge can be accomplished through
telecommunications that do not require
the patient to remain within the
geographic proximity of the hospital
responsible for the EPM episode. In that
section, we also noted that the design of
the EPMs does not preclude hospitals
from coordinating care with other
providers outside of their immediate
service area, that most EPM participants
have the tools to engage in effective
remote care coordination that results in
high quality episode care, and that we
finalized several waivers of Medicare
program rules, as discussed in section
III.J. of this final rule, to facilitate
efficient and effective episode care
coordination for beneficiaries in remote
or distant locations outside of the EPM
participant’s immediate community. We
also finalized policies for financial
arrangements in section III.I. of this final
rule that allow EPM participants to
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share upside and downside financial
risk with a variety of individuals and
entities who collaborate with the EPM
participant in redesigning care and
caring for EPM beneficiaries, regardless
of the geographic proximity of these
individuals and entities to the EPM
participant. Through financial
arrangements, EPM participants could
align the financial incentives of
providers in the EPM beneficiary’s
home community with the goals of the
EPM participant to improve the quality
and reduce the cost of EPM episodes.
Therefore, we do not believe it is
necessary to make a payment
adjustment when a beneficiary receives
post-acute care in a different MSA from
the MSA in which the anchor
hospitalization occurred. However, we
plan to monitor these occurrences and
could consider modifying our policy
should that be determined appropriate.
Comment: Several commenters
requested that CMS include more
flexibility with respect to payments for
post-acute care services under the
models. For example, some commenters
noted that while Medicare payments for
inpatient rehabilitation facility or longterm care hospital services are based on
a prospective amount, payments for
skilled nursing facility services are less
‘‘encompassing’’ and are based on a per
diem amount. Commenters suggested
that these differences can create an
unequal playing field and prevent
efficiencies that are realized from being
reflected in payments. As such,
commenters requested that CMS
identify flexibilities so that payments
among a broader array of post-acute care
providers could more closely reflect any
efficiencies that are realized, for
example, through payments on a per
diem basis or at a reduced rate.
Response: We appreciate the
suggestions commenters offered to
better align payments across post-acute
care providers. We will not be adopting
these suggestions for purposes of these
models as, to the greatest extent
possible, we want to test the effects of
bundled payments within the existing
FFS Medicare framework. We will
consider the applicability of the
suggestions offered, however, as we
explore future models that involve
payments for post-acute care services.
(2) Adjustments To Account for EPMEpisode Price Variation
We also considered further
adjustments to account for clinical and
resource variation that could affect EPM
participants’ costs for EPM episodes. As
was the case for the CJR model (80 FR
73338 through 73339), we stated our
belief that no standard risk adjustment
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approach that is widely-accepted
throughout the nation exists for the
proposed EPM episodes. Thus, we did
not propose to make risk adjustments
based on beneficiary-specific
demographic characteristics or clinical
indicators. Likewise, we questioned
whether CMS Hierarchical Condition
Categories (HCC) used to adjust for risk
in the Medicare Advantage program
would be appropriate for risk-adjusting
EPM episodes as such categories are
used to predict total Medicare
expenditures in an upcoming year for
MA plans and may not be appropriate
for use in predicting expenditures over
a shorter period of time, such as the
EPM episodes. Further, the validity of
HCC scores for predicting Medicare
expenditures for shorter episodes-ofcare or specifically for the AMI, CABG,
and SHFFT model episodes that we are
proposing has not been determined.
Thus, we did not propose to risk-adjust
EPM-episode benchmark or qualityadjusted target prices using HCC scores
for the EPMs. We referred to the CJR
Final Rule for additional discussion of
our assessment of risk-adjustment
options for the CJR model, which
informed our views on their
appropriateness for the EPMs (80 FR
73338 through 73340).
We also noted, however, that there are
circumstances that could account for
spending variation in EPM episodes
where certain pricing adjustments could
be appropriate. We identified several
scenarios where increased EPM-episode
efficiencies would be limited for certain
groups of EPM beneficiaries and a
standard EPM-episode benchmark price
based on the anchor MS–DRG would,
therefore, not account for circumstances
where clinically-appropriate care could
consistently result in higher EPMepisode payments. For example, as
discussed in section III.C.4.a.(5) of the
proposed rule, variation could arise
from the asymmetric distribution of
cardiac care across hospitals, which
makes transfers, either from a
hospitalization or from the emergency
department (without inpatient
admission) of one hospital to another, a
common consideration in the treatment
course for beneficiaries with an initial
diagnosis of AMI, resulting in a chained
anchor hospitalization for inpatient-toinpatient transfers. We also recognized
that certain episodes involving hospital
readmissions for clinically-appropriate
planned follow-up care may have higher
episode spending than episodes with a
single hospitalization or with chained
anchor hospitalizations involving
transfers that do not have any
readmissions. Further, a beneficiary
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who has a CABG in the context of
hospitalization for an AMI may have
different spending in the 90 days posthospital-discharge due to different
health needs than a beneficiary who has
an elective CABG. Accordingly, we
proposed specific policies and payment
adjustments in recognition of the
systematic, consistent variation in EPMepisode spending that could result from
such circumstances.
The following is a summary of the
comments received and our responses.
Comment: While one commenter
supported the proposal to risk-stratify
episode costs based largely on MS–
DRGs with additional adjustments for
scenarios including chained anchor
hospitalizations, readmissions, and
CABG, many commenters expressed
concerns that no further risk-adjustment
was proposed beyond the riskstratification inherent in the MS–DRGs
and CMS’ proposed adjustments for
such scenarios as chained anchor
hospitalizations or episodes involving
readmissions or CABG. These
commenters noted their views that the
absence of further risk-adjustment
would penalize hospitals treating the
sickest, most complicated, and most
vulnerable patients for factors that are
beyond the hospitals’ control. One
commenter reported that adequate riskadjustment is especially important as
CMS considers additional clinical
groups for bundling programs, such as
cardiac care or SHFFT patients, that are
more clinically heterogeneous than CJR
patients. MedPAC noted that it has
‘‘consistently found that chronic
conditions and advanced age play a
major role in explaining variation in
spending across beneficiaries. CMS
proposes no further risk-adjustments
beyond the DRG/subgroups but provides
no data to assess whether the proposed
stratification is sufficient to adjust for
differences in spending across
beneficiaries within each episode type.
The Commission urges CMS to evaluate
whether additional risk adjustment
strategies, such as comorbidities and
age, would improve the accuracy of the
benchmarks.’’
Many of the commenters pointed to a
recent study noting that the use of
region-based target pricing can lead to
reduced reconciliation payments for
hospitals.78 However, reconciliation
payments would substantially increase
for hospitals that treat patients with
high complexity and be reduced for
hospitals that treat patients with low
78 Ellimoottil C, Ryan AM, Hou H, et al.
Medicare’s New Bundled Payment For Joint
Replacement May Penalize Hospitals That Treat
Medically Complex Patients. Health Affairs. 2016:
35(9):1651–1657. doi: 10.1377/hlthaff.2016.0263.
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complexity when CMS–HCC scores are
applied. Some commenters cited
additional data in support of their views
that the absence of risk-adjustment
ignores the substantial variation in
episode payments that exists, penalizes
hospitals for assuming the risk of
higher-cost/higher-risk patients, or
potentially impedes access to high
quality care.
A number of commenters related the
absence of further risk-adjustment to
concerns with the proposal to phase-in
regionally determined target prices. For
example, commenters noted that the use
of a regional spending component will
hold all hospitals in a region to the same
target price, even though they would
have different clinical capabilities and
different risk profiles that results in
their treating patient populations with
differing levels of severity and costs,
which further buttressed the view that
substantial variation in episode
payments exist within each target price
category, not just between the target
price categories. Some commenters
expressed concerns that differences in
clinical capabilities, and therefore,
differing rates of more costly transfer
episodes, could penalize smaller
hospitals that do not have the most
sophisticated cardiac care available.
Some commenters expressed the view
that the absence of risk adjustment
would particularly affect hospitals that
typically treat more complex patients,
for example, tertiary hospitals or
hospitals that are academic medical
centers because the absence of risk
adjustment would not account for the
complexity of their patients, which
often included multiple co-morbidities,
longer lengths of stay, and higher costs.
As hospitals could view these patients
as increasing their financial risk under
the EPMs, commenters expressed
concerns that patients who suffer from
multiple chronic conditions or
comorbidities may find it more difficult
to find participating hospitals willing to
serve them.
Other commenters expressed concern
that hospitals serving communities with
a high percentage of lower income
patients could be adversely affected by
the absence of risk-adjustment.
Moreover, the lack of further riskadjustment could create a risk-adverse
environment with the possibility of
withholding appropriate care to patients
with moderate to high-risk profiles, for
example to women, due to their older
age at cardiac presentation and
minorities due to increased frequency of
clinical renal disorder. These
commenters noted that such patients
could have higher costs due to their age
or presence of multiple co-morbidities.
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305
Further, by not providing an adjustment
factor, there could be a greater chance
of transfer abuse whereby smaller
providers might shift risk for these
patients to tertiary providers by
transferring emergency room patients
that are at greater risk for complications
or readmissions.
Commenters also noted that CMS
appeared to be inconsistent and
contradictory in not proposing to apply
CMS–HCC scores for the proposed
models or for the CJR model when it
does so for similar programs and
applications. Specifically, commenters
observed that CMS–HCC scores are
applied to quality measures such as
Medicare Spending per Beneficiary
(MSPB), 30-day mortality and
readmission, as well as for the quality
measures proposed to be included
under the proposed models.
Commenters remarked that this gives
the impression of poor harmonization of
efforts within CMS, which leads to
fragmented programs.
Thus, the commenters requested that
CMS apply some kind of additional riskadjustment to the proposed models and
the CJR model at the latest before
downside risk begins. One commenter
noted that even if not ideal, further riskadjustment would be at least as good as
CMS’ proposal, but simpler and easier
to understand than the 75 different
target prices CMS proposed. Other
commenters recommended that CMS
explore and incorporate additional riskadjustment to address sociodemographic factors, in addition to
clinical factors, to more accurately
reflect the level of risk associated with
such beneficiary characteristics as
income and employment status. Further,
another commenter reported that sociodemographic factors such as the
availability of primary care, physical
therapy, easy access to medications and
appropriate food, and other supportive
services, which are beyond providers’
control, affect hospitals’ performance on
outcome measures.
Several commenters recommended
that CMS apply the CMS–HCC scores. In
their view, some benefits of these scores
is that they capture the severity of a
patient’s level of underlying illness,
better match hospital’s payment to the
complexity of their patients,
appropriately account for the expected
increase in utilization of health care
services, reduce the likelihood of a
Medicare repayment, and should be
administratively simple to apply given
their use for other efforts and programs
under Medicare. One commenter offered
that these codes could, at a minimum,
serve as a basis for CMS to begin to
construct an appropriate risk-
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adjustment for CJR episodes, as well as
for SHFFT episodes if it re-proposes
their implementation in the future.
Another commenter suggested that CMS
identify a means to adjust the CMS–
HCC codes so that they could better
apply to a 90-day episode. Moreover,
while encouraging further riskadjustment as soon as possible within
the period of the model, this commenter
also suggested that the proposed models
could be an opportunity to obtain the
data needed to develop EPM riskadjusters.
One commenter encouraged the use of
physician-defined patient condition
categories to ensure effective risk
stratification in condition-based
payment models. This commenter
reported that alternative payment
models that are designed to control
overuse need to incorporate effective
risk adjustment or risk stratification
components in order to protect patients
against underuse and to avoid
penalizing physicians for delivering and
ordering services that patients need. In
their view, CMS–HCCs and other
claims-based regression models are not
adequate for risk adjustment in
condition-based payment models.
Rather, condition-based payment
models must be risk stratified based on
the clinical characteristics and
functional status of patients that are
most relevant to the types of conditions
being managed.
Some commenters urged CMS to
improve the risk-adjustment
methodology by collaborating with the
clinical community and relevant
medical specialty societies such as the
cardiovascular community that have
experience with the different risks
facing patients who will be treated
within these episode models. Other
commenters recommended that CMS
review risk adjustment methodologies
used by other’s bundling models or to
incorporate data from the STS Risk
Calculator into the risk-adjustment
methodology or to use multiple model
to better predict the cost of care.
Commenters requested that CMS
expand risk-adjustment to other
provider types or measures factors in
addition to the patient alone. For
example, one commenter expressed
concern that CMS has no riskadjustment methodology in place for
patients’ transitions into the post-acute
and long-term care sector and that many
factors contribute to cost variation in
these milieu are outside of the control
of the facilities themselves. The
commenter requested CMS to clearly
define risk stratification indices and
develop a cost-to-risk algorithm based
on previous utilization data and
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incorporating specific, patient
characteristics, including functional
status, age, and frailty, to accurately
evaluate EPM performance. Another
commenter recommended that CMS
examine whether the CMS–HCC model
would be an appropriate way to
measure the resource use of geriatricians
as well as serve as a risk-adjustment
mechanism. Finally, one commenter
urged CMS to modify the riskadjustment policy to reflect the relative
riskiness of the procedures as well as
the beneficiary-specific demographic
characteristics and clinical indicators.
Response: We appreciate the
comment supporting our proposal to
risk-stratify episode costs based largely
on MS–DRGs with additional
adjustments for scenarios including
chained anchor hospitalizations,
readmissions, and CABG as well as the
many comments expressing concerns
about our proposal, data cited in
support of these concerns, requests for
additional measures to adjust for risk,
and suggestions on approaches to
consider for this purpose. We share
commenters’ interests in ensuring that
payments under the models are well
aligned with costs and adequately
recognize cost variation associated with
either the services provided or
beneficiary characteristics so that
participants are encouraged and able to
be successful under the models, which
includes providing access to high
quality care to Medicare beneficiaries.
In particular, we share commenters’
concerns that episode payments be more
closely aligned with costs when all EPM
participants will assume downside risk
and have their payments determined
more fully based on regional pricing.
Based on the comments we received,
we are persuaded to explore additional
measures with which we could adjust
EPM episode payments for risk to
complement our proposals to stratify
and adjust episode payments based on
type and combination of anchor MS–
DRGs included in an episode. As such,
we plan to examine a range of options
such as CMS–HCC scores, beneficiary
factors, clinical factors, pathways
including planned readmissions after
discharge for an acute cardiac event,
and other measures that potentially
further explain variation in costs,
including socio-demographic factors
such availability of primary care
services. As discussed in section
III.D.7.c.(2) of this final rule, CMS will
also consider and potentially
incorporate results from studies
conducted under the Improving
Medicare Post-Acute Care
Transformation ‘‘IMPACT’’ Act of 2014
(Pub. L. 113–183) with respect to
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factors, including socio-demographic
factors, that could affect resource use
under Medicare and the EPMs.
While we are optimistic that we will
be able to identify factors that explain
more variation in episode expenditures
than risk stratification alone, we
acknowledge that no combination of
adjustments will account for all
variation in episode expenditures. Still,
we intend to proceed with the models
and as discussed elsewhere in this rule
are finalizing other financial protections
like an extended period of no downside
risk (see section III.D. 2.c.), capping high
payment episodes (see section
III.D.3.d.), and more generous stop-loss
protections for certain hospitals (see
III.D.7.c.(1)). We also intend to engage
with and seek input from stakeholders
as we examine this range of options
prior to rulemaking.
Our goal is to make our refinements
to the pricing methodology to reflect
risk adjustment effective beginning in
PY3, which we would establish based
on a notice and comment rulemaking
process. As such, the additional
measures would apply to episodes
ending on or after January 1, 2019 and
that had anchor discharges occurring
after October 1, 2018 and thus be in
place at the time downside risk is
required.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal, without
modification, to risk-stratify episodes
based on adjustments to recognize the
combination of MS–DRGs and pathways
associated with an episode. We will also
explore and plan to implement
additional adjustments to account for
risk through rulemaking to be effective
in PY3.
(a) Adjustments for Certain AMI Model
Episodes With Chained Anchor
Hospitalizations
In section III.C.4.a.(5) of the proposed
rule, we stated that once an AMI model
episode is initiated at an AMI model
participant, the AMI model episode
continues under the responsibility of
that specific participant, regardless of
whether the beneficiary is transferred to
another hospital for further medical
management of AMI or
revascularization through PCI or CABG
during a chained anchor hospitalization.
Given there could be significant
differences between the discharge MS–
DRG from the hospital that initiates the
AMI episode and the hospital to which
a beneficiary is transferred, as well as
the Medicare payment associated with
these different MS–DRGs and the postdischarge spending for these
beneficiaries, we stated that it would be
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appropriate to adjust the AMI modelepisode benchmark prices for certain
AMI model episodes involving a
chained anchor hospitalization. More
specifically, we indicated that it would
be appropriate to make an adjustment
when a final hospital discharge MS–
DRG in the chained anchor
hospitalization is an anchor MS–DRG
under either the AMI or CABG model.
Thus, for episodes involving a chained
anchor hospitalization with a final
discharge diagnosis of any of AMI MS–
DRG 280–282, PCI MS–DRG 246–251
without an intracardiac ICD–CM
procedure code in any position on the
inpatient claim, or CABG MS–DRG 231–
236, we proposed to set a chain-adjusted
AMI model-episode benchmark price or
‘‘price MS–DRG’’ based on the AMI,
PCI, or CABG MS–DRG in the chained
anchor admission with the highest IPPS
weight. If a CABG MS–DRG occurred in
a chained anchor hospitalization that
was initiated with an AMI MS–DRG or
PCI MS–DRG without an intracardiac
ICD–CM procedure code in any position
on the corresponding inpatient claim,
we proposed that the AMI model
episode would begin with and be
attributed to the first hospital, and we
proposed to set the price MS–DRG to
the CABG MS–DRG in the chained
anchor hospitalization with the highest
IPPS weight.
If the price MS–DRG was an AMI or
PCI MS–DRG, we proposed to set the
episode benchmark price as the
307
standard AMI model-episode
benchmark price for the price MS–DRG,
subject to a possible adjustment for
readmission for CABG MS–DRGs, as
described in section III.D.4.b.(2)(c) of
the proposed rule. If the price MS–DRG
is a CABG MS–DRG, we proposed to set
the AMI model-episode benchmark
price as the CABG model-episode
benchmark price for the corresponding
CABG MS–DRG, with no further
adjustment in the event of a readmission
for CABG MS–DRGs.
Table 13 displays the weights for
CABG, PCI, and AMI MS–DRGs
established in the FY 2016 IPPS final
rule, which are subject to change each
FY through the annual IPPS rulemaking
(80 FR 49325 through 49886).
TABLE 13—FY 2016 IPPS WEIGHTS FOR MS–DRGS 231–236, 246–251, AND 280–282
MS–DRG
231
232
233
234
235
236
246
MS–DRG title
...............................................
...............................................
...............................................
...............................................
...............................................
...............................................
...............................................
247 ...............................................
248 ...............................................
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249
250
251
280
281
282
...............................................
...............................................
...............................................
...............................................
...............................................
...............................................
CORONARY BYPASS W PTCA W MCC .................................................................................
CORONARY BYPASS W PTCA W/O MCC .............................................................................
CORONARY BYPASS W CARDIAC CATH W MCC ................................................................
CORONARY BYPASS W CARDIAC CATH W/O MCC ............................................................
CORONARY BYPASS W/O CARDIAC CATH W MCC ............................................................
CORONARY BYPASS W/O CARDIAC CATH W/O MCC ........................................................
PERC CARDIOVASC PROC W DRUG–ELUTING STENT W MCC OR 4 + VESSELS/
STENTS.
PERC CARDIOVASC PROC W DRUG–ELUTING STENT W/O MCC ....................................
PERC CARDIOVASC PROC W NON–DRUG–ELUTING STENT W MCC OR 4 + VES/
STENTS.
PERC CARDIOVASC PROC W NON–DRUG–ELUTING STENT W/O MCC ..........................
PERC CARDIOVASC PROC W/O CORONARY ARTERY STENT W MCC ...........................
PERC CARDIOVASC PROC W/O CORONARY ARTERY STENT W/O MCC .......................
ACUTE MYOCARDIAL INFARCTION, DISCHARGED ALIVE W MCC ...................................
ACUTE MYOCARDIAL INFARCTION, DISCHARGED ALIVE W CC ......................................
ACUTE MYOCARDIAL INFARCTION, DISCHARGED ALIVE W/O CC/MCC .........................
We stated our belief that this proposal
could minimize potential disincentives
to AMI model participants from
transferring patients when different or
higher levels of care are needed. This is
because the AMI model-episode
benchmark prices we set would be more
representative of the AMI spending
based on the totality of care furnished
during the chained anchor
hospitalization and post-discharge
period within the AMI model episode
and for which the AMI model
participants would be held accountable.
We also stated our view that our
proposal could encourage AMI model
participants that frequently transfer
patients after admission to improve
their efficiency and the quality of care
by transferring beneficiaries needing
higher levels of care prior to hospital
admission and managing those
beneficiaries admitted to reduce the
need for later transfers.
As an alternative, we also considered
an approach where we would set the
target price taking into consideration
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Weights
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IPPS payments for both the MS–DRG
assigned to the first admission in the
chained anchor hospitalization and the
MS–DRG assigned to the final
admission in the chained anchor
hospitalization. We could apply this
approach to all AMI model participant
hospitals or to only a subset of hospitals
based on special situations that could
lead to more common transfer scenarios
that are unavoidable, such as small bedsize, rural location, interventional or
cardiac surgery capacity, or other
characteristic of the hospitals. All AMI
model episodes involving chained
anchor hospitalizations would include
at least two IPPS payments for the
chained anchor hospitalization,
compared to one IPPS payment for most
AMI episodes with only an anchor
hospitalization that does not result in an
inpatient-to-inpatient transfer. In our
view, the alternative approach would
likely result in a higher AMI-model
episode benchmark price than under
our proposal for AMI model episodes
including a chained anchor
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7.8056
5.7779
7.3581
4.9076
5.8103
3.8013
3.2494
2.1307
3.0696
1.9140
2.6975
1.6863
1.6971
1.0232
0.7557
hospitalization. Therefore, we noted
that this alternative approach could
have the effect of further reducing
potential disincentives to hospitals from
transferring patients when different or a
higher level of care is needed; however,
we were not convinced this approach
would ultimately improve care quality
and efficiency under the AMI model.
First, we were concerned that this
alternative approach could serve as an
incentive for hospitals to admit and
then transfer patients when doing so
might not be medically necessary,
which would neither enhance care
quality nor efficiency. A recent study
showed that non-procedure hospitals,
defined as hospitals that lack onsite
cardiac catheterization and coronary
revascularization facilities, vary
substantially in their use of the transfer
process for Medicare beneficiaries
admitted with AMI.79 Beneficiaries
79 Barreto-Filho J, Wang Y, Rathore SS, et al.
Transfer Rates From Nonprocedure Hospitals After
Initial Admission and Outcomes Among Elderly
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transferred from hospitals that had a
high transfer rate experienced greater
use of invasive cardiac procedures after
admission to the transfer hospital than
beneficiaries transferred from hospitals
with a low transfer rate. However,
higher transfer rates were not associated
with a significantly lower riskstandardized mortality rate at 30 days,
and at one year, there was only a 1.1
percent mortality rate difference
between hospitals with higher and
lower transfer rates. As such, we
believed this alternative approach could
be appropriate for only a subset of AMI
model participant hospitals based on
specific hospital characteristics that
could lead to a higher frequency of
unavoidable transfers for AMI model
beneficiaries rather than appropriate for
hospitals overall. In addition, if we were
to adopt this alternative approach, we
believed it would also be necessary to
incorporate methods for monitoring
changes in the frequency of AMI model
participant hospital patient transfers
over the model’s performance years, as
well as assessing the appropriateness of
those transfers. For example, to address
changes in transfer frequency, we might
compare how often an AMI model
participant hospital transferred a
beneficiary following an inpatient
admission within each performance
year relative to the frequency of
transfers during its initial 3-year
historical period. To address
appropriateness of transfers, we might
consider reviewing and comparing a
sample of a hospital’s transfers within a
performance year as compared to the
historical period. Furthermore, we
might also propose future changes to
this approach where changes in the
frequency or appropriateness of
transfers were identified.
Second, in contrast to our proposal,
we believed that this alternative
approach would not have the benefit of
encouraging AMI model participant
hospitals to make an early decision and
transfer patients prior to rather than
following inpatient admission when
doing so prior to admission would be
appropriate for the beneficiary’s clinical
circumstances and the hospital’s
capabilities. While we recognized that
in some cases, an AMI model
beneficiary admitted to the initial
treating hospital may need to be
transferred to a referral hospital that can
provide a different or higher level of
care, we noted our belief it is important
that the AMI model’s payment
methodology support the goal of rapid
Patients With Acute Myocardial Infarction. JAMA
Intern Med. 2014;174(2):213–222. doi:10.1001/
jamainternmed.2013.11944.
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decision-making by the AMI model
participant hospital about the AMI
model beneficiary’s care pathway based
on clinical guidelines that often
incorporate a time dimension in the
guidelines for care.
Thus, on balance, we believed that
our proposed methodology would best
establish appropriate incentives to
improve care quality and efficiency
under the AMI model by encouraging
timely decisions about admission to the
initial treating hospital and
incentivizing only those transfers that
are necessary to meet AMI model
beneficiary’s health care during the
course of their hospitalization. Our
proposal would adjust the AMI modelepisode benchmark price that applies to
the episode when a chained anchor
hospitalization occurs and results in
more costly care at the transfer hospital
than would be expected based on the
anchor MS–DRG at the initial treating
hospital who would be accountable for
the episode under the AMI model, thus
accounting for the care at the referral
hospital.
In contrast, some chained anchor
hospitalizations could begin an episode
based on an MS–DRG that anchors an
episode in the model such as an AMI
MS–DRGs that subsequently also
includes an MS–DRG that does not
anchor an episode under the model (for
example, heart failure, renal failure, or
cardiac valve replacement). Some of
these non-anchor MS–DRGs could be
related to the AMI episode but are
unavoidable, for example, cardiac valve
surgery, while others could potentially
reflect complications resulting from
inadequate care management during the
episode (for example, heart or renal
failure).
As discussed in section III.C.4.b. of
the proposed rule, we proposed to
cancel an AMI model episode when the
final MS–DRG in a chained anchor
hospitalization is from an MS–DRG that
would not an anchor MS–DRG under
the AMI or CABG model. We believed
that, in tandem, these proposals would
allow for appropriate pricing of AMI
model episodes that continue and
include chained anchor
hospitalizations.
The proposals to establish pricing for
AMI model episodes involving chained
anchor hospitalizations were included
in § 512.300(c)(7)(i). We sought
comment on our proposals for pricing
AMI episodes involving chained anchor
hospitalizations and the alternative
proposals we considered. We also
sought comment on the alternative
considered that would account for both
the MS–DRGs at the first and last
hospitals caring for the AMI model
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beneficiary during the chained anchor
hospitalization in setting the AMImodel episode benchmark price for
episodes involving a chained anchor
hospitalization. In particular, under
such an alternative, we sought comment
on the clinical circumstances in which
inpatient-to-inpatient transfers are
unavoidable and whether or not there
are hospital characteristics that would
lead us to expect higher frequencies of
unavoidable inpatient-to-inpatient
transfers for AMI model beneficiaries
than hospitals overall. We also sought
comment on how we could discourage
unintended consequences under this
alternative, such as less timely decisions
about the most appropriate hospital to
treat the beneficiary and increased
beneficiary transfers that are
unnecessary or inappropriate for
improved quality of AMI model episode
care.
The following is a summary of the
comments received and our responses.
Comment: As discussed earlier in
Section III.C.4.a. of this final rule, many
commenters expressed concerns and
opposed the proposal that once an AMI
model episode is initiated at an AMI
model participant, the AMI model
episode continues under the
responsibility of that specific
participant, regardless of whether the
beneficiary is transferred to another
hospital for further medical
management of AMI or
revascularization through PCI or CABG
during a chained anchor hospitalization.
Similarly, many commenters expressed
concerns with respect to the pricing of
episodes in the case of these chained
anchor hospitalizations that generally
paralleled the comments discussed in
section III.C.4.a. of this final rule.
Response: As discussed in section
III.C.4.a., we were persuaded by
commenters to not finalize our proposal
that once an AMI model episode is
initiated at an AMI model participant,
the AMI model episode would continue
under the responsibility of that specific
participant when a beneficiary is
transferred to another hospital for
further medical management of AMI or
revascularization through PCI or CABG
during a chained anchor hospitalization.
Instead, we are finalizing a policy that
for an episode involving an inpatient-toinpatient transfer, the episode would be
attributed to the transfer hospital rather
than the initial hospital.
Accordingly, we are also not
finalizing our proposed pricing
methodology for these episodes, which
would have set a chain-adjusted AMI
model-episode benchmark price or
‘‘price MS–DRG’’ based on the AMI,
PCI, or CABG MS–DRG in the chained-
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anchor admission with the highest IPPS
weight. Instead, we are finalizing a
policy where an episode’s price will be
determined only by the anchor MS–DRG
for the AMI or CABG model episode as
determined by the transfer hospital in
the same manner as we would for any
other AMI episode that does not involve
a transfer.
Since we are not finalizing our
original proposal, we also will not be
finalizing the terms ‘‘chained anchor
hospitalization’’ or ‘‘price MS–DRG’’ as
all episodes under the model will be
priced based on their assigned anchor
MS–DRG. Accordingly, we will be
deleting these terms from our proposed
regulations.
Final Decision: After consideration of
the public comments received, we are
not finalizing the proposal to make
payment adjustments for AMI episodes
involving a chained anchor
hospitalization, but will instead
attribute the episode to the final
hospital and calculate prices for these
episodes based on the anchor MS–DRG
for that episode determined by the
transfer hospital. As such, we are
replacing the term ‘‘price MS–DRG’’
with ‘‘MS–DRG’’ and deleting references
to ‘‘chained-anchor hospitalizations.’’
Also as discussed in section III.C.4.a.(5)
of this final rule, given our concerns
about the potential missed opportunities
and unintended consequences due to
the final AMI model transfer episode
initiation and attribution policy, we will
be examining AMI transfers to and from
AMI model participants very closely
through our monitoring and evaluation
activities as discussed in sections
III.G.4. through 6. and IV. of this final
rule, both of beneficiaries that
ultimately are included in AMI episodes
and those that are not. We may revisit
the transfer policy or propose payment
adjustments through future rulemaking
if we see reduced AMI transfer
efficiency, opportunities to increase
transfer efficiency, disproportionate
transfers of complex AMI beneficiaries
or those with potentially avoidable
complications suggesting that AMI
model participants are engaging in
adverse patient selection or providing
poor quality care, inordinate loss of
beneficiaries from the AMI model due to
transfer outside of the MSAs where the
AMI and CABG models are being tested,
or other patterns of concern.
(b) Adjustments for CABG Model
Episodes
Among Medicare beneficiaries
historically discharged under a CABG
MS–DRG, average episode spending was
substantially higher for those
beneficiaries who also had AMI ICD–
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CM diagnosis codes on their inpatient
claims ($57,000) than those who did not
($44,000).80 About 30 percent of CABG
beneficiaries had AMI ICD–CM
diagnosis codes on their claims, while
about 70 percent did not, and this
percentage of CABG beneficiaries with
AMI varied substantially across IPPS
hospitals furnishing CABG
procedures.81 While average spending,
in total, was substantially higher for
CABG beneficiaries with AMI than
without AMI, average spending during
the anchor hospitalization was not
substantially higher. Rather, much of
this variation in CABG model episode
spending occurred after discharge from
the anchor hospitalization and
correlated both with the presence of
AMI and whether the CABG beneficiary
was discharged from the anchor
hospitalization in a CABG MS–DRG
with major complication or comorbidity
(MS–DRGs 231, 233, or 235) as opposed
to a CABG MS–DRG without major
complication or comorbidity (MS–DRGs
232, 234, or 236). Specifically, we found
that average CABG episode spending
after discharge from the anchor
hospitalization was—
• $9,000 for non-AMI CABG
beneficiaries discharged from MS–DRGs
232, 234, or 236;
• $11,000 for CABG beneficiaries
with AMI discharged from MS–DRGs
232, 234, or 236;
• $16,000 for non-AMI CABG
beneficiaries discharged from MS–DRGs
231, 233, or 235; and
• $20,000 for CABG beneficiaries
with AMI discharged from MS–DRGs
231, 233, or 235.82
Thus, for CABG model episodes, we
proposed to set CABG model-episode
benchmark prices by first splitting
historical CABG model-episode
expenditures into expenditures that
occurred during anchor hospitalizations
and expenditures that occurred after
discharge from the anchor
hospitalizations.
We proposed to calculate the CABG
anchor hospitalization benchmark price
by following the general payment
methodology that was applied to the
80 Episodes for CABG model beneficiaries
initiated by all U.S. IPPS hospitals and constructed
using standardized Medicare FFS Parts A and B
claims, as proposed in this rule, that began in CYs
2012–2014.
81 Episodes for CABG model beneficiaries
initiated by all U.S. IPPS hospitals and constructed
using standardized Medicare FFS Parts A and B
claims, as proposed in this rule, that began in CYs
2012–2014.
82 Episodes for CABG model beneficiaries
initiated by all U.S. IPPS hospitals and constructed
using standardized Medicare FFS Parts A and B
claims, as proposed in this rule that began in CYs
2012–2014.
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309
CJR model (80 FR 73337 through
73358), with expenditures limited to
those that occurred during the anchor
hospitalization and risk stratification
according to the price CABG MS–DRG.
We also proposed to calculate the
CABG post-anchor hospitalization
benchmark price by following the
general payment methodology that was
applied to the CJR model (80 FR 73337
through 73358), with expenditures
limited to those that occurred after the
anchor hospitalization and riskstratification according to the presence
of an AMI ICD–CM diagnosis code on
the anchor inpatient claim and whether
the price MS–DRG is a CABG MS–DRG
with major complication or comorbidity
(231, 233, or 235) or a CABG MS–DRG
without major complication or
comorbidity (232, 234, or 236).
We proposed that the CABG modelepisode benchmark price for an episode
would be the sum of the corresponding
CABG anchor hospitalization
benchmark price and the corresponding
CABG post-anchor hospitalization
benchmark price, as discussed in this
section and in III.D.4.d. of the proposed
rule.
The proposals to establish pricing for
CABG model episodes were included in
§ 512.300(c)(7)(ii). We sought comment
on our proposals to establish pricing for
CABG model episodes.
The following is a summary of the
comments received and our responses.
Comment: One commenters suggested
that CMS create a separate target price
for CABG episodes where a patient has
a previous history of CABG.
Response: We appreciate the
commenter’s suggestion, but believe the
existing MS–DRGs that apply under the
IPPS, which similarly do not distinguish
CABG MS–DRG discharges based on
whether or not a beneficiary had a
previous history of CABG, our proposed
pricing adjustments for CABG episodes,
and additional risk-adjustments that we
anticipate will be effective in PY3
should appropriately recognize the
potential costs for beneficiaries within
CABG episodes whether or not they had
a previous history of CABG.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal, without
modification, to establish pricing for
CABG model episodes. Our final policy
for establishing CABG model episodes is
included in § 512.300(c)(7)(i).
(c) Adjustments for Certain AMI Model
Episodes With CABG Readmissions
In section III.C.4.b of the proposed
rule, we discussed AMI model episodes
where a beneficiary is discharged from
an AMI model participant under an AMI
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MS–DRG and is later readmitted for a
CABG. In that section, we did not
propose to cancel the AMI model
episode altogether for a CABG
readmission during the 90-day posthospital discharge period or cancel the
AMI model episode and initiate a CABG
model episode because planned CABG
readmission following an anchor
hospitalization that initiates an AMI
episode may be an appropriate clinical
pathway for certain beneficiaries. For
example, we noted that historically
approximately 10 percent of those AMI
beneficiaries who received CABGs
during AMI episodes would receive the
CABG between 2 and 90 days postdischarge from the anchor
hospitalization, and most of those
readmissions did not occur through
hospital emergency departments. Even
though CABG readmissions are not
excluded from AMI model episodes
(because they are clinically-related to
the AMI model episode), we proposed
to provide an adjusted AMI modelepisode benchmark price in such
circumstances so as not to financially
penalize AMI model participants for
relatively uncommon, costly, clinicallyappropriate care patterns for AMI model
beneficiaries. Accordingly, we proposed
to establish an adjusted CABGreadmission AMI model-benchmark
episode price for AMI model episodes
with a price MS–DRG of 280–282 or
246–251 that have readmission for a
CABG MS–DRG 231–236.
Specifically, if a CABG readmission
occurs during an AMI model episode
with a price MS–DRG of 280–282 or
246–251, we proposed to calculate a
CABG-readmission AMI model-episode
benchmark price equal to the sum of the
standard AMI model-episode
benchmark price corresponding to the
price MS–DRG (AMI MS–DRGs 280–282
or PCI MS–DRGs 246–251) and the
CABG anchor hospitalization
benchmark price corresponding to the
MS–DRG of the CABG readmission.
Because the adjustment would be based
on the anchor hospitalization
benchmark price, which does not
include costs associated with the postdischarge period for CABG, this
adjustment approach would avoid
‘‘double counting’’ post-discharge costs.
Because adjusting for spending that
occurred during a CABG readmission
accounts for most of the spending
variation between AMI model episodes
with a CABG readmission and AMI
model episodes without a CABG
readmission, we proposed no additional
adjustment to the price for AMI model
episodes with a CABG readmission.
In the event of any other readmission
other than CABG during an AMI model
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episode that is not excluded from the
AMI model episode definition, we
would apply the usual rules of EPMepisode pricing that would include the
spending for the related readmission in
the actual AMI model-episode spending,
without other adjustments. Fewer than
3 percent of those AMI model
beneficiaries who receive inpatient or
outpatient PCIs during AMI episodes
receive the PCIs between 2 and 90 days
post-discharge from the anchor or
chained anchor hospitalizations, and we
did not propose to make a pricing
adjustment for PCIs that occur later in
the AMI model episodes after discharge
from the anchor or chained anchor
hospitalizations. Since a PCI for an AMI
typically is provided during the anchor
or chained anchor hospitalization and
most PCIs later in an episode occur in
the context of a beneficiary presenting
through the emergency department, we
believe that the beneficiary likely has
experienced a complication of care
resulting in a PCI that may potentially
be avoided through care management
during the AMI model episode. Given
that our intention is to offer appropriate
incentives for care quality and
efficiency by holding AMI model
participants accountable for
readmissions that could be related to the
quality of care provided prior to the
readmission, we believe that an
adjustment other than for a CABG
readmission would not be appropriate.
The proposal for adjusting episodes
involving CABG readmissions was
included in § 512.300(c)(7)(iii). We
sought comment on our proposal for
adjusting episodes involving CABG
readmissions.
The following is a summary of the
comments received and our responses.
Comment: Several commenters
expressed concerns about the proposal
for adjusting episodes involving CABG
readmissions—specifically, that the
proposal does not sufficiently account
for the increased post-acute care that a
beneficiary typically receives after a
CABG, but which they would not
receive after only an AMI. One of the
commenters presented data supporting
their concern suggesting that postdischarge spending for certain MS–
DRGs with a CABG readmission was
substantially higher than for those same
MS–DRGs without a CABG readmission.
The commenters requested that CMS
modify the methodology to account for
the increased post-acute care that a
beneficiary typically receives after a
CABG.
Response: We appreciate the concerns
raised by the commenters and have
conducted further analysis of our
proposal with respect to how well our
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proposal would account for post-acute
care costs for AMI episodes involving
CABG readmissions. While we agree
that spending after discharge from the
anchor stay for AMI episodes with
CABG readmissions is substantially
higher than for episodes without these
readmissions, we disagree with
suggestions that our proposal
inadequately adjusts for these
differences. Rather, based on our
analysis, on average, the proposed
adjustments account for the
overwhelming majority of additional
spending that occurs in AMI episodes
with CABG readmissions relative to
episodes without CABG readmissions.
Additionally, the number of episodes
for many of the affected MS–DRGs is
relatively small, which we believe
would impede our ability to establish
reliable prices that would be an
improvement over our current proposal
in terms of payment accuracy.
Accordingly, we are not persuaded to
modify our proposal.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal, without
modification, to adjust episodes with
CABG readmissions. Our final policy for
adjusting episodes with CABG
readmissions is included in
§ 512.300(c)(7)(ii).
(d) Potential Future Approaches To
Setting Target Prices for AMI and Hip
Fracture Episodes
As previously described, our
proposed approach for pricing AMI and
CABG model episodes for beneficiaries
with AMI set different episode target
prices depending upon whether the
beneficiary is managed medically,
undergoes PCI, or undergoes CABG
during the acute phase of the episode,
as well as whether the episode involved
a chained anchor hospitalization or
CABG readmission. Similarly, the target
price set for beneficiaries experiencing
hip fracture would depend on whether
the patient undergoes hip fixation (and
therefore initiates a SHFFT model
episode) or hip arthroplasty (and
therefore initiates a CJR model episode).
We believed that this would be a
prudent approach that both recognizes
the resource costs of services provided
while encouraging care redesign during
the portions of these episodes that we
believe present the greatest
opportunities to improve the quality
and efficiency of the care delivered.
However, we noted that the general
principle guiding our payment reform
efforts is that the payment system
should hold providers accountable for
the overall quality and cost of the care
their beneficiaries receive rather than
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setting their payment based on the
specific services delivered or settings in
which they are delivered. We indicated
that this approach would give providers
maximum flexibility to redesign care in
ways that both produce the best
outcomes for patients and controls the
growth in spending for these services.
For this reason, we expressed interest
in exploring future approaches to
episode payment that would set an
inclusive target price for episodes for
beneficiaries with AMI that does not
depend on whether the beneficiary is
managed medically or receives PCI or
CABG during the acute portion of the
episode and, similarly, future
approaches that would set prices for
episodes for beneficiaries with hip
fracture that do not depend on whether
the beneficiary undergoes hip fixation
or hip arthroplasty. While we believe
that the choice of treatment during the
acute phase of these episodes may be
determined predominantly by clinical
factors such that financial factors may
play a smaller role in shaping episode
care redesign than they do following
hospital discharge, we nevertheless
believe it would be valuable to consider
testing an inclusive episode payment
model. Providers may be able to
redesign and implement care pathways
that we might not have otherwise
anticipated, especially as the evidencebase for AMI and hip fracture treatment
continues to grow and evolve.
We sought comment on this type of
approach to setting an inclusive episode
target price and on any episode payment
model design features that would be
needed to make such an approach
successful. In particular, we sought
comment on potential approaches to
risk-adjustment aimed at ensuring that
providers are appropriately paid for
caring for high-complexity episode
beneficiaries in the context of this
alternative approach. We would seek to
ensure that all providers caring for these
episode beneficiaries, including those
providers for which we proposed
additional protections and those that
serve a high percentage of potentially
vulnerable populations of medically and
socially complex patients as discussed
in section III.D.7.c. of the proposed rule,
would not bear undue financial risk and
to mitigate any incentives to avoid
caring for high-complexity patients. In
addition, we sought comment on
whether and how our methodology
linking quality performance to payment
under the EPMs and the CJR model
might need to be modified in the
context of this alternative approach that
would set an inclusive episode target
price, in order to appropriately
incentivize the delivery of high-quality
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care and discourage stinting on
appropriate care.
The following is a summary of the
comments received and our responses.
The comments we received typically
recommended that we consider either
population-based models or capitated
models, which we have addressed in
section III.D.2.b. of this final rule;
however, we are providing some
specific examples that were
recommended in the following
comments.
Comment: A commenter
recommended that we consider a
population-based model that was tied to
an ‘‘event’’ such as a beneficiary’s initial
Medicare enrollment in a selected
geographic area such as a county or
MSA; however, we should exclude
Medicare Advantage enrollees or
enrollees participating in other
Medicare payment reform efforts. The
model would include multiple quality
measures reflecting both a clinical
perspective and a beneficiary
perspective. The model could include
two tracks: Full financial accountability
and partial financial accountability.
Under the first track, we would pay
participating providers a monthly, allinclusive, beneficiary-risk-adjusted
premium based on regional historical
expenditures and the provider would
assume full risk for all Part A and Part
B expenditures. Under the partial
financial accountability track, we would
continue to provide the plan
administration (allowing provider
organizations without claims-payment
and risk-assumption capabilities the
opportunity to participate). Model
participants would receive a monthly,
beneficiary-risk-adjusted target budget
for Medicare Part A and Part B services
and their actual expenditures would be
compared against their target budget at
the end of each year for reconciliation.
If costs exceeded the target, then the
participant would repay CMS an agreed
upon amount. If costs were below the
target, then CMS would pay the
participant an agreed upon amount.
Both tracks could be eligible for
Advanced APM designation under the
Quality Payment Program, if they had a
certified Electronic Health Record
technology requirement for participants.
Another commenter, who had
suggested that CMS adopt a model
including prospective negotiated rates
rather than retrospective reconciliation
of fee-for-service claims, suggested that
a capitated model would allow
providers to experiment with services,
in addition to telehealth consultations,
that do not generate a fee-for-service
claim. In their view, hospitals and
surgeons have more opportunity to
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311
innovate in how they deploy
professional staff, choose technology,
and engage with outpatient and homebased services when they have full
flexibility within a budgeted payment
amount, and would encourage
collaboration between all clinicians
involved in patient care as well as
provide predictable pricing. Also, the
commenter believes that using
prospectively determined negotiated
rates or competitive bids would result in
a more rapid transformation in cost and
resource use. In their view, using target
prices based on a provider’s historical
costs or the region’s average costs is
inconsistent with the goal of
implementing innovative payment
models. Moreover, current practice
patterns should not be used to set a total
cost for care, given the unnecessary
care, excessive costs and cost variations
that result from this payment approach.
As such, this commenter recommend
that providers competitively bid their
episode price to encourage competition
among providers to achieve the best
outcomes for the lowest cost.
A commenter recommended that CMS
design EPMs that would allow providers
two options; specifically to (1) organize
themselves in the manner most efficient
to accept a prospective bundled
payment from Medicare, and allocate it
among the participating providers or (2)
if other providers find it easier to
continue billing under current payment
systems, then retrospectively reconcile
those payments against a prospectively
defined budget. In this commenter’s
view, jointly-governed teams should
have the flexibility to determine which
organizational approach and
retrospective or prospectivelydetermined payment model best works
for their particular circumstances.
Another commenter suggested that
CMS consider a model that pays
specialists for management of specific
conditions and combinations of
conditions using the same payment
model concepts being used with
primary care physicians in the
Comprehensive Primary Care Plus
initiative. Under this model, CMS
should focus accountability on services
directly related to the condition, rather
than total spending on all of the
patients’ health care needs and for
which the physician may be unable to
control. Further, the model would
encourage the use of physician-defined
patient condition categories to ensure
effective risk stratification in conditionbased payment models. These models
would be risk stratified based on the
clinical characteristics and functional
status of patients that are most relevant
to the types of conditions being
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managed. Patients could designate the
physician who would be managing care
for their condition(s) but would be
required to use the team of providers
chosen by that physician for delivery of
services related to the condition(s).
Further, target spending amounts would
be set for condition-based payments and
episode payments prior to the beginning
of the performance period. Finally,
physicians and other providers could be
for high-value services that are not
currently billable as part of condition-
based and episode-based payment
models that use retrospective
reconciliation.
Another commenter noted that while
not recommending a specific
framework, CMS should consider
additional geographic-based models that
include other costly procedures that
vary in total episode costs, for example,
spine surgery.
Response: We appreciate the
comments and suggestions that were
offered and that while not adopting
these suggestions for these models, we
will take them into consideration as we
explore similar models in the future.
(e) Summary of Final Pricing
Methodologies for AMI, CABG, and
SHFFT Model Episode Scenarios
Tables 14 through 16 summarize our
final standard pricing methodologies
and the adjustments that will occur that
are in sections III.D.4.b.(1) and (2) of
this final rule for AMI, CABG, and
SHFFT model episodes.
TABLE 14—AMI MODEL PRICING SCENARIOS
AMI pricing scenario
Price
Single hospital AMI MS–DRG or PCI MS–DRG (with AMI diagnosis) ....
Episode benchmark price is standard episode benchmark price based
on anchor MS–DRG.
Episode benchmark price is the sum of the standard episode benchmark price corresponding to the anchor MS–DRG and the CABG anchor hospitalization benchmark price corresponding to the CABG readmission MS–DRG.
An AMI MS–DRG or PCI MS–DRG (with AMI diagnosis) anchored episode with CABG readmission.
TABLE 15—CABG MODEL PRICING SCENARIOS
CABG pricing scenario
Price
Single hospital CABG MS–DRG with AMI diagnosis ...............................
Episode benchmark price is the sum of the CABG anchor hospitalization benchmark price for the MS–DRG and the CABG post–anchor
hospitalization benchmark price based on the presence of an AMI
ICD–CM diagnosis code and whether the anchor MS–DRG is w/
MCC or w/o MCC.
Episode benchmark price is the sum of the CABG anchor hospitalization benchmark price for the MS–DRG and the CABG post–anchor
hospitalization benchmark price based on no AMI ICD–CM diagnosis
code and whether the anchor MS–DRG is w/MCC or w/o MCC.
Single hospital CABG MS–DRG without AMI diagnosis ..........................
TABLE 16—SHFFT MODEL PRICING SCENARIOS
SHFFT pricing scenario
Price
SHFFT MS–DRG ......................................................................................
Episode benchmark price is standard episode benchmark price based
on anchor MS–DRG (which is the price MS–DRG).
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(3) Three Years of Historical Data
As was the case for the CJR model (80
FR 73340 through 73341), we proposed
to use 3 years of historical EPM
episodes for calculating EPM
participants’ EPM-episode benchmark
prices, with each set of historical
episodes updated every other year (81
FR 50854). Under our proposal, each of
the first 2 years of historical data would
be trended to the most recent of the 3
years, based on national trend factors for
each combination of price MS–DRGs
and payments would be updated for
each payment system (for example,
IPPS, PFS, etc.) based on annual
changes in input costs (see sections
III.D.4.b (4) and III.D.4.b (5) of the
proposed rule). Under our proposal, we
would establish historical EPM-episode
payments based on episodes that started
between—
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• January 1, 2013 and December 31,
2015 for performance years 1 and 2;
• January 1, 2015 and December 31,
2017 for performance years 3 and 4; and
• January 1, 2017 and December 31,
2019 for performance year 5.
We believe that 3 years of historical
EPM-episode data should provide
sufficient historical episode volume to
reliably calculate EPM-episode
benchmark prices, and that updating
these data every other year would allow
us to make the most current claims data
available in a way that incorporates the
effects of regular Medicare payment
system updates and changes in
utilization without creating uncertainty
in pricing for EPM participants. We
would further note that the effects of
updating EPM-participant hospitalspecific data on an EPM-episode’s
benchmark prices would diminish over
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time as the contribution of regional
pricing on EPM benchmark prices will
increase from one-third for performance
years 1 and 2 to two-thirds in
performance year 3, and 100 percent in
performance years 4 and 5.
The proposal for 3 years of historical
data updated every other year under the
EPMs was included in § 512.300(c)(1).
We sought comment on our proposal
for 3 years of historical data updated
every other year.
The following is a summary of the
comments received and our responses.
Comment: Some commenters
requested that CMS apply more trend
data than the 3 years we proposed. A
commenter expressed concern that in
the absence of several years of historical
data, target setting would not fully
reflect case mix and behavior changes in
addition to historical claims patterns.
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Further, an impact of a focus on shortterm costs may be a shift away from new
technologies proven to improve
outcomes and reduce costs. Another
commenter requested an additional 2
years of trend data for Program Year 1,
to bring the data up from 2015 to the
2017 program level and another 3 years
of trend data to bring the 2015 claims
up to the 2018 level. A commenter
requested that the process be open and
transparent so as to insure that all
impacted collaborators are given the
information and opportunity to
comment and adjust.
Response: We continue to believe our
proposed period for 3 years of historical
data updated every other year is
appropriate for the models. We disagree
that including additional years of data
beyond those we proposed would be
necessary or helpful. Instead, rather
than improving our historical data, the
request for additional years of data
could result in more heterogeneous
historical data that is less reflective of
a participant’s most recent performance.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal, without
modification to use 3 years of historical
EPM episodes for calculating EPM
participants’ EPM-episode benchmark
prices, with each set of historical
episodes updated every other year. The
final policy for using 3 years of
historical EPM episodes for calculating
benchmark prices is included in
§ 512.300(c)(1).
(4) Trending Historical Data to the Most
Recent Year
We recognize that some payment
variation could exist in the 3 years of
historical EPM-episode data due to
annual Medicare payment system
updates (for example, IPPS, OPPS, IRF
PPS, SNF PPS) and national changes in
utilization patterns. Thus, EPM episodes
in the third year of the 3 historical years
might have higher average payments
than those from the earlier 2 years, in
part due to Medicare payment rate
increases over the course of the 3-year
period. Also, EPM-episode payments
could change over time due to national
trends reflecting changes in industrywide practice patterns. For example,
readmissions for all patients, including
those in CABG model episodes, may
decrease nationally due to improved
industry-wide surgical protocols that
reduce the chance of infections. We do
not intend for the incentives under the
EPMs to be affected by Medicare
payment system rate changes that are
beyond EPM participants’ control or to
provide reconciliation payments to (or
require repayments from) EPM
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participants for achieving lower (or
higher) Medicare expenditures solely
because they followed national changes
in practice patterns. Instead, we aim to
incentivize EPM participants to improve
care quality and efficiency based on
their hospital-specific inpatient and
post-discharge care practices under the
EPMs.
To mitigate the effects of Medicare
payment system updates and changes in
national utilization practice patterns on
the 3 years of historical episode data, we
proposed to apply a national trend
factor to each of the years of historical
EPM-episode payments (81 FR 50855) as
we do with the CJR model (80 FR 73341
through 73342). Specifically, we
proposed to inflate the 2 oldest years of
historical EPM-episode payments for
EPM episodes to the most recent year of
the 3 historical years using changes in
the national EPM-episode payments for
each different type of EPM episode.
That is, we proposed to apply separate
national trend factors for the following
pricing scenarios:
• SHFFT model episodes, separately
by each price MS–DRG in 480–482.
• AMI model episodes without CABG
readmissions, separately by each price
MS–DRG in 280–282 and 246–251; and
• The anchor hospitalization portion
of CABG model episodes, separately by
each price MS–DRG in 231–236.
• The post-anchor hospitalization
portion of CABG model episodes,
separately for:
++ With AMI ICD–CM diagnosis code
on the anchor inpatient claim and
CABG price MS–DRG with major
complication or comorbidity (231, 233,
or 235);
++ With AMI ICD–CM diagnosis code
on the anchor inpatient claim and
CABG price MS–DRG without major
complication or comorbidity (232, 234,
or 236);
++ Without AMI ICD–CM diagnosis
code on the anchor inpatient claim and
CABG price MS–DRG with major
complication or comorbidity (231, 233,
or 235); and
++ Without AMI ICD–CM diagnosis
code on the anchor inpatient claim and
CABG price MS–DRG without major
complication or comorbidity (232, 234,
or 236).
For example, when using Calendar
Year (CY) 2013 through 2015 historical
EPM-episode data to establish EPMepisode benchmark prices for
performance years 1 and 2, we would
calculate an aggregate national average
SHFFT model episode payment in
historical episodes with price MS–DRG
480 for each of the 3 historical years. To
trend historical payments to the most
recent year in an historical window, we
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313
would create a ratio based on national
average historical EPM-episode payment
for that episode type in a previous year
and for the most recent year. Thus, in
this example, we would create a ratio of
national average SHFFT model
historical episode payment with price
MS–DRG 480 in CY 2015 as compared
to that national average SHFFT model
historical episode payment in CY 2013
in order to trend the CY 2013 historical
SHFFT model episode payments to CY
2015. Similarly, we would determine
the ratio of the national average SHFFT
model historical episode payment for
CY 2015 to national average SHFFT
model historical episode payment in CY
2014 to trend 2014 SHFFT model
episode payments to CY 2015. This
process would be repeated for each
pricing scenario previously listed.
We noted our belief that this method
for trending data would capture updates
in Medicare payment systems as well as
national utilization pattern changes that
might have occurred within that 3-year
period. Moreover, as with the CJR
model, we believed that adjusting for
national rather than regional trends in
utilization would be most appropriate as
any Medicare payment system updates
and significant changes in utilization
practice patterns would not be regionspecific but rather be reflected
nationally.
The proposal for trending historical
data was included in § 512.300(c) (11).
We sought comment on our proposal for
trending historical data.
The following is a summary of the
comments received and our responses.
Comment: A few commenters
addressed the use and trending of
historical data. A commenter expressed
their general agreement with the
proposed trending methodology, but
recommended that CMS update prices
every other year rather than annually to
limit the extent that participants would
face increasingly more difficult targets.
Another commenter recommended that
CMS trend the initial 3 years of
historical data for the full five years of
the models. A commenter suggested that
CMS apply more trend data to each
performance year and expressed
concerns that while CMS would trend
data to the end of the benchmark 3-year
period, CMS would not be trending data
from the end of the benchmark period
to match the time period for which the
prices will be applied to pay providers.
Response: We appreciate the
comments we received on our proposal
to trend data and would like to clarify
that their application would be on a
semi-annual basis when we update
target prices rather than annually. We
disagree with the suggestion to apply
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the 3 initial years of trend data to all
five performance years as our intention
is to establish target prices for the
models using more recent performance
data so as to maintain incentives for
participants to continuously improve.
Similarly, we disagree with the
suggestion to expand the number of
years used to trend data or to
permanently relate trend data for a
given performance year to those data for
the initial 3-year benchmark period as
doing so would result in data that are
less representative of a participant’s
most recent performance.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal, without
modification, to trend data. Our final
policy for trending data is included in
§ 512.300(c) (11).
(5) Update Historical EPM-Episode
Payments To Account for Ongoing
Payment System Updates
As previously mentioned, we
proposed to prospectively update the
historical EPM- episode payments to
account for ongoing updates to
Medicare payment systems (for
example, IPPS, OPPS, IRF PPS, SNF,
PFS, etc.) in order to ensure we
incentivize EPM participants based on
historical utilization and practice
patterns, not Medicare payment system
rate changes that are beyond hospitals’
control. Under our proposal (81 FR
50855), we would apply the same
methodology developed for the CJR
model to incorporate Medicare payment
updates (80 FR 73342 through 73446).
Because Medicare payment systems
rates are not updated at the same time
during the year—for example, rates
under the IPPS, IRF PPS, and SNF
payment systems are updated effective
October 1, while the hospital OPPS and
MPFS rates are updated annually
effective January 1—we proposed to
generally update historical EPM-episode
payments and calculate EPM-episode
benchmark prices separately for EPM
episodes initiated between January 1
and September 30 versus October 1 and
December 31 of each performance year,
and at other intervals if determined
necessary. The EPM-episode benchmark
price in effect as of the day the EPM
episode is initiated would be the EPMepisode benchmark price for the whole
EPM episode. Note that for performance
year 5, the second set of EPM-episode
benchmark prices would be for EPM
episodes that start and end between and
including October 1 and December 31
because the fifth performance period of
the SHFFT, CABG, and AMI models
would end on December 31, 2021. Also,
an EPM episode benchmark price for a
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given EPM performance year could be
applied to EPM episodes included in
another performance year. For example,
an EPM episode initiated in November
2017, and ending in February 2018
would have an EPM-episode benchmark
price based on the second set of 2017
EPM-episode benchmark prices (for
EPM episodes initiated between October
1, 2017, and December 31, 2017), and it
would be captured in the CY 2018 EPM
performance year (performance year 2)
because it ended between January 1,
2018, and December 31, 2018. We refer
to section III.D.2.a. of this final rule for
further discussion on the definition of
EPM performance years.
We proposed to update historical
EPM-episode payments by applying
separate Medicare payment system
update factors each January 1 and
October 1 to each of the following six
components of each EPM participant’s
historical EPM-episode payments:
• Inpatient acute.
• Physician.
• IRF.
• SNF.
• HHA.
• Other services.
A different set of update factors
would be calculated for January 1
through September 30 versus October 1
through December 31 EPM episodes
each EPM performance year. The six
update factors for each of the previously
stated components would be EPMparticipant hospital-specific and would
be weighted by the percent of the
Medicare payment for which each of the
six components accounts in the EPM
participant’s historical EPM episodes.
The weighted update factors would be
applied to historical EPM-participantspecific average payments to
incorporate ongoing Medicare payment
system updates. A weighted update
factor would be calculated by
multiplying the component-specific
update factor by the percent of the EPM
participant’s historical EPM-episode
payments the component represents,
and summing together the results. Each
of an EPM participant’s six update
factors would be based on how inputs
have changed in the various Medicare
payment systems for the specific EPM
participant.
As an example, we would assume for
purposes of this example that 50 percent
of an EPM participant’s historical EPMepisode payments were for inpatient
acute care services, 15 percent were for
physician services, 35 percent were for
SNF services, and 0.0 percent were for
the remaining services. We would also
assume for purposes of this example
that the update factors for inpatient
acute care services, physician services,
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and SNF services are 1.02, 1.03, and
1.01, respectively. The weighted update
factor in this example would be the
following: (0.5 * 1.02) + (0.15 * 1.03) +
(0.35 * 1.01) = 1.018. The EPM
participant in this example would have
its historical average EPM-episode
payments multiplied by 1.018 to
incorporate ongoing payment system
updates. The specific order of steps, and
how this step fits in with others, is
discussed further in sections III.D.4.c
through d. of the proposed rule. Also, as
discussed further in sections III.D.4.c.
through d. of the proposed rule, the
update factors would vary by price MS–
DRG. For example, in CABG model
episodes, the update factors would be
calculated separately for the anchor
hospitalization portion of episodes and
the post-anchor hospitalization portion
of episodes, as described in section
III.D.4.d. of the proposed rule.
Region-specific update factors for
each of the previously stated
components and weighted update
factors would also be calculated in the
same manner as the EPM-participantspecific update factors. Instead of using
historical EPM episodes attributed to a
specific hospital, region-specific update
factors would be based on all historical
EPM episodes initiated at any IPPS
hospital within the region with
historical EPM episodes, regardless of
whether or not the MSAs in which the
hospitals are located were selected for
inclusion in the models. We referred to
the CJR Final Rule (80 FR 73342 through
73446) for further discussion of our
specific methodology and
considerations for adopting this
methodology for updating historical
EPM-episode payments for ongoing
payment system updates.
The proposal for updating episode
payments for ongoing annual Medicare
payment updates was included in
§ 512.300(c)(10). We sought comment on
our proposal for updating episodes
payments for ongoing annual Medicare
payment updates. We received no
specific comments on our proposal for
updating historical EPM-episode
payments to account for ongoing
payment system updates. However, we
wish to highlight that, as we do for the
CJR model (80 FR 73343 through
73344), where an equation is used to
calculate update factors for payment
systems that apply annual updates to
their rates effective October 1 of each
year such as for inpatient acute, SNF,
and IRF services, in lieu of calculating
the update factors using the values
applicable at the end of the latest
historical year used to calculate target
prices, we use a blend of the values
applicable during the latest historical
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year. This blend is intended to account
for the payment systems that update
payment rates on a fiscal year cycle, and
ensure we are calculating update factors
based on the payment rates that apply
to a given period to the extent feasible,
and result in more accurate target price
calculations.
Final Decision: We are finalizing the
proposal, without modification, to
update episode payments for ongoing
annual Medicare payment updates. The
final policy for updating episode
payments for ongoing annual Medicare
payment updates is included in
§ 512.300(c)(10).
(6) Blend Hospital-Specific and
Regional Historical Data
We proposed to calculate EPMepisode benchmark prices using a blend
of EPM-participant-specific and regional
historical average EPM-episode
payments, including historical EPMepisode payments for all IPPS hospitals
that are in the same U.S. Census
division, which was discussed further
in section III.D.4.b.(7) of the proposed
rule (81 FR 50856). Specifically, we
proposed to blend two-thirds of the
EPM-participant-specific historical
EPM-episode payments and one-third of
the regional historical EPM-episode
payments to set an EPM participant’s
EPM-episode benchmark prices for the
first 2 performance years of the EPMs
(CYs 2017 and 2018). For performance
year 3 of the EPMs (CY 2019), we
proposed to adjust the proportion of the
EPM-participant-specific and regional
historical EPM-episode payments used
to calculate the EPM-episode
benchmark prices from two-thirds EPM
participant-specific and one-third
regional to one-third EPM participantspecific and two-thirds regional.
Finally, we proposed to use only
regional historical EPM-episode
payments for performance years 4 and 5
of the EPMs (CYs 2020 and 2021) to set
an EPM participant’s EPM episodebenchmark prices, rather than a blend
between the participant-specific and
regional historical EPM episode
payments.
Consistent with our methodology for
the CJR model (80 FR 73544), we
proposed two exceptions. First, we
proposed to use only regional historical
EPM-episode payments to calculate
EPM episode-benchmark prices for EPM
participants with low historic EPMepisode volume). For SHFFT model
episodes, this exception applies to
SHFFT model participants with fewer
than 50 historical SHFFT model
episodes in total across the 3 historical
years. For AMI model episodes
anchored by MS–DRGs 280–282, this
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exception applies to AMI model
participants with fewer than 75 of these
particular AMI model historical
episodes in total across the 3 historical
years. For AMI model episodes
anchored by PCI MS–DRGs 246–251,
this exception applies to AMI model
participants with fewer than 125 of this
particular AMI model historical
episodes in total across the 3 historical
years. For CABG model episodes, this
exception applies to CABG model
participants with fewer than 50
historical CABG model episodes in total
across the 3 historical years. The
thresholds for low historic volume in
this final rule are higher than the CJR
model threshold for low historical LEJR
episode volume of 20 episodes in total
across the 3 historical years. The higher
thresholds are based on the volume
thresholds from the BPCI Model 2 Risk
Track B for 90-day episodes, which
increase when the ratio of withinhospital episode spending variation to
between-hospital episode spending
variation increases. That is, as EPM
episode payment variation increases
within a hospital relative to EPMepisode payment variation between
hospitals, it is necessary to have more
EPM episodes at that hospital to
estimate a stable EPM-episode
benchmark price using data from only
that hospital. We proposed to set higher
thresholds for the SHFFT, AMI, and
CABG models based on internal analysis
from BPCI episode data that shows
higher within-hospital episode spending
variation relative to between-hospital
episode spending variation for episodes
anchored by the EPM MS–DRGs,
compared to episodes anchored by MS–
DRGs 469 and 470 included in the CJR
model.83
Second, in the case of an EPM
participant that has undergone a merger,
consolidation, spin-off, or other
reorganization that results in a new
hospital entity without 3 full years of
historical claims data, we proposed that
EPM participant hospital-specific
historical EPM-episode payments would
be determined using the historical EPM
episode payments attributed to their
predecessor(s), as in the CJR model (80
FR 73544).
The aforementioned proposals align
with our method for blending EPM
participant hospital-specific and
regional data under the CJR model. We
83 BPCI Model 2 Baseline Price Common
Template calculations for 90-day episodes in Risk
Track B calculates BPCI volume thresholds based
on the ratio of within-hospital episode spending
variation and between-hospital episode spending
variation for BPCI Clinical Episodes, based on
episodes that met BPCI eligibility criteria and that
began in July 1, 2009–June 30, 2012.
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315
referred to the CJR model Final Rule (80
FR 73346 through 73349) for further
discussion on alternatives to and
reasons for adopting this methodology
for the CJR model, which informed our
proposal with respect to the EPMs.
The proposal for blending payments
when establishing participants’
benchmark and quality-adjusted targets
and certain exceptions was included in
§ 512.300(c)(2), (3), and (4). We note that
the specific order of steps, and how this
step fits in with others, is discussed
further in section III.D.4.c. of this final
rule. We sought comment on our
proposal for blending payments when
establishing participants’ benchmark
and quality-adjusted targets as well as
the exceptions.
The following is a summary of the
comments received and our responses.
Comment: Commenters expressed
different views on the proposal to base
prices initially on a blend of participantspecific and regional historical data,
while phasing in full regional pricing.
Their perspective commonly related to
the proposal to determine regional
prices based on U.S. Census Divisions,
which is discussed in section
III.D.4.b.(7) that immediately follows.
Some commenters appreciated the
proposal of moving to regional pricing
because it would help attenuate the
effect of participants having to compete
against their own best performance and
where the most efficient participants in
a region could be rewarded. Moreover,
some of these commenters
recommended that CMS even accelerate
regional pricing or allow efficient
participants the option to transition
from historic to regional target prices at
an accelerated rate. A commenter
viewed the proposal as a way to
incentivize both historically efficient
and less efficient hospitals to provide
high quality, efficient care.
Response: We appreciate the
comments supporting our proposal to
blend payments when establishing
participants’ benchmark and qualityadjusted targets and agree with their
perceived benefits of the proposal. We
do not agree with suggestions to
accelerate regional pricing or allowing
flexibility for hospitals to accelerate
their transition to regional prices. We
continue to believe our proposed phasein period for regional pricing would
generally be most protective of
participants as they adjust to the models
because their performance would be
compared to their own historical
performance rather than hospitals in
their region. We are also concerned that
allowing certain hospitals the option to
accelerate toward regional pricing as
was suggested could affect our estimates
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and possibly generate inflated
reconciliation payments due to potential
selection issues if historically efficient
hospitals were to opt earlier for a more
generous regional price. Allowing
certain hospitals the option to select
regional pricing earlier would also
increase administrative complexity
under the models.
Comment: Several commenters
opposed proposed regional pricing
policy, asking that CMS slow its phasein period, asking that CMS phase-in
regional prices to something less than
100 percent, for example, to only a 50–
50 blend of participant-specific and
regional pricing, or relying solely on
participant-specific performance data.
Some commenters suggested that
hospitals might not be prepared to
compete relative to regional pricing
while others expressed concern that
hospitals would be penalized for factors
beyond their control, for example,
hospitals with a disproportionately large
population of high-cost or vulnerable
beneficiaries. Thus, several commenters
suggested that CMS also account for
these factors.
Response: As we stated in the CJR
Final Rule (80 FR 73348), we believe
that only using participant-specific
pricing would not reward already
efficient participants for maintaining
high performance and participants
already delivering high quality and
efficient care would find it challenging
to improve upon their own historical
performance to quality for reconciliation
payments. We appreciate the concerns
raised about participants being
penalized for factors beyond their
control once regional prices are phasedin. As discussed earlier in section
III.D.4.b.(2) of this final rule, we will be
exploring additional methods for further
risk-adjusting episodes under the
models that we intend to make effective
by PY3. We believe that these additional
adjustments in tandem with our general
methodology for risk stratification, caps
on high-payment episodes, and limits
on Medicare repayments will offer
sufficient protections to participants so
that they are not penalized once
regional pricing is phased-in.
Comment: Some commenters noted
that even when regional pricing is fully
phased-in, CMS and participants will
see diminishing returns over time,
beginning with providers in lowspending areas where more limited
opportunities for additional gains in
efficiency exist and target prices could
not be further constrained without
putting the quality of care at risk. Thus,
these commenters requested that CMS
use the higher of national or regional
historical episode payments when
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calculating the target price to help
ensure that appropriate incentives are
provided to participants in both highand low-spending areas. A commenter
recommended that CMS vary pricing
based on whether the participants is in
a MSA with higher or lower than
average historical prices. For example,
for participants in MSAs with costs well
above the national average, target prices
would be based on a blend of
participant-specific data and MSA
historical data to help level the playing
field while continuing to allow program
savings. For participants in MSAs
already below the national average,
CMS should use a 5-state regional
benchmark that would allow high
performing MSAs to drive improvement
and achieve savings for CMS and
providers. Alternatively, some
commenters recommended that CMS
adopt a bifurcated transition whereby it
uses a lower weight for the participants
determined to have spending higher
than their region similar to the Shared
Savings Program.
Response: As we stated in the CJR
Final Rule (80 FR 73348), we believe
that using the higher of regional and
participant-specific prices would not
sufficiently incentivize inefficient
participants to become more efficient.
That is, participants with historically
high episode expenditures would have
less of an incentive to become more
efficient over the course of a model if
they can quality for reconciliation
payments by improving only slightly
relative to their own performance while
still being less efficient than their
regional peers.
We appreciate the suggestions to
adopt a bifurcated transition or to vary
pricing based on whether the
participant is in a MSA with higher or
lower than average historical prices—
that is, to base target prices on a blend
of participant-specific data and MSA
historical data in MSAs with higher
than average costs and a 5-state regional
benchmark for hospitals in MSAs with
lower than average costs, but do not
believe these would materially improve
upon our proposed methodology. We
believe the protections we are offering
participants are sufficient and obviate
further adjustments such as the
‘‘bifurcated’’ transition or weighting
adjustments recently adopted for the
Shared Savings Program. Further, we
believe the latter proposal would
decrease incentives for all participants
by potentially making it too difficult to
achieve success for participants in
higher-spending regions while relaxing
standards for those in lower spending
regions.
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Comment: Some commenters
recommended that, in lieu of regional
pricing targets, CMS adopt national
targets. In its comments, MedPAC noted
that national prices are used in other
Medicare FFS payment systems and that
it believes the EPMs should transition to
national prices. Further, in 2013,
MedPAC reported that risk-adjusted
spending on post-acute care and
readmissions varied about 30 percent
between high- and low-spending MSAs
for SHFFT episodes. Transitioning to
regionally-based benchmarks, as
opposed to nationally-based
benchmarks, will continue to allow
large differences in spending across the
country. In markets with long-term care
hospitals (LTCH) and inpatient
rehabilitation facilities (IRF), these highcost settings will raise the participants’
benchmarks. In markets without these
providers, on the other hand, post-acute
care is delivered in lower-cost settings
and participants’ benchmarks will be
lower. MedPAC recommended that CMS
ultimately transition to national
benchmarks to exert pressure on highcost regions to bring their spending in
line with spending in other markets.
Another commenter seemed to suggest
that applying nationally-based
benchmarks would help in addressing
their concern with disparate device
costs depending on whether a
participant was in a rural or
metropolitan area. In their view,
participants in rural areas would be
disadvantaged by higher costs for these
items.
Response: We agree with MedPAC on
the benefits of national prices as well as
their view that national prices should
ultimately be adopted if the EPMs were
fully integrated into Medicare on a
national basis. We also continue to
believe that our proposal to phase-in
regional pricing from participantspecific prices offers the most
appropriate balance of incentives and
protections for purposes of testing the
proposed EPMs. In particular, we are
concerned that immediately moving
toward national pricing could impede
the chances for success among
participants in high cost regions. As a
result, we are reluctant to adopt national
pricing at this time. We also do not
agree with the suggestion that moving
toward national pricing would benefit
participants in rural areas with respect
to device costs. This is because financial
performance, including spending on
devices, during the performance years
would be generally compared to a
participant’s historical costs or to the
historical costs of providers in their
region. In either case, the costs for
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317
and quality-adjusted targets. We would
note that our final policy would also
include § 512.300(c)(5) in conjunction
with § 512.300(c)(2), (3), and (4). Thus,
the final policy for blending payments
when establishing benchmark and
quality-adjusted targets is included in
§ 512.300(c)(2), (3), (4), and (5).
(7) Define Regions as U.S. Census
Divisions
We believe U.S. Census divisions
provide the most appropriate balance
between very large areas with highly
disparate utilization patterns and very
small areas that would be subject to
price distortions due to low volume or
participant-specific utilization patterns.
Our proposed rule also clarified that we
would ascribe the same regional
component of EPM-episode benchmark
prices for EPM participants in MSAs
that span U.S. Census divisions. That is,
selected MSAs that span U.S. Census
divisions would be attributed to one
U.S. Census division for purposes of
calculating the regional component of
an EPM-episode benchmark price.
Specifically, we would attribute an
MSA to the U.S. Census division in
which the majority of people in the
MSA reside.
The proposal to define a region as one
of the nine U.S. Census divisions was
included in § 512.300(c)(2). We sought
comment on our proposal to define
region in this manner.
The following is a summary of the
comments received and our responses.
Comment: Many of the commenters
on the proposed regional definition
expressed concerns about the proposal
to blend participant-specific and
regional pricing. In general, the
commenters expressed concerns that,
given the size and diversity of the
proposed U.S. Census divisions with
respect to health conditions and costs,
a single regional price would potentially
not be an accurate measure of a
participant’s costs. As a result, those
participants that treated sicker patients
would be penalized in particularly large
and diverse regions. Thus, many of
these commenters requested that CMS
set prices based on a narrower and more
cohesive geographic area, for example,
at the MSA level, IPPS wage index level,
or based on MAC regions. A commenter
recommended that CMS not base
benchmark prices fully on a regional
average but consider taking into account
a participant’s relative mix of patients
with respect to CCs and MCCs.
Another commenter suggested that
while some financial risk is captured
based on CMS-HCC scores, the best way
to remove unintended consequence is
by comparing participants with similar
patient populations, instead of using
Census Divisions to calculate target
prices. In their view, using Census
Divisions to set target prices penalizes
high acuity hospitals for existing in the
same multi- state ‘‘region’’ as
lower-acuity hospitals, even if those
hospitals are more capable at caring for
sicker patients. As such, many hospitals
are funneled the most complex AMI,
CABG, or fracture cases, which may
increase average costs in a way that is
consistent with providing the
highest-quality care. As such, this
commenter recommended that CMS
instead compare hospitals against other
hospitals with similar patient
populations for the purpose of
calculating target prices. As high-acuity
84 There are four census regions—Northeast,
Midwest, South, and West. Each of the four census
regions is divided into two or more ‘‘census
divisions’’. Source: https://www.census.gov/geo/
reference/gtc/gtc_census_divreg.html. Accessed on
April 15, 2015.
85 https://www.eia.gov/consumption/commercial/
census_maps.cfm.
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As we did for the CJR model (80 FR
73349 through 73350), for all 5
performance years, we defined ’’region’’
as one of the nine U.S. Census
divisions 84 in Figure 1 (81 FR 50857).
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devices should be relatively more
comparable than if comparisons were
made to a national measure.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal, without
modification, to blend payments when
establishing participants’ benchmark
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referral centers are most at-risk given
that they treat the most ill patients in
the nation for all of the proposed EPMs,
the commenter recommended that CMS
group together such high-acuity referral
centers and treat them as their own
‘‘Peer group’’ cohort rather than by
region or within each region for the
purpose of calculating target price. This
would ensure that locations
systematically treating the most
complex cases are being compared
appropriately. Another commenter
suggested this concept be expanded
more broadly so that peer groups might
be formed around characteristics such
as urban teaching hospitals, suburban
hospitals, or small rural hospitals.
Response: We appreciate the
comments and concerns raised on our
proposal to base regional pricing on U.S.
Census Divisions as well as the
suggested alternatives. Our proposal
intended to balance our goal of
identifying relatively cohesive,
homogeneous, and meaningful groups
for purposes of establishing benchmark
prices with what was administratively
feasible. While we appreciate the
suggested alternatives that were offered
and could consider them for future
models, we continue to believe, as we
stated in the CJR Final Rule (80 FR
73350), that U.S. Census Divisions
provide the most appropriate balance
between very large areas with highly
disparate utilization patterns and very
small areas that would be subject to
price distortions due to low volume or
hospital specific utilization patterns. We
would also note that as discussed earlier
in section III.D.4.b.(2), we will be
exploring additional methods for further
risk-adjusting episodes under the
models that we intend to make effective
by PY3. We believe that these additional
adjustments will make comparisons of
financial performance among
participants more comparable regardless
of a region’s diversity.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal, without
modification, to define a region as one
of the nine U.S. Census divisions. Our
final policy for defining regions is
included in § 512.300(c)(2).
(8) Normalize for Provider-Specific
Wage Adjustment Variations
Some variation in historical EPMepisode payments across hospitals in a
region may be due to wage adjustment
differences in Medicare payments. In
setting Medicare payment rates,
Medicare typically adjusts facilities’
costs attributable to wages and wagerelated costs (as estimated by the
Secretary from time to time) by a factor
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(established by the Secretary) that
reflects the relative wage level in the
geographic area of the facility or
practitioner (or the beneficiary’s
residence, in the case of home health
and hospice services) compared to a
national average wage level. Such
adjustments are essential for setting
accurate payments, as wage levels vary
significantly across geographic areas of
the country. However, having the wage
level for one hospital influence the
regional-component of another
hospital’s EPM episode-benchmark
price with a different level would
introduce unintended pricing distortion
not based on utilization pattern
differences.
To preserve how wage levels affect
provider payment amounts, while
minimizing the distortions introduced
when calculating the regionalcomponent of blended EPM-episode
benchmark prices, we proposed to
normalize for wage indices at the claim
level for both historical EPM-episode
payments and actual EPM-episode
payments (81 FR 50858). As discussed
in section III.D.3.b. of the proposed rule
(81 FR 50845 through 50846), we utilize
the CMS Price (Payment)
Standardization Detailed Methodology
to calculate EPM-episode benchmark
and quality-adjusted target prices and
actual EPM-episode spending. This
methodology removes wage level
differences in calculating standardized
payment amounts.
We believe it is important to
reintroduce wage index variations near
the end of the EPM-episode price-setting
methodology and when calculating
actual EPM-episode payments during an
EPM performance year, to account for
the differences in cost for care redesign
across different geographic areas of the
country. For example, hiring additional
hospital staff to aid in patient follow-up
during the post-discharge period of an
AMI model episode would be
significantly more costly in San
Francisco than in rural Idaho. If we do
not reintroduce wage index variations
into EPM-episode benchmark price and
actual EPM-episode payment
calculations, we would calculate
reconciliation and repayment amounts
that would not capture labor cost
variation throughout the country, and
EPM participants in certain regions may
see less opportunity and financial
incentive to invest in care redesign.
Thus, when setting EPM-episode
benchmark prices and calculating actual
EPM-episode payments, we proposed to
reintroduce the participant-specific
wage variations by multiplying EPMepisode payments by the wage
normalization factor when calculating
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the EPM-episode benchmark prices and
actual EPM-episode payments for each
EPM participant, as described in section
III.D.4.c. of the proposed rule.
We proposed to use the following
algorithm to create a wage
normalization factor: 0.7 * IPPS wage
index + 0.3. The 0.7 approximates the
labor share in IPPS, IRF PPS, SNF, and
HHA Medicare payments. The specific
order of steps, and how this step fits in
with others, is discussed further in
section III.D.4.c. through III.D.4.e. of the
proposed rule (81 FR 50862 through
50864). We also referred to the CJR
model Final Rule for more detailed
information on our normalization
process adopted for the CJR model (80
FR 73350 through 73352).
The proposal to normalize for
provider-specific wage adjustment
variations was included in
§ 512.300(c)(12). We sought comment on
our proposal to normalize for these
variations.
We received no specific comments on
our proposal to normalize for providerspecific wage adjustment variations
other than one in support of the
proposal.
Final Decision: We are finalizing the
proposal, without modification, to
normalize for provider-specific wage
adjustment variations. Our final policy
for normalizing provider-specific wage
adjustment variations is included in
§ 512.300(c)(12).
(9) Combining Episodes to Set Stable
Benchmark and Quality-Adjusted Target
Prices
For the purposes of having sufficient
episode volume to set stable EPMepisode benchmark and quality-adjusted
target prices, we proposed generally to
follow the process from the CJR model
(80 FR 73352 and 73353) to calculate
severity factors, EPM participantspecific weights, and region-specific
weights that allow us to surmount
issues of low volume for EPM episodes
with particular characteristics by
aggregating EPM episodes and portions
of EPM episodes across dimensions that
include anchor MS–DRGs, the presence
of AMI ICD–CM diagnosis code on the
anchor inpatient claim, and the
presence of a major complication or
comorbidity for anchor CABG MS–DRGs
(81 FR 50858 through 50861). Where the
CJR Final Rule referred to anchor
factors, however, for the purposes of the
proposed rule, we referred to severity
factors to avoid confusion when
performing calculations pertaining to
expenditures that occurred during the
anchor hospitalization and after the
anchor hospitalization in CABG model
episodes.
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319
we proposed to calculate severity factors
for episodes with price MS–DRGs 480
and 481 equal to—
model participant, a hospital weight
would be calculated using the following
formula, where SHFFT model episode
counts are SHFFT-model-participant
hospital-specific and based on the
SHFFT model episodes in the 3
historical years used in SHFFT model
episode benchmark and quality-adjusted
target price calculations:
A SHFFT model participant’s specific
average episode payment would be
calculated by multiplying such
participant’s weight by its combined
historical average episode payment
(sum of historical episode payments for
historical episodes with price MS–DRGs
480–482 divided by the number of
historical episodes with price MS–DRGs
480–482). The calculation of the
participant weights and the participantspecific pooled historical average
episode payments would be comparable
to how case-mix indices are used to
generate case-mix adjusted Medicare
payments. The participant weight
essentially would count each episode
with price MS–DRGs 480 and 481 as
more than one episode (assuming
episodes with price MS– DRGs 480 and
481 have higher average payments than
episodes with price MS–DRG 482) so
that the pooled historical average
episode payment, and subsequently the
SHFFT model episode benchmark and
quality-adjusted target prices, are not
skewed by the SHFFT model
participant’s relative breakdown of
historical episodes with price MS–DRGs
480 and 481 versus historical episodes
with price MS–DRG 482.
We would calculate region-specific
weights and region-specific pooled
historical average payments following
the same steps as for hospital-specific
weights and hospital-specific pooled
average payments. Instead of grouping
episodes by the attributed hospital as for
hospital-specific calculations, regionspecific calculations would group
together SHFFT model episodes that
were attributed to any IPPS hospital
located within the region. The
participant-specific and region-specific
pooled historical average payments
would be blended together as discussed
in section III.D.4.b.(6) of the proposed
rule. The specific order of steps, and
how this step fits in with others, is
discussed further in section III.D.4.c. of
the proposed rule.
Afterwards, the blended pooled
calculations would be ‘‘unpooled’’ by
setting the episode benchmark price for
episodes with price MS–DRG 482 to the
resulting calculation, and by
multiplying the resulting calculation by
the severity factors to produce the
episode benchmark prices for episodes
with price MS–DRGs 480 and 481.
Applying the discount factor as
discussed in III.D.4.b.(10) and III.D.4.c.
of the proposed rule would result in the
SHFFT model quality-adjusted target
prices for episodes with price MS–DRGs
480–482.
For episodes in the AMI model with
price MS–DRGs in 280–282 or 246–251
and without readmissions for CABG
MS–DRGs, we proposed to follow an
analogous procedure to the SHFFT
model with the following modifications.
First we proposed to group episodes
with price MS–DRGs 280–282
separately from episodes with price
MS–DRGs 246–251 for the calculations.
Second, we proposed to calculate
severity factors for episodes with price
MS–DRGs 280–282 as—
Third, we proposed to calculate
hospital-specific weights and region-
specific weights for episodes with price
MS–DRGs 280–282 as—
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historical episode volume to set more
stable SHFFT episode benchmark and
quality-adjusted target prices. To do so,
The national average would be based on
SHFFT model episodes attributed to any
IPPS hospital. The resulting severity
factors would be the same for all SHFFT
model participants. For each SHFFT
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For SHFFT model episodes, we
proposed to combine episodes with
price MS–DRGs 480–482 to use a greater
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Fourth, we proposed to calculate
severity factors for episodes with price
MS–DRG 246–251 as—
After blending historical and regional
pooled episode payments for episodes
with price MS–DRGs 280–282, the
blended pooled calculations would be
‘‘unpooled’’ by setting the episode
benchmark price for price MS–DRG 282
to the resulting calculation, and by
multiplying the resulting calculation by
the severity factors to produce the
episode benchmark prices for price MS–
DRGs 280 and 281.
After blending historical and regional
pooled episode payments for episodes
with price MS–DRGs 246–251, the
blended pooled calculations would be
‘‘unpooled’’ by setting the episode
benchmark price for price MS–DRG to
the resulting calculation, and by
multiplying the resulting calculation by
the severity factors to produce the
episode benchmark prices for price MS–
DRGs 246–251.
Applying the discount factor as
discussed in III.D.4.b.(10) and III.D.4.c
of the proposed rule would result in the
quality-adjusted target prices for price
MS–DRGs 280–282 and 246–251.
For episodes in the CABG model with
price MS–DRGs in 231–236, we
proposed to calculate severity factors,
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hospital-specific weights, and regionspecific weights separately for the
anchor hospitalization portion of CABG
model episodes and the post-anchor
hospitalization portion of CABG model
episodes.
For the anchor hospitalization portion
of CABG model episodes, we proposed
to follow an analogous procedure to the
SHFFT model with the anchor
hospitalization portion of CABG model
episodes grouped by the price MS–DRG.
Specifically, we proposed to calculate
anchor hospitalization severity factors
for price MS–DRGs 231–235 as—
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specific weights for episodes with price
MS–DRG 246–251 as—
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Fifth, we proposed to calculate
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hospitalization portion of CABG model
episodes as—
For the post-anchor hospitalization
portion of CABG model episodes, we
proposed to follow an analogous
procedure to the SHFFT model with the
post-anchor hospitalization portion of
CABG model episodes grouped in the
following manner—
• With AMI diagnosis on the anchor
inpatient claim and price MS–DRG with
major complication or comorbidity (231,
233, or 235)
• With AMI diagnosis on the anchor
inpatient claim and price MS–DRG
without major complication or
comorbidity (232, 234, or 236)
• Without AMI diagnosis on the
anchor inpatient claim and price MS–
DRG with major complication or
comorbidity (231, 233, or 235)
• Without AMI diagnosis on the
anchor inpatient claim and price MS–
DRG without major complication or
comorbidity (232, 234, or 236)
Specifically, we proposed to calculate
post-anchor hospitalization severity
factors as—
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After blending historical and regional
pooled anchor hospitalization payments
for the CABG model episodes, the
blended pooled calculations would be
‘‘unpooled’’ by setting the price MS–
DRG 236 anchor hospitalization
benchmark price to the resulting
calculation, and by multiplying the
resulting calculation by the severity
factors to produce the anchor
hospitalization benchmark prices for
price MS–DRGs 231–235.
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We also proposed to calculate
participant-specific weights and regionspecific weights for the anchor
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hospitalization portion of CABG model
episodes as—
prices. Applying the discount factor as
discussed in III.D.4.b.(10) and III.D.4.d
of the proposed rule would result in the
quality-adjusted target prices for CABG
model episodes.
For episodes in the AMI model with
CABG readmissions, we proposed to
perform no additional blending of
participant-specific and regionalspecific episode payments. We
proposed to calculate the AMI model
episode benchmark and quality-adjusted
target prices for such episodes as
described in section III.D.4.e. of the
proposed rule.
The proposals to combine episodes to
set stable benchmark and qualityadjusted target prices were included in
§ 512.300(c)(13). We sought comment on
our proposals for combining episodes
for these purposes.
We received no comments on our
proposals for combining episodes.
Final Decision: We are finalizing the
proposal, without modification, to
combine prices for episodes. Our final
policy for combining episodes is
included in § 512.300(c)(13). We would
note that since we did not finalize our
proposal for price MS–DRGs, the term
price MS–DRG is excluded and replaced
with the term anchor MS–DRG.
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(10) Effective Discount Factor
As discussed in section III.D.2.c. of
the proposed rule, we proposed to make
EPM participants partly or fully
accountable for EPM-episode payments
in relationship to the EPM qualityadjusted target price (81 FR 50844). As
part of this, in setting an episode
quality-adjusted target price for an EPM
participant, we proposed to apply an
effective discount factor to an EPM
participant’s participant-specific and
regional blended historical EPM-episode
payments for a performance period. We
expect EPM participants to have a
significant opportunity to improve the
quality and efficiency of care furnished
during episodes in comparison with
historical practice, because the EPMs
would facilitate the alignment of
financial incentives among providers
caring for EPM beneficiaries. Our
proposed effective discount factors were
intended to serve as Medicare’s portion
of reduced expenditures from an EPM
episode with any EPM-episode
expenditures below the quality-adjusted
target price potentially available as
reconciliation payments to the EPM
participant where the anchor
hospitalization occurred.
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After blending historical and regional
pooled post-anchor hospitalization
payments for the CABG model episodes,
the blended pooled calculations would
be ‘‘unpooled’’ by setting the without
AMI ICD–CM diagnosis code on the
anchor inpatient claim and price MS–
DRG without major complication or
comorbidity (232, 234, or 236) postanchor hospitalization benchmark price
to the resulting calculation, and by
multiplying the resulting calculation by
the severity factors to produce the postanchor hospitalization benchmark
prices for:
• With AMI diagnosis on the anchor
inpatient claim and price MS–DRG with
major complication or comorbidity (231,
233, or 235)
• With AMI diagnosis on the anchor
inpatient claim and price MS–DRG
without major complication or
comorbidity (232, 234, or 236)
• Without AMI diagnosis on the
anchor inpatient claim and price MS–
DRG with major complication or
comorbidity (231, 233, or 235)
We proposed to calculate episode
benchmark prices for CABG model
episodes by summing combinations of
CABG anchor hospitalization
benchmark prices and CABG postanchor hospitalization benchmark
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We also proposed to calculate
hospital-specific weights and regionspecific weights for the post-anchor
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For the EPMs, we proposed to
establish a 3 percent effective discount
factor to calculate the quality-adjusted
target prices for EPM participants in the
below acceptable and acceptable quality
categories, as discussed in section
III.E.3.f. of the proposed rule (81 FR
50887 through 50893) and similar to the
CJR model (80 FR 73355). The effective
discount factor to calculate the qualityadjusted target price for EPM
participants in the good and excellent
quality categories would be 2 percent
and 1.5 percent, respectively.
As discussed in section III.D.2.c. of
the proposed rule (81 FR 50844),
because of the proposed phase-in of
repayment responsibility with no
responsibility in either performance
year 1 or performance year 2 (NDR) and
only partial repayment responsibility in
performance year 2 (DR) and all of
performance year 3, an EPM participant
with actual EPM-episode payments that
exceeded the quality-adjusted target
prices multiplied by the EPM
participant’s number of EPM episodes to
which each quality-adjusted target price
would apply in performance year 2 (DR)
and performance year 3 would owe
Medicare less than would otherwise
result from this calculation.
Also, as discussed in section III.E.3.f
of the proposed rule (81 FR 50801), we
proposed to apply an ‘‘applicable
discount factor’’ to repayment amounts
in performance years 2 and 3 while this
repayment responsibility was being
phased-in. We refer to section III.E.1.
and specifically Tables 20 through 28 in
our proposed rule for further illustration
of the discount percentages that would
apply for reconciliation payment and
Medicare repayment over the 5 EPM
performance years (81 FR 50888 through
50892). We believe this methodology
offers EPM participants an opportunity
to create savings for themselves and
Medicare, while also maintaining or
improving quality of care for EPM
model beneficiaries.
The proposal to establish discount
factors that would apply to the quality
categories was included in § 512.300(d).
We sought comment on our proposal to
establish discount factors that apply to
the quality categories.
The following is a summary of the
comments received and our responses.
Comment: Most commenters
suggested that the ability to achieve
savings under the proposed models
(most notably for the cardiac models
and the CABG model in particular) was
more limited than for the CJR model,
and that these limitations would
become more significant as target prices
decline further over time. For example,
commenters opined that while about
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half of CJR episode spending is
attributable to the initial hospitalization,
CMS noted that about three-quarters of
CABG episode spending is attributable
to the initial hospitalization. As such,
there are fewer opportunities to achieve
efficiencies within the inpatient
hospital payment amount because it is
a predetermined per-discharge payment
based primarily on the patient’s
condition, not on services provided.
Further, some portion of CABG and AMI
costs outside the initial hospitalization
is attributable to readmissions; however,
these costs are already declining due to
hospitals’ responses to the HRRP and
any remaining readmissions are more
likely to be clinically appropriate and
necessary. As such, it would be difficult
to achieve efficiencies within the
remaining percentage of spending that
occurs outside the initial
hospitalization. Thus, commenters
requested that CMS implement a
smaller discount factor than what was
proposed—typically a 1 percentage
point reduction.
Response: We appreciate the
comments and concerns raised with
respect to our proposed discount factor.
We recognize that, as compared to
episodes under the CJR model,
opportunities to achieve improved
efficiencies under the proposed models
would be different and potentially more
challenging for participants under the
proposed models. However, we do not
believe the increased efficiencies
needed to be successful as was proposed
under the models are unattainable.
Given our policy to phase-in full
regional pricing over time, participants’
performance will increasingly be
compared to that of peers within their
region; thus, for the more efficient
participants, target pricing would likely
be higher than if we relied on
participant-specific pricing alone.
Further, as discussed in section
III.D.4.b.(2), we plan to explore and
implement additional adjustments for
risk beginning in PY3, which should
facilitate successful participants’ ability
to achieve savings under the models.
We would also note that our final policy
to include reconciliation payments
when updating target prices for
successful participants under the
models should ease the decline in
pricing over time, which should
facilitate their ability to be rewarded for
improved efficiencies.
Comment: A commenter encouraged
CMS to provide participants with
protection against having to make
repayments that result from adverse
events beyond their control, similar to
the protections offered under the
Medicare Shared Savings Program.
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323
Specifically, during risk-bearing periods
of the program, instead of setting a
repayment target price equal to
historical payments minus some
percentage, the commenters
recommended that CMS should instead
set a symmetric target price equal to
historical payments plus or minus some
percentage. Under this proposal,
participants with historical payments
falling between, for example, 97 percent
and 103 percent of historical payments
would neither receive reconciliation
payments nor be held responsible for
repaying Medicare.
Response: We appreciate the
suggested alternative the commenter
offered, but would note that the
proposed models are intended to test a
bundled payment rather than a shared
savings model, which is being tested
through Innovation Center and Shared
Savings Program ACO efforts.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal, with
modification, to establish discount
factors that would apply to the quality
categories. Specifically, for repayment
amounts in performance year 2, our
final applicable discount factor would
apply only to participants that elected
downside risk in that year. Also, in
conformance with our final policy for
phasing-in repayment responsibility, the
applicable discount factor is extended
so that it will apply to all EPM
participants in performance year 4. Our
final policy for the discount factor is
included in § 512.300(d).
c. Approach To Combine Pricing
Features for All SHFFT Model Episodes
and AMI Model Episodes Without
CABG Readmissions
The following presents our proposed
methodology for combining the pricing
features presented in section III.D.4.b. of
the proposed rule with respect to
SHFFT model episodes and AMI model
episodes without a CABG readmission
(81 FR 50862 and 50863).
• Step 1—Calculate historical EPMepisode payments for episodes that were
initiated during the 3-historical-years of
each applicable EPM (that is,
individually for each of the SHFFT and
AMI models) (section III.D.4.b.(3) of the
proposed rule) for all IPPS hospitals for
all Medicare Part A and B services
included in the EPM episodes. Limit the
potential AMI model episodes to those
episodes with price MS–DRGs in 280–
282 or 246–251 and without
readmissions for CABG MS–DRGs. We
note that specific PBPM payments may
be excluded from historical EPMepisode payment calculations as
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discussed in section III.D.6.d. of the
proposed rule.
• Step 2—Remove the effects of
special payment provisions (section
III.D.3.b. of the proposed rule) and
normalize for wage index differences
(section III.D.4.b.(8). of the proposed
rule) by standardizing Medicare FFS
payments at the claim-level.
• Step 3—Prorate Medicare payments
for included episode services that span
a period of care that extends beyond the
episode (section III.D.3.c. of the
proposed rule.).
• Step 4—Trend forward the 2 oldest
historical years of data to the most
recent year of historical data (section
III.D.4.b.(4) of the proposed rule).
Separate national trend factors would be
applied for each combination of price
MS–DRGs.
• Step 5—Cap high episode payment
episodes with a region- and price-MS–
DRG-specific high payment ceiling
(section III.D.3.d. of the proposed rule),
using the episode output from the
previous step.
• Step 6—Group episodes based on
price MS–DRGs (SHFFT MS–DRGs 480–
482; AMI MS–DRGs 280–282; PCI MS–
DRGs 246–251). Within each group of
episodes, calculate severity factors and
EPM participant-specific weights
(section III.D.4.b.(9) of the proposed
rule) using the episode output from the
previous step to pool together episodes
in each group of price MS–DRGs,
resulting in EPM participant-specific
pooled historical average episode
payments for each group of price MS–
DRGs. Similarly, calculate regionspecific weights to calculate regionspecific pooled historical average
episode payments for each group of
price MS–DRGs.
• Step 7—Calculate EPM participantspecific and region-specific weighted
update factors (section III.D.4.b.(5). of
the proposed rule). Multiply each EPM
participant-specific and region-specific
pooled historical average episode
payment by its corresponding EPM
participant-specific and region-specific
weighted update factors to calculate
EPM participant-specific and regionspecific updated, pooled, historical
average episode payments.
• Step 8—Blend together each EPMparticipant-specific updated, pooled,
historical average episode payment with
the corresponding region-specific
updated, pooled, historical average
episode payment according to the
proportions for the EPM performance
year (III.D.4.b.(6) of the proposed rule).
EPM participants that do not have the
minimum episode volume across the
historical 3 years would use 0.0 percent
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and 100 percent as the proportions for
hospital and region, respectively.
• Step 9—Multiply the outputs of
step (8) by the wage normalization
factor described in section III.D.4.b.(8)
of this final rule to reintroduce
geographic variation. For purposes of
the proposed rule, we defined the three
outputs of this step as the standard
episode benchmark price for—
++ SHFFT model episodes with price
MS–DRG 482
++ AMI model episodes with price MS–
DRG 282 without readmission for
CABG, and
++ AMI model episodes with price MS–
DRG 251 without readmission for
CABG.
• Step 10—Multiply the output of
step (9) by the appropriate severity
factors (step (6) of this calculation
process and detailed in section
III.D.4.b.(9) of the proposed rule) to
calculate the standard episode
benchmark prices for—
++ SHFFT model episodes with price
MS–DRGs 480–481
++ AMI model episodes with price MS–
DRGs 280–281 without readmission
for CABG
++ AMI model episodes with price MS–
DRGs 246–250 without readmission
for CABG
• Step 11—Multiply the outputs of
step (9) and (10) by 1 minus the
applicable effective discount factor
based on the EPM participant’s quality
category as described in sections
III.D.4.b.(10) and III.E.3.f. of the
proposed rule. For purposes of the
proposed rule, we defined the outputs
of this step as the episode qualityadjusted target prices for:
++ SHFFT model episodes with price
MS–DRGs 480–482
++ AMI model episodes with price MS–
DRGs 280–282 without readmission
for CABG, and
++ AMI model episodes with price MS–
DRGs 246–251 without readmission
for CABG
We would note that because our final
policy for inpatient-to-inpatient hospital
transfers for AMI episodes does not
include chained anchor
hospitalizations, the one change to our
proposed approach for combining
pricing features for all SHFFT model
episodes and AMI model episodes
without CABG readmissions is to
replace the term price MS–DRG with the
term anchor MS–DRG.
d. Approach To Combine Pricing
Features for CABG Model Episodes
The following presents our proposed
methodology for combining the pricing
features presented in section III.D.4.b of
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the proposed rule with respect to CABG
model episodes (81 FR 50863 through
50864).
(1) Anchor Hospitalization Portion of
CABG Model Episodes
• Step 1—Calculate historical episode
payments that occurred during the
anchor hospitalization of CABG model
episodes that were initiated during the
3 historical years (section III.D.4.b.(2). of
the proposed rule) for all IPPS hospitals
for all Medicare Part A and B services
included in the episodes. We note that
specific PBPM payments may be
excluded from historical episode
payment calculations as discussed in
section III.D.6. of the proposed rule.
• Step 2—Apply steps III.D.4.c.(2)
through (4) to the results of step (1) with
trend factors calculated based on the
anchor hospitalization portion of CABG
model episodes with price MS–DRGs
231–236.
• Step 3—Group the anchor
hospitalization portion of episodes
based on price MS–DRGs 231–236 and
apply steps III.D.4.c.(6) through (10) to
the anchor hospitalization portion of the
CABG model episodes with severity
factors, hospital-specific weighted
update factors, and region-specific
weighted update factors calculated to
apply based only on the anchor
hospitalization portion of CABG model
episodes with price MS–DRGs 231–236.
For purposes of the proposed rule, we
defined the output of this step as CABG
anchor hospitalization benchmark
prices for CABG model episodes with
price MS–DRGs 231–236.
We would note that because our final
policy for inpatient-to-inpatient hospital
transfers for AMI episodes does not
include chained anchor
hospitalizations, the one change to our
approach for combining pricing features
for CABG model episodes is to replace
the term price MS–DRG with the term
anchor MS–DRG.
(2) Approach To Combine Pricing
Features for Post-Anchor
Hospitalization Portion of CABG Model
Episodes
• Step 1—Calculate historical episode
payments that occurred after the anchor
hospitalization for CABG model
episodes that were initiated during the
3 historical years (section III.D.4.b.(2) of
the proposed rule) for all IPPS hospitals
for all Medicare Parts A and B services
included in the episodes. We note that
specific PBPM payments may be
excluded from historical episode
payment calculations as discussed in
section III.D.6. of the proposed rule.
• Step 2—Apply steps III.D.4.c.(2)
through (4) to the results of step (1) with
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trend factors calculated based on the
post-anchor hospitalization portion of
CABG model episodes with price MS–
DRGs 231–236, as described in section
III.D.4.b.(4) of the proposed rule.
• Step 3—Group the post-anchor
hospitalization portion of episodes
based on—
++ With AMI diagnosis on the anchor
inpatient claim and price MS–DRG
with major complication or
comorbidity (231, 233, or 235)
++ With AMI diagnosis on the anchor
inpatient claim and price MS–DRG
without major complication or
comorbidity (232, 234, or 236)
++ Without AMI diagnosis on the
anchor inpatient claim and price MS–
DRG with major complication or
comorbidity (231, 233, or 235)
++ Without AMI diagnosis on the
anchor inpatient claim and price MS–
DRG without major complication or
comorbidity (232, 234, or 236).
Then apply steps III.D.4.c.(6)–(10) to
the post-anchor hospitalization portion
of the CABG model episodes with
severity factors, hospital-specific
weights, and region-specific weights
calculated to apply based on the groups
previously described in this step. For
purposes of the proposed rule, we
defined the output of this step as CABG
post-anchor hospitalization benchmark
prices for CABG model episodes
corresponding to the groups described
in this step.
We would note that because our final
policy for inpatient-to-inpatient hospital
transfers for AMI episodes does not
include chained anchor
hospitalizations, the one change to our
approach for combining pricing features
for the post-anchor hospitalization
portion of CABG model episodes is to
replace the term price MS–DRG with the
term anchor MS–DRG.
(3) Combine CABG Anchor
Hospitalization Benchmark Price and
CABG Post-Anchor Hospitalization
Benchmark Price
• Step 1—Sum the CABG anchor
hospitalization benchmark price
corresponding to each price CABG MS–
DRG and the CABG post-anchor
hospitalization price corresponding to
each of the post-anchor hospitalization
groupings described in III.D.4.d.(2) of
the proposed rule. For purposes of the
proposed rule, we defined the outputs
of those calculations to be CABG model
episode benchmark prices for—
++ CABG model episodes with price
MS–DRG 231 and with AMI
diagnosis;
++ CABG model episodes with price
MS–DRG 232 and with AMI
diagnosis;
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++ CABG model episodes with price
MS–DRG 233 and with AMI
diagnosis;
++ CABG model episodes with price
MS–DRG 234 and with AMI
diagnosis;
++ CABG model episodes with price
MS–DRG 235 and with AMI
diagnosis;
++ CABG model episodes with price
MS–DRG 236 and with AMI
diagnosis;
++ CABG model episodes with price
MS–DRG 231 and without AMI
diagnosis;
++ CABG model episodes with price
MS–DRG 232 and without AMI
diagnosis;
++ CABG model episodes with price
MS–DRG 233 and without AMI
diagnosis;
++ CABG model episodes with price
MS–DRG 234 and without AMI
diagnosis;
++ CABG model episodes with price
MS–DRG 235 and without AMI
diagnosis; and
++ CABG model episodes with price
MS–DRG 236 and without AMI
diagnosis.
The CABG episode benchmark prices
for each price CABG MS–DRG with AMI
diagnosis would also apply as AMI
model episode benchmark prices for
AMI model episodes with price MS–
DRGs 231–236.
• Step 2—Multiply the results of step
1 by the appropriate effective discount
factor that reflects the EPM participant’s
quality category as described in sections
III.D.4.b.(10) and III.E.3.f. of the
proposed rule. For purposes of the
proposed rule, we defined the outputs
of this step to be CABG model episode
quality-adjusted target prices for—
++ CABG model episodes with price
MS–DRG 231 and with AMI diagnosis;
++ CABG model episodes with price
MS–DRG 232 and with AMI diagnosis;
++ CABG model episodes with price
MS–DRG 233 and with AMI diagnosis;
++ CABG model episodes with price
MS–DRG 234 and with AMI diagnosis;
++ CABG model episodes with price
MS–DRG 235 and with AMI diagnosis;
++ CABG model episodes with price
MS–DRG 236 and with AMI diagnosis;
++ CABG model episodes with price
MS–DRG 231 and without AMI
diagnosis;
++ CABG model episodes with price
MS–DRG 232 and without AMI
diagnosis;
++ CABG model episodes with price
MS–DRG 233 and without AMI
diagnosis;
++ CABG model episodes with price
MS–DRG 234 and without AMI
diagnosis;
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325
++ CABG model episodes with price
MS–DRG 235 and without AMI
diagnosis; and
++ CABG model episodes with price
MS–DRG 236 and without AMI
diagnosis.
The episode quality-adjusted target
prices for each anchor CABG MS–DRG
with AMI diagnosis would also apply as
AMI model episode quality-adjusted
target prices for AMI model episodes
with price MS–DRGs 231–236. The
effective discount factor applied to
calculate the AMI model episode
quality-adjusted target prices for AMI
model episodes with price MS–DRGs
231–236 could differ from the effective
discount factor applied to calculate
CABG model episode quality-adjusted
target prices for CABG model episodes
if the participant had different levels of
quality performance on the AMI and
CABG model composite quality scores
that determine the discount factor for
the quality-adjusted target prices.
We would note that because our final
policy for inpatient-to-inpatient hospital
transfers for AMI episodes does not
include chained anchor
hospitalizations, the one change to our
approach for combining CABG anchor
hospitalization benchmark prices and
CABG post-anchor hospitalization
benchmark prices is to replace the term
price MS–DRG with the term anchor
MS–DRG.
e. Approach To Combine Pricing
Features for AMI Model Episodes With
CABG Readmissions
The following presents our proposed
methodology for combining the pricing
features presented in section III.D.4.b of
the proposed rule with respect to AMI
model episodes with a CABG
readmission (81 FR 50864).
In general, the AMI model episode
benchmark price for AMI model
episodes with CABG readmission is the
sum of the applicable standard AMI
model episode benchmark price for an
AMI episode without readmission
corresponding to the AMI price MS–
DRG and the applicable CABG anchor
hospitalization benchmark price for a
CABG model episode corresponding to
the CABG readmission MS–DRG in the
AMI model.
• Step 1—For each combination of
AMI price MS–DRG and CABG
readmission MS–DRG, sum the
corresponding AMI model episode
benchmark price and CABG anchor
hospitalization benchmark price. This
results in 54 possible CABG
readmission AMI model episode
benchmark prices, corresponding to—
++ Price MS–DRG 280; Readmission
MS–DRG 231;
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++ Price MS–DRG 280; Readmission
MS–DRG 232;
++ Price MS–DRG 280; Readmission
MS–DRG 233;
++ Price MS–DRG 280; Readmission
MS–DRG 234;
++ Price MS–DRG 280; Readmission
MS–DRG 235;
++ Price MS–DRG 280; Readmission
MS–DRG 236;
++ Price MS–DRG 281; Readmission
MS–DRG 231;
++ Price MS–DRG 281; Readmission
MS–DRG 232;
++ Price MS–DRG 281; Readmission
MS–DRG 233;
++ Price MS–DRG 281; Readmission
MS–DRG 234;
++ Price MS–DRG 281; Readmission
MS–DRG 235;
++ Price MS–DRG 281; Readmission
MS–DRG 236;
++ Price MS–DRG 282; Readmission
MS–DRG 231;
++ Price MS–DRG 282; Readmission
MS–DRG 232;
++ Price MS–DRG 282; Readmission
MS–DRG 233;
++ Price MS–DRG 282; Readmission
MS–DRG 234;
++ Price MS–DRG 282; Readmission
MS–DRG 235;
++ Price MS–DRG 282; Readmission
MS–DRG 236;
++ Price MS–DRG 246; Readmission
MS–DRG 231;
++ Price MS–DRG 246; Readmission
MS–DRG 232;
++ Price MS–DRG 246; Readmission
MS–DRG 233;
++ Price MS–DRG 246; Readmission
MS–DRG 234;
++ Price MS–DRG 246; Readmission
MS–DRG 235;
++ Price MS–DRG 246; Readmission
MS–DRG 236;
++ Price MS–DRG 247; Readmission
MS–DRG 231;
++ Price MS–DRG 247; Readmission
MS–DRG 232;
++ Price MS–DRG 247; Readmission
MS–DRG 233;
++ Price MS–DRG 247; Readmission
MS–DRG 234;
++ Price MS–DRG 247; Readmission
MS–DRG 235;
++ Price MS–DRG 247; Readmission
MS–DRG 236;
++ Price MS–DRG 248; Readmission
MS–DRG 231;
++ Price MS–DRG 248; Readmission
MS–DRG 232;
++ Price MS–DRG 248; Readmission
MS–DRG 233;
++ Price MS–DRG 248; Readmission
MS–DRG 234;
++ Price MS–DRG 248; Readmission
MS–DRG 235;
++ Price MS–DRG 248; Readmission
MS–DRG 236;
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++ Price MS–DRG 249; Readmission
MS–DRG 231;
++ Price MS–DRG 249; Readmission
MS–DRG 232;
++ Price MS–DRG 249; Readmission
MS–DRG 233;
++ Price MS–DRG 249; Readmission
MS–DRG 234;
++ Price MS–DRG 249; Readmission
MS–DRG 235;
++ Price MS–DRG 249; Readmission
MS–DRG 236;
++ Price MS–DRG 250; Readmission
MS–DRG 231;
++ Price MS–DRG 250; Readmission
MS–DRG 232;
++ Price MS–DRG 250; Readmission
MS–DRG 233;
++ Price MS–DRG 250; Readmission
MS–DRG 234;
++ Price MS–DRG 250; Readmission
MS–DRG 235;
++ Price MS–DRG 250; Readmission
MS–DRG 236;
++ Price MS–DRG 251; Readmission
MS–DRG 231;
++ Price MS–DRG 251; Readmission
MS–DRG 232;
++ Price MS–DRG 251; Readmission
MS–DRG 233;
++ Price MS–DRG 251; Readmission
MS–DRG 234;
++ Price MS–DRG 251; Readmission
MS–DRG 235; and
++ Price MS–DRG 251; Readmission
MS–DRG 236.
• Step 2—Multiply the results of step
1 by the effective discount factor that
reflects the EPM participant’s quality
category, as described in sections
III.D.4.b.(10) and III.E.3.f. of the
proposed rule. For purposes of the
proposed rule, we defined the outputs
of this step to be AMI model episode
quality-adjusted target prices for the
same combinations of AMI price MS–
DRG and readmission MS–DRG in step
(1).
We would note that because our final
policy for inpatient-to-inpatient hospital
transfers for AMI episodes does not
include chained anchor
hospitalizations, the one change to our
approach for combining pricing features
for AMI model episodes with CABG
readmissions is to replace the term price
MS–DRG with the term anchor MS–
DRG.
5. Process for Reconciliation
a. Net Payment Reconciliation Amount
(NPRA)
Consistent with the CJR model (80 FR
73381 through 73383), we proposed to
conduct reconciliation for each EPM by
calculating an EPM-specific NPRA for
each EPM participant (81 FR 50864
through 50865). After the completion of
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an EPM performance year, we proposed
to retrospectively calculate an EPM
participant’s actual EPM-episode
payments based on the EPM episode
definitions as discussed in sections
III.C.3. and III.C.4. of the proposed rule
and the payment policies applicable to
calculating actual EPM-episode
payments as discussed in the
subsections of section III.D.3 of the
proposed rule.
We proposed to compare each EPM
participant’s actual EPM episode
payments to its quality-adjusted target
prices. We proposed, as discussed in
section III.D.4. of the proposed rule, that
an EPM participant would have
multiple quality-adjusted target prices
for EPM episodes ending in a given
performance year, based on the anchor
MS–DRG for the EPM episode, whether
the EPM episode included a chained
anchor hospitalization; whether the
EPM episode included readmission for
CABG MS–DRGs; whether the EPM
episode included an AMI ICD–CM
diagnosis code on the anchor inpatient
claim; the performance year when the
EPM episode was initiated; when the
EPM episode was initiated within a
given performance year (January 1
through September 30 of the
performance year, October 1 through
December 31 of the performance year,
October 1 through December 31 of the
prior performance year); and the
potential effective discount factors. The
difference between each EPM episode’s
actual EPM episode payment and the
relevant quality-adjusted target price
under the EPM (calculated as qualityadjusted target price subtracted by
actual EPM episode payment) would be
aggregated for all EPM episodes in each
EPM for an EPM participant within the
performance year, representing the
NPRA. For performance year 2, we
would perform two separate
aggregations in order to create two
NPRAs—one reflecting episodes that
ended during performance year 2 (NDR),
and a second for episodes that ended
during performance year 2 (DR).
We proposed to not include any
reconciliation payments or repayments
to Medicare under the EPMs for a given
performance year when calculating
actual episode spending and, therefore
the NPRA for a subsequent performance
year. We want to incentivize providers
to provide high-quality and efficient
care in all years of the EPMs. If
reconciliation payments for a
performance year were counted as
Medicare expenditures in a subsequent
performance year, an EPM participant
would experience higher Medicare
expenditures in the subsequent
performance year as a consequence of
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providing high-quality and efficient care
in the prior performance year, negating
some of the incentive to perform well in
the prior year. Therefore, we proposed
to not have the NPRA for a given
performance year be impacted by EPM
repayments or reconciliation payments
made in a prior performance year. For
example, if an EPM participant receives
a $10,000 reconciliation payment in the
second quarter of 2018 for achieving
episode spending below the qualityadjusted target price for performance
year 1, that $10,000 reconciliation
payment amount would not be included
in the performance year 2 calculations
of actual EPM-episode payments.
The NPRA would be subject to the
stop-loss and stop-gain limits described
in section III.D.7.b. and III.D.7.c.(1) of
the proposed rule.
b. Payment Reconciliation
We proposed to retrospectively
reconcile an EPM participant’s actual
EPM-episode payments against the
quality-adjusted target prices 2 months
after the end of the performance year (81
FR 50865 through 50867). Specifically,
we would capture claims submitted by
March 1st following the end of the
performance year and carry out the
NPRA calculation as described
previously to make an EPM
reconciliation payment or hold
participants responsible for repayment,
as applicable, in quarter 2 of that
calendar year.
We also proposed that during the
following performance year’s
reconciliation process, we would
calculate the prior performance year’s
actual EPM episode payments a second
time to account for final claims run-out
and any canceled EPM episodes, due to
overlap with other models or other
reasons as specified in section III.C.4.b
of the proposed rule. This calculation,
termed the subsequent reconciliation,
would occur approximately 14 months
after the end of the prior performance
year. As discussed later in that section,
the amount from this calculation, if
different from zero, would be applied to
the NPRA for the subsequent
performance year, as well as the postepisode spending and ACO overlap
calculation in order to determine the
amount of the payment Medicare would
make to the EPM participant or such
participant’s repayment amount. We
note that the subsequent reconciliation
calculation would be combined with the
previous calculation of NPRA for a
performance year to ensure the stop-loss
and stop-gain limits discussed in
section III.D.7.b. and III.D.7.c.(1) of the
proposed rule are not exceeded for a
given performance year.
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For the performance year 1
reconciliation process, we would
calculate an EPM participant’s NPRA as
previously described, and if positive,
such participant would receive the
amount as a reconciliation payment
from Medicare, subject to the stop-gain
limit for performance year 1. If negative,
the EPM participant would not be
responsible for repayment to Medicare,
consistent with our proposal to phase in
financial responsibility beginning in the
second quarter of performance year 2.
For the performance year 2
reconciliation process, we would
calculate two separate NPRAs for an
EPM participant—one for episodes that
ended during performance year 2 (NDR)
and a second for episodes that ended
during performance year 2 (DR). While
these NPRAs would be separately
determined for each of these two
periods, whether an EPM participant
receives a Medicare reconciliation
payment or makes a Medicare
repayment in performance year 2 would
be determined based on the sum of
these two separately determined
NPRAs. The NPRA for both performance
year 2 (NDR) and performance year 2
(DR) would be subject to the same stopgain limit of 5 percent, but because EPM
participants would only have repayment
responsibility for negative NPRA in
performance year 2 (DR), the stop-loss
limit of 5 percent would only apply to
performance year 2 (DR). Thus, if an
EPM participant’s NPRA for the first
quarter of performance year 2 is
positive, that amount would be counted
toward a reconciliation payment from
Medicare, subject to the stop-gain limit
for performance year 2. If negative, the
EPM participant would not be
responsible for repayment to Medicare
of the amount determined for
performance year 2 (NDR). If an EPM
participant’s NPRA is positive for
episodes ending during performance
year 2 (DR), that amount would be
counted toward a reconciliation
payment from Medicare, subject to the
stop-gain limit for performance year 2.
If negative, the EPM participant would
be responsible for repayment to
Medicare of the amount determined for
episodes ending during performance
year 2 (DR), subject to the stop loss
limits for performance year 2 (DR).
During the subsequent reconciliation
process for performance year 2, we
would also calculate the prior
performance year’s actual EPM episode
payments a second time separately for
episodes that ended during performance
year 2 (NDR) and for episodes that
ended during performance year 2 (DR).
Also, starting with the EPM
reconciliation process for performance
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327
year 2, in order to determine the
reconciliation or repayment amount, the
amount from the subsequent
reconciliation calculation would be
combined with the NPRA for that
subsequent year. The result of the postepisode spending calculation for
performance year 1, as discussed in
section III.D.7.e. of the proposed rule,
and the dollar amount of the EPM
discount percentage that was paid out as
shared savings to an ACO during the
prior year as specified in section
III.D.6.b. of the proposed rule, would
also be added to the NPRA and
subsequent reconciliation calculation in
order to create the reconciliation
payment or repayment amount. If the
amount is positive, and if the EPM
participant is in the acceptable or better
quality category for the EPM (discussed
further in section III.E.3.f of the
proposed rule), the EPM participant
would receive the amount as a
reconciliation payment from Medicare.
If the amount is negative, Medicare
would hold the EPM participant
responsible for repaying the absolute
value of the repayment amount
following the rules and processes for all
other Medicare debts. For example,
when we conduct reconciliation for
performance year 2 in early 2019, we
would calculate the performance year 2
NPRA and the subsequent reconciliation
calculation, post-episode spending, and
ACO overlap calculation for
performance year 1. These amounts
would be added together to create the
reconciliation payment or repayment
amount.
Note that given our proposal to not
hold EPM participants financially
responsible for repayment for the first
performance year, during the
reconciliation process for performance
year 2, the subsequent reconciliation
calculation amount (for performance
year 1) would be compared against the
performance year 1 NPRA to ensure that
the sum of the NPRA calculated for
performance year 1 and the subsequent
reconciliation calculation for year 1 is
not less than zero. Likewise given our
proposal to not hold EPM participants
financially responsible for repayment
for episodes ending during performance
year 2 (NDR), during the reconciliation
process for performance year 3, the
subsequent reconciliation calculation
amount for performance year 2 (NDR)
would be compared against the
performance year 2 (NDR) NPRA to
ensure that the sum of the NPRA
calculated for performance year 2 (NDR)
and the subsequent reconciliation
calculation for performance year 2
(NDR) is not less than zero.
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For performance year 2 (DR) and
performance years 3 through 5, though,
we proposed that Medicare would hold
the participant responsible for repaying
part or all of the absolute value of the
repayment amount, as proposed in
section III.D.2.c. of the proposed rule,
following the rules and processes for all
other Medicare debts. Table 17
illustrates a simplified example of how
the subsequent reconciliation
calculation may affect the following
year’s reconciliation payment. Note that
this example assumes the EPM
participant is not responsible for postepisode spending or ACO overlap for
performance year 1.
TABLE 17—SAMPLE RECONCILIATION RESULTS
Performance year
1
(2017)
NPRA
Performance year
1 subsequent
reconciliation
calculation
Difference
between PY1
subsequent
reconciliation
calculation and
NPRA
Performance year
2
(2018)
NPRA*
Reconciliation
payment made to
EPM participant
in quarter 2 2019
$50,000
$40,000
($10,000)
$25,000
$15,000
Participant A ..........................................
* Note the calculation of NPRA for performance year 2 represents the combined amounts of the NPRA for performance year 2 (NDR) and performance year 2 (DR).
The second column represents the
NPRA calculated for performance year
1, meaning that EPM participant A’s
aggregated episode payment was
$50,000 below the sum of qualityadjusted target prices for all of
Participant A’s EPM episodes. The third
column represents the subsequent
reconciliation calculation, indicating
that when calculating actual EPMepisode payments during performance
year 1 a second time, we determined
that Participant A’s aggregated EPMepisode payment was $40,000 below the
sum of quality-adjusted target prices for
all of Hospital A’s EPM episodes, due to
claims run out, accounting for model
overlap, or other reasons. The fourth
column represents the difference
between the subsequent reconciliation
calculation and the raw NPRA
calculated for performance year 1. This
difference is then combined with the
amount in the fifth column to create the
reconciliation payment amount for PY2,
which is reflected in the sixth column.
This reconciliation process would
account for overlap between the EPMs
and other CMS models and programs as
discussed in section III.D.6.b of the
proposed rule, and would also involve
updating performance year EPMepisode claims data. We also noted that
in cases where an EPM participant has
appealed one or more of its EPM quality
measure results through the HIQR
Program appeal process (which is not
part of the proposed EPM appeals
process), where such HIQR Program
appeal findings would result in a
different effective discount factor for the
EPM participant to calculate the qualityadjusted target prices from EPM-episode
benchmark prices, the subsequent
reconciliation calculation would
account for these changes as well.
For example, for performance year 1
for these EPMs in 2017, we would
capture claims submitted by March 1,
2018, and reconcile payments for EPM
participants approximately 6 months
after the end of the performance year 1
in quarter 2 of calendar year 2018. We
would carry out the subsequent
reconciliation calculation in the
following year in quarter 2 of calendar
2019, simultaneously with the
reconciliation process for the second
performance year, 2018. Table 18
displays the reconciliation timeframes
for the EPMs.
TABLE 18—TIMEFRAME FOR RECONCILIATION FOR EPMS
EPM
performance
year
NPRA calculation
Second reconciliation, ACO overlap,
and post-episode
spending
calculations
Calculation
amounts included in
reconciliation
payment and
repayment amounts
March 1, 2018 .......
Q2 2018 .................
March 1, 2019 .......
Q2 2019
March 1, 2019 .......
Q2 2019 .................
March 1, 2020 ........
Q2 2020
March 1, 2020 .......
Q2 2020 .................
March 2, 2021 ........
Q2 2021
March 2, 2021 .......
Q2 2021 .................
March 1, 2021 ........
Q2 2021
March 1, 2022 .......
Q2 2022 .................
March 1, 2023 ........
Q2 2023
EPM performance period
Year 1* .............
Year 2 ...............
Year 3 ...............
Year 4 ...............
Year 5 ...............
Reconciliation
claims submitted by
Episodes beginning on or after July
1, 2016 and ending through December 31, 2017.
Episodes ending January 1, 2018
through December 31, 2018.
Episodes ending January 1, 2019
through December 31, 2019.
Episodes ending January 1, 2020
through December 31, 2020.
Episodes ending January 1, 2021
through December 31, 2021.
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* Note that the reconciliation for Year 1 would not include repayment responsibility from EPM participants.
We proposed this approach in order
to balance our goals of providing
reconciliation payments in a reasonable
timeframe, while being able to account
for overlap and all Medicare claims
attributable to EPM episodes. We
believe that beginning to pull claims 2
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months after the end of the performance
year would provide sufficient claims
run-out to conduct the reconciliation in
a timely manner, given that our
performance year includes EPM
episodes ending, not beginning, by
December 31st. We noted that in
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accordance with the regulations at
§ 424.44 and the Medicare Claims
Processing Manual (Pub. L. 100–04),
Chapter 1, Section 70, Medicare claims
can be submitted no later than 1
calendar year from the date-of-service.
We also noted our recognition that by
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pulling claims 2 months after the end of
the performance year to conduct
reconciliation, we would not have
complete claims run-out. However, we
believed that the 2 months of claims
run-out would be an accurate reflection
of EPM-episode payments and
consistent with the claims run-out
timeframes used for reconciliation in
other payment models, such as BPCI
Models 2 and 3 and the CJR model.
Otherwise, the alternative would be to
wait to reconcile until we have full
claims run out 12 months after the end
of the performance year, but we were
concerned that this approach would
significantly delay earned reconciliation
payments under the EPMs.
However, we proposed to conduct a
subsequent reconciliation calculation 14
months after the end of a performance
year to account for canceled episodes,
post-episode spending, overlap with
other CMS models and programs, and
any remaining claims available at that
time. The proposals for the annual
reconciliation and subsequent
reconciliation calculation were included
in § 512.305 and § 512.307. We sought
comment on these proposals for an
annual reconciliation and subsequent
calculation.
The following is a summary of the
comments received and our responses.
Comment: A number of commenters
supported the proposal for
reconciliation payments, including the
waiver of deductibles and copays with
respect to reconciliation payments and
Medicare repayments. While one
commenter indicated that the proposed
timeframes for reconciliation were
reasonable, most of the commenters
requested that CMS provide
reconciliation payments or estimates of
what reconciliation payments would be
on a more frequent basis than annually.
In most cases, these commenters
recommended reconciliation payments
on a quarterly basis (some noted this
would be similar to BPCI and
recommended the BPCI true-up process
whereby we would make an initial
reconciliation with three revisions (or
‘‘true-ups’’) in order to include
additional claims run outs and any
other changes that might have occurred
with the third (final) true-up occurring
9 months after the initial reconciliation
rather than 12 months later than the
subsequent reconciliation as is the case
for the EPMs and CJR. Another
commenter recommended quarterly
reconciliation determination with the
option of an annual reconciliation for
those hospitals preferring such while
another recommended the opposite.
Commenters favoring more frequent
reconciliations suggested that doing so
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would provide hospitals with better
cash flow that could be used to invest
in the changes needed to be successful
as well as more immediate feedback that
would enable participants to better
assess their performance and determine
which of their approaches are effective
as well as what changes might be
needed to improve their performance.
Further, if hospitals had more up front
funding, they could in turn provide
more frequent financial rewards to
downstream collaborating providers,
which would better maintain incentives
on a more consistent basis to promote
care coordination, with improved
quality and efficiencies. One commenter
suggested that the proposed annual
reconciliation payment schedule could
impede care redesign efforts and
undermine gainsharing.
In addition to comments on the
frequency of reconciliation, a
commenter recommended that
reconciliation occur at the beneficiary
episode level rather than in aggregate
across beneficiary episodes, as we
proposed, because the former would
better focus financial incentives on each
episode as hospitals would recognize
that they bear risk for every episode
individually rather than in aggregate. In
this commenter’s view, CMS’ proposal
will more likely encourage gaming
across episodes where a hospital tries to
offset losses from one episode through
savings on another.
Response: We appreciate the
comments we received supporting our
proposal for an annual reconciliation
with subsequent calculation as well as
the suggestions for more frequent
reconciliations or estimated
reconciliation amounts. We are not
persuaded to make reconciliation
payments or estimated payment
amounts available more frequently than
on an annual basis. We are concerned
that, particularly for small hospitals, the
number of cases included in quarterly
data would limit the representativeness
of the data, which could produce
somewhat misleading results. For
similar reasons, do not believe that
making more frequent reconciliation
payments available than annually
would advantage participants based on
the expectation that additional
resources would enhance their ability to
develop infrastructure or gainsharing
arrangements. Last, we are not
persuaded to adopt the suggestion to
determine reconciliations at the episode
level. The commenter suggested that the
proposed policy will result in hospitals
‘‘gaming’’ payments by offsetting losses
for one episode with savings in another;
however, we question this view. Rather,
we believe the issue raised in this
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329
comment and our proposal for
determining reconciliation payments
under the models is similar and
analogous to the basis under which
Medicare makes payments under its FFS
prospective systems in general. That is,
for Medicare FFS prospective payments,
an ‘‘average’’ payment is typically
determined for a specific procedure or
set of services where participants might
‘‘gain’’ or ‘‘lose’’ for a specific case but,
on average and in aggregate across all
cases, are paid that average amount.
Given their recognition of this, we
would not anticipate that Medicare
providers and suppliers ‘‘game’’ their
payments to offset losses on a case-bycase basis. Likewise, we would not
expect that EPM participants would be
any more or less encouraged to ‘‘game’’
episode payments depending on
whether they received reconciliation
payments at the episode level or in
aggregate across all episodes.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal, without
modification, to make an annual
reconciliation with subsequent
calculation. Our final policies for an
annual reconciliation and subsequent
calculation are included in § 512.305
and § 512.307.
We would also note that since we
have delayed the requirement to assume
downside risk to performance year 3,
except for participants that elect
downside risk in performance year 2,
we will not be performing two separate
aggregations, as we had proposed, to
separately create one NPRA for the
period in performance year 2 without
downside risk and another NPRA for the
period where downside risk would
apply.
Thus, in contrast to our proposal,
unless the EPM participant elected
downside risk in performance year 2,
we would calculate an EPM
participant’s NPRA for the performance
year 1 and 2 reconciliation processes,
and if positive, such participant would
receive the amount as a reconciliation
payment from Medicare, subject to the
stop-gain limit for performance year 1 or
performance year 2.
Also, starting with the EPM
reconciliation process for performance
year 2, in order to determine the
reconciliation or repayment amount, the
amount from the subsequent
reconciliation calculation would be
combined with the NPRA for that
subsequent year. The result of the postepisode spending calculation for
performance year 1, as discussed in
section III.D.7.e. of the proposed rule,
and the dollar amount of the EPM
discount percentage that was paid out as
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shared savings to an ACO during the
prior year as specified in section
III.D.6.b. of the proposed rule, would
also be added to the NPRA and
subsequent reconciliation calculation in
order to create the reconciliation
payment or repayment amount. If the
amount is positive, and if the EPM
participant is in the acceptable or better
quality category for the EPM (discussed
further in section III.E.3.f of the
proposed rule), the EPM participant
would receive the amount as a
reconciliation payment from Medicare.
If the amount is negative, Medicare
would hold the EPM participant
responsible for repaying the absolute
value of the repayment amount
following the rules and processes for all
other Medicare debts. Though the NPRA
for performance year 2 will be subject to
a stop-loss limit of 0 percent, except for
EPM participants that elected downside
risk in performance year 2, it is still
possible that EPM participants not
electing downside risk for performance
year 2 could owe a repayment amount
because of the subsequent reconciliation
calculation, post-episode spending
calculation, and ACO overlap
calculation for performance year 1. For
example, when we conduct
reconciliation for performance year 3 in
early 2020, we would calculate the
performance year 3 NPRA and the
subsequent reconciliation calculation,
post-episode spending, and ACO
overlap calculation for performance year
2. These amounts would be added
together to create the reconciliation
payment or repayment amount.
Note that given our proposal to not
hold EPM participants financially
responsible for repayment for the first
performance year and the stop-loss limit
of 0 percent for NPRA for the second
performance year (except for EPM
participants that otherwise elected
downside risk),during the reconciliation
process for performance year 3, the
subsequent reconciliation calculation
amount (for performance year 2) would
be compared against the performance
year 2 NPRA to ensure that the sum of
the NPRA calculated for performance
year 2 and the subsequent reconciliation
calculation for year 2 is not less than
zero.
For an EPM participant that elected
downside risk in performance year 2
and all participants in performance
years 3 through 5, Medicare would hold
the participant responsible for repaying
part or all of the absolute value of the
repayment amount, as proposed in
section III.D.2.c. of the proposed rule,
following the rules and processes for all
other Medicare debts.
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Also, we would note that this final
rule corrects proposed § 512.305(d)(iii)
so that it refers to § 512.460(b) rather
than § 512.460(b)(5).
c. Reconciliation Report
For EPM participants to receive
timely and meaningful feedback on their
performance under the models as well
as better understand the basis of their
reconciliation payment or Medicare
repayment for a given performance year,
if any, we proposed to annually issue to
EPM participants a reconciliation report
(81 FR 50867), similar to the CJR
Reconciliation Report we make
available to CJR participants (80 FR
73408). We proposed that these reports
would contain the following
information:
• Information on the EPM
participant’s composite quality score
described in section III.E.3.a. through
III.E.3.e of this final rule.
• The total actual episode payments
for the EPM participant.
• The NPRA.
• Whether the EPM participant is
eligible for a reconciliation payment or
must make a repayment to Medicare.
• The NPRA and subsequent
reconciliation calculation amount for
the previous performance year, as
applicable.
• The post-episode spending amount
and ACO overlap calculation for the
previous performance year, as
applicable.
• The reconciliation payment or
repayment amount.
For performance year 2, we proposed
that the reconciliation report would
include information separately for the
performance year 2 (NDR) and
performance year 2 (DR) portions of that
year.
As discussed in section III.D.8 of the
proposed rule, EPM participants would
review their reconciliation report and
would be required to provide written
notice of any error, in a calculation error
form that must be submitted in a form
and manner specified by CMS. Unless
the EPM participant provides such
notice, the reconciliation report would
be deemed final within 45 calendar days
after it is issued, and CMS would
proceed with payment or repayment.
The proposal to issue a reconciliation
report was included in § 512.305(f). We
sought comments on our proposal to
issue a reconciliation report to EPM
participants and what other
information, if any, would be helpful to
include in this report.
The following is a summary of the
comments received and our responses.
Comment: As noted previously in
section III.D.5.a. and b. of this final rule,
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some commenters requested that
reconciliation payments or estimates of
what reconciliation payments would be
more frequently than on an annual
basis. A commenter requested that,
given the many adjustments to costs,
including various value-based payments
such as HRRP, CMS make publicly
available and to the CJR model
participant hospitals and EPM
participants documentation of the
various adjustments that would allow
participants to verify or validate the
adjustments and calculations. This
commenter was concerned that
providers who are taking on risk could
otherwise be penalized multiple times
for readmissions in the bundled
payment program as well as other valuebased payment programs.
Response: For the reasons previously
articulated in this comment and
response section, we are not persuaded
to make reconciliation reports available
for frequently than on an annual basis.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal, without
modification, to annually issue a
reconciliation report. Our final policy
for issuing a reconciliation report is
included in § 512.305(f).
6. Adjustments for Overlaps With Other
Innovation Center Models and CMS
Programs
a. Overview
Three issues may arise in overlap
situations that must be addressed under
EPM. First, we acknowledge that there
may be circumstances where a hospital
in a geographic area selected for the
AMI, CABG or SHFFT model is also
participating in BPCI for the same
episode. We refer to this as ‘‘provider
overlap.’’ Second, there may be
situations where a Medicare beneficiary
receives care that could potentially be
counted under more than one episode or
total cost of care payment model. We
refer to this as ‘‘beneficiary overlap.’’
Finally, EPM reconciliation payments
and Medicare repayments made under
Parts A and B and attributable to a
specific beneficiary’s episode may be at
risk of not being accounted for by other
models and programs when determining
the beneficiary’s cost of care under
Medicare. Therefore, a payment
reconciliation policy is necessary in
order to credit the entity that is closest
to that care for the episode of care in
terms of time, location, and care
management responsibility.
We established our proposal for
provider overlap at § 512.100(b) and
§ 512.230(g). We established our
proposal for beneficiary overlap at
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§ 512.230(f), § 512.230(h), and
§ 512.230(i). We established our
proposal for payment reconciliation at
§ 512.210 and § 512.305. We sought
comment on our proposals to account
for overlap between EPMs and other
CMS models or programs.
The following is a summary of the
comments received and our responses.
Comment: We received numerous
comments related to overlap between
EPMs and other CMS models or
programs.
Response: For further discussion of
comments related to model and program
overlap, we refer readers to the specific
sections later in this section of this final
rule.
b. Provider Overlap
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(1) BPCI Participant Hospitals in
Geographic Areas Selected for EPMs
Provider overlap exists when a
hospital in a geographic area selected
for the AMI, CABG or SHFFT model is
also an episode initiator in BPCI for an
episode anchored by that EPM’s DRG.
BPCI is an episode payment model
testing AMI, CABG, SHFFT, and 45
other episodes in acute care, post-acute
care, or both acute care and post-acute
care settings.
Similar to CJR, we proposed for the
EPMs that in the geographic areas where
the AMI, CABG and SHFFT models will
be implemented, an acute care hospital
participating in BPCI Model 2 or 4 will
participate in an EPM for episodes
anchored by EPM MS–DRGs that are not
covered under the hospital’s current
BPCI agreement. If a BPCI hospital in an
EPM-selected area withdraws from BPCI
episodes anchored by EPM MS–DRGs,
the BPCI hospital will participate in the
EPMs from which it was previously
excluded. As we stated in the proposed
rule, we believe this proposal promotes
accountable care by ensuring
beneficiary coverage by BPCI or an EPM
in selected areas.
We established the proposal for
hospitals in geographic areas selected
for EPMs that are also participating in
BPCI episodes anchored by EPM DRGs
at § 512.100(b). We sought comment on
this proposal. The following is a
summary of the comments received and
our responses.
Comment: Overall, we received
considerable support from commenters
for our proposal to continue to give
precedence to existing BPCI models
where the EPM participant was also
participating in a BPCI model that
overlapped with a SHFFT, AMI, or
CABG EPM. Several commenters
requested that existing precedence rules
should continue for any similar
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voluntary models implemented after
September 2018 when the current BPCI
model is scheduled to end.
Response: We appreciate the many
comments of support received for this
aspect of the model. We wish to clarify
that the current order of precedence for
model overlaps pertains only to the
currently existing models. CMS shall
evaluate how to handle model overlaps
for any future models at the time of
implementation based on experience
and knowledge gained through previous
models.
We also recognize that this policy
could indirectly impact clinicians with
financial arrangements with an EPM
participant, therefore, we refer to
section III.A.2 for discussions of the
ability for eligible clinicians to become
qualifying APM participants (QP) as
affiliated practitioners of EPMs that
meet the Advanced APM criteria under
the Quality Payment Program.
Specifically, we are referring to the
policy that eligible clinicians can meet
program thresholds through
participation in multiple Advanced
APMs. We further discuss the
considerations for a new alternative
bundled payment model, and in
particular the consideration for such a
program to qualify as an Advanced
APM, in section III.A.3.
Comment: Several commenters
recommended that in order to minimize
overlap with existing BPCI models, CMS
exclude MSAs where there are existing
BPCI models. A commenter
recommended that BPCI participating
hospitals be exempt from having to
participate in multiple models even if
there were no overlap in the episodes
covered under each model. For
example, a hospital participating in
BPCI for SHFFT episodes would be
exempt from having to participate in
CABG or AMI EPMs.
Response: In identifying eligible
MSAs where the EPMs could be
implemented, we proposed to explicitly
factor in the number of non-BPCI
eligible cases when considering the
relevant minimum volume of cases in
an MSA. We refer readers to sections
III.B.4., ‘‘Geographic Unit of Selection
and Exclusion of Selected Hospitals’’
and IIII.B.5., ‘‘Overview and Options for
Geographic Area Selection for AMI and
CABG Episodes’’ of this final rule for a
more detailed discussion of the factors
considered in the selection of MSAs for
EPMs. We do not believe it is
appropriate to exempt hospitals from
participating in EPMs solely because
they are participating in a BPCI model
for another non-overlapping episode. To
do so would limit the potential volume
of cases for evaluation purposes and
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331
could lead to patient steerage in areas
where some hospitals in the same
market may be participating in the EPM
and others may not. Moreover, while we
acknowledge the potential for some
operational differences for those
hospitals implementing multiple
models, hospitals already participating
in BPCI may, in fact, already have some
of the infrastructure in place and be
well positioned to succeed in
implementing EPMs as well.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal, without
modification, for handling overlap
situations between EPM and BPCI
participating hospitals. That is, in the
geographic areas where the AMI, CABG
and SHFFT models will be
implemented, an acute care hospital
participating in BPCI Model 2 or 4 will
participate in an EPM only for episodes
anchored by EPM MS–DRGs that would
not otherwise be a BPCI episode. BPCI
episodes would take precedence over
EPM episodes.
(2) BPCI Physician Group Practice (PGP)
Episode Initiators in Hospitals
Participating in EPMs
It is possible that a physician in a
BPCI PGP may treat a Medicare
beneficiary in a hospital participating in
one or more EPMs. We proposed that if
a beneficiary is admitted to an EPM
participant for an episode anchored by
EPM MS–DRGs that is also covered
under the PGP’s BPCI agreement and the
attending or operating physician on the
admission’s inpatient claim is a member
of the BPCI PGP, the BPCI episode will
take precedence over the EPM episode
for which the hospital would otherwise
be the accountable entity. In other
words, if, for any portion of the EPM
episode, a beneficiary would also be in
a BPCI PGP episode, we will cancel an
episode that has already been initiated
or never initiate the EPM episode in the
first place. For example:
• A beneficiary is admitted for a
CABG to an EPM participant in the
CABG model. The attending or
operating physician on the inpatient
claim for the admission is in a BPCI
Model 2 PGP participating in CABG.
The episode is initiated under BPCI; an
EPM episode does not initiate.
• A beneficiary is admitted for an
AMI to an EPM participant in the AMI
model. The beneficiary receives a PCI
while hospitalized. The attending or
operating physician on the inpatient
claim for the admission is in a BPCI
Model 2 PGP participating in PCI
episodes but not medical AMI episodes.
A PCI episode is initiated under BPCI;
an EPM episode does not initiate.
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• A beneficiary is admitted for an
AMI to an EPM participant in the AMI
model. A PCI was not part of the
beneficiary’s treatment. The attending or
operating physician on the inpatient
claim for the admission is in a BPCI
Model 2 PGP participating in PCI
episodes only. The episode is initiated
under the AMI model. A PCI episode
under BPCI Model 2 would not initiate
unless a PCI were performed on the
beneficiary, and
• A beneficiary is admitted for an
AMI to an EPM participant in the AMI
model. A CABG was not part of the
beneficiary’s treatment. The attending or
operating physician on the inpatient
claim is in a BPCI Model 2 PGP
participating in CABG episodes only.
The episode is initiated under the AMI
model. A CABG episode under BPCI
Model 2 would not be initiated unless
a CABG was performed on the
beneficiary while hospitalized.
We established the proposal for BPCI
PGP episode initiators in hospitals
participating in EPMs at § 512.230(g).
We sought comment on this proposal.
The following is a summary of the
comments received and our responses.
Comment: Many commenters
supported our proposal to give
precedence to situations where there
was overlap between an episode
attributed to a PGP voluntarily
participating in BPCI and one that could
otherwise have been attributed to an
EPM participating hospital. However,
we received several comments that
expressed disagreement with this
policy. These commenters believed that
the hospital participant should have
priority for having responsibility and
financial accountability for the episode.
A commenter expressed the specific
concern that PGPs participating in BPCI
could potentially select lower intensity
cases and steer higher intensity and
potentially more costly cases to nonBPCI, EPM participant hospitals.
Concern was also expressed by some
commenters that attributing episodes to
BPCI in these situations would lower
the volume of episodes available to the
hospital and potentially make it less
cost effective for the hospital to
implement operational changes
necessary to better manage episodes.
Response: We acknowledge the
potential for overlap between PGP
initiated BPCI episodes and hospital
attributed EPM episodes in those MSAs
selected for EPM participation where
there are also PGP BPCI initiators. CMS
will monitor admission and transfer
patterns and trends to identify any
inappropriate patient steerage that may
be occurring. On balance, however, we
believe it is important to maintain CMS’
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commitment to existing models for
which participants have volunteered
and in which they are already actively
involved. As these models end and CMS
has the opportunity to evaluate their
performance, including the impact of
overlaps, we will incorporate the
findings in the design of future models.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal, without
modification, for handling overlaps
between BPCI PGP episodes and
episodes initiated in hospitals
participating in EPMs.
(c) Beneficiary Overlap
(1) Beneficiary Overlap With BPCI
As we stated in the proposed rule, we
also need to account for instances where
a different model’s episode could
initiate during an ongoing EPM episode.
We proposed that any BPCI Model 2, 3
or 4 episode, regardless of its anchor
DRG exclusion status from an EPM
episode definition, takes precedence
over an AMI, CABG or SHFFT episode
such that it would cancel or prevent the
initiation of an AMI, CABG or SHFFT
episode. For example—
• If a beneficiary is in an ongoing
AMI model episode and is treated for
SHFFT by a hospital, PGP physician, or
post-acute care provider participating in
a BPCI SHFFT episode, the initial AMI
model episode will be canceled. The
second entity will initiate a new episode
under BPCI subject to the payment rules
under that model, and
• If a beneficiary is in an ongoing
BPCI AMI episode and is readmitted for
SHFFT to an EPM participant in the
SHFFT model, the BPCI episode would
continue and the SHFFT model episode
would not initiate.
Participants in BPCI have an
expectation that eligible episodes will
be part of the BPCI model test, whereas,
based on our proposal, EPM participants
would be aware that episodes may be
canceled when there is overlap with
BPCI episodes. As stated in the
proposed rule, we aim to preserve the
integrity of ongoing model tests without
introducing major modifications that
could make evaluation of existing
models more challenging. Given the
current scheduled end date for BPCI, we
proposed to give precedence to episodes
covered under BPCI Models 2, 3 and 4
initiated on or before September 30,
2018.
In the proposed rule, we
acknowledged that this proposed BPCI–
EPM overlap policy differs from the CJR
beneficiary overlap policy, where a
beneficiary may be in a CJR LEJR
episode and a non-LEJR BPCI episode
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concurrently. However, in CJR this
overlap is rare. Within the 90-day posthospital discharge period, included
readmissions occur for less than 1
percent of LEJR beneficiaries. In
contrast, included readmissions occur
for approximately 25 percent of AMI
and CABG beneficiaries. The high
incidence of included readmissions for
AMI, CABG, and SHFFT episodes
necessitates a different policy to avoid
double-paying savings and doublecounting losses, as well as not initiating
new episodes when the readmission is
a complication of care during the first
episode that could have been managed.
As we stated in the proposed rule, we
considered alternative options for
dealing with situations in which a
beneficiary in an EPM episode could
also be in a BPCI episode, including
allowing the first episode initiated to
take precedence regardless of the model
under which it occurred. This would
encourage more accountable care,
particularly with AMI, CABG, and
SHFFT episodes that are more likely to
involve readmissions for complications
than generally occur with LEJR.
However, preventing BPCI episodes
from being initiated, particularly those
initiated by post-acute care providers
which, by definition, occur after an
anchor hospitalization, could
substantially reduce the number of such
episodes and our ability to fully test
BPCI. Moreover, operational challenges
due to different timelines for payment
reconciliation are of concern.
We established the proposal for
beneficiary overlap with BPCI at
§ 512.230(h). We sought comment on
this proposal.
The following is a summary of the
comments received and our responses.
Comment: As with the previously
described overlap situations, we
received numerous comments in
support of giving precedence to the
BPCI initiated episode. However, many
commenters did express concern over
how EPM participant hospitals would
be able to know whether a presenting
patient is already covered by a BPCI
episode or if an EPM episode is
subsequently cancelled. Several
commenters stated that it was
unrealistic to expect hospitals or other
providers to identify such patients in
‘‘real-time’’ and requested CMS clarify
its administrative policies for
identifying and informing EPM
participants about beneficiaries whose
episodes are initiated and then
cancelled for any reason. A commenter
requested at least quarterly notification.
The commenters pointed out that EPM
participant awareness of episode
cancellation is important for several
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reasons, including EPM participant
calculation and monitoring of episode
spending; beneficiary notification;
provision of beneficiary engagement
incentives; and determination of
beneficiary eligibility for certain rule
waivers. In addition, these commenters
expressed concern about the potential
for beneficiary confusion and
dissatisfaction with multiple
coordinators of care, as well as costly
duplication of services when multiple
entities believe they are accountable for
the episode.
Response: We acknowledge the
potential for confusion for providers
participating in markets where there are
BPCI participants or in situations where
patients may travel out of area to receive
services that result in cancelling EPM
episodes. We also appreciate the interest
of the commenters in conducting timely
analyses of EPM episode spending, as
well as ensuring that the requirements
of the EPM are met in their treatment of
Medicare beneficiaries. The potential for
this to occur makes it important for EPM
participants to become familiar with the
range of models operating in their
market and to maintain ongoing
relationships with their patients after
discharge, as well as to develop
collaboration arrangements with
physicians. Even with this, we
acknowledge that EPM participants and
their staff may not know when all
overlaps occur. Given our plans for
providing and updating episode claims
data to EPM participants upon request
as frequently as quarterly as discussed
in section III.K.5. of this final rule, we
will explore adding additional data
elements to the beneficiary-identifiable
claims data provided to EPM
participants that would indicate
potential for episode cancellation such
as admission of a beneficiary to a
hospital or post-acute care facility that
initiates episodes under BPCI or receipt
of inpatient services by a physician in
a BPCI PGP. To the extent adding such
indicators to the claims data is feasible,
providing this information through the
claims data shared with EPM
participants would ensure that EPM
participants are informed as frequently
as quarterly about beneficiary
circumstances that could result in EPM
episode cancellation. This information
would not be real-time, however, and
while based on the best available
information at the time, it would be
subject to change due to the lag-time for
the relevant claim to be submitted and
processed and then reported back to the
EPM participant. We note that at
reconciliation, complete information
would be provided to EPM participants
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about those episodes that were
ultimately included in the participant’s
reconciliation report as discussed in
section III.D.5. of this final rule.
We note that we expect EPM
participants to be actively managing all
of their beneficiaries with conditions
characterized by AMI, CABG, or SHFFT
based on their care pathways, regardless
of the model of program that may
ultimately apply to the beneficiary
under the uncommon circumstances of
EPM episode cancellation. We also want
to emphasize the importance of strong,
ongoing communication among
providers in a given geographic area
caring for beneficiaries in similar
models or programs where provider
interests in delivering high quality,
efficient health care should align.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal, without
modification, for handling situations in
which a beneficiary eligible for coverage
under an EPM is already covered by a
BPCI episode or subsequently becomes
eligible for coverage under a BPCI
episode during the EPM episode period.
Recognizing the limitation on available
data, CMS will work to provide better,
more timely informational resources to
participants, where feasible, to assist
them in identifying episodes that may
be ineligible or cancelled due to
overlaps.
(2) Beneficiary Overlap With the CJR
Model and Other EPMs
As discussed in section III.C.4. of the
proposed rule, if a beneficiary is in a
SHFFT, AMI or CABG model or CJR
episode and has a hospital readmission
that is not excluded from the ongoing
episode definition and would otherwise
initiate an episode in a different EPM or
the CJR model, that hospital
readmission will not initiate another
episode or cancel the ongoing episode.
If a beneficiary is in a SHFFT, AMI or
CABG model episode or CJR episode
and has a hospital readmission that is
excluded from the ongoing episode
definition and could initiate an episode
in a different EPM or the CJR model, the
subsequent EPM or CJR episode will
initiate, the ongoing episode would
continue, and both episodes will occur
concurrently. For example—
• The CJR model episode definition
does not exclude the MS–DRGs that
would initiate a SHFFT model episode.
If a beneficiary is in the CJR model and
receives SHFFT at an EPM participant
in the SHFFT model during the ongoing
CJR episode, the CJR episode will
continue and the SHFFT model episode
will not initiate;
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333
• The SHFFT model episode
definition does not exclude the MS–
DRGs that would initiate a CJR LEJR
episode. If a beneficiary is in the SHFFT
model and receives an LEJR at a CJR
hospital during the ongoing SHFFT
episode, the SHFFT episode will
continue and the CJR episode will not
initiate;
• The SHFFT model episode
definition does not exclude the MS–
DRGs that would initiate an AMI model
episode. If a beneficiary is in the SHFFT
model and is readmitted for an AMI to
an EPM participant in the AMI model
during the ongoing SHFFT model
episode, the SHFFT model episode will
continue and the AMI model episode
will not initiate;
• The AMI model episode definition
does not exclude the MS–DRGs that
would initiate a CABG model episode.
If a beneficiary is in the AMI model and
is readmitted for a CABG to the same or
another EPM participant in the CABG
model during the ongoing AMI model
episode, the AMI model episode will
continue and the CABG model episode
will not initiate.
As stated in the proposed rule, we
believe that an overlap policy that gives
precedence to the ongoing episode over
subsequent episodes initiated during the
post-hospital discharge period, except
where the second admission is
explicitly excluded, aligns with our
stated goal of encouraging more
accountable care. Moreover, this policy
would establish an operationally
straightforward policy for future EPMs.
We established the proposal for
beneficiary overlap with the CJR model
and other EPMs at § 512.230(i). We
sought comment on this proposal.
We received no comments related to
our proposed overlap policy that gave
precedence to the ongoing episode
when there was the potential for overlap
between CJR and EPM episodes that
were not otherwise excluded from the
first episode’s definition.
Final Decision: Given that we
received no public comments on the
proposed policy for beneficiary overlap
with the CJR model and the EPMs, we
are finalizing the proposal, without
modification, to give precedence to an
ongoing EPM episode over subsequent
episodes initiated during the posthospital discharge period, except where
the second admission is explicitly
excluded from the initial episode.
(3) Beneficiary Overlap With Shared
Savings Models and Programs
We explained in the proposed rule
our expectation that many beneficiaries
in an AMI, CABG or SHFFT model
episode will also be assigned to a
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Shared Savings Program ACO or a
participant in an ACO model initiated
by the CMS Innovation Center. For the
purposes of this discussion, the term
ACO will be used generically to refer to
either Shared Savings Program or
Innovation Center ACO models. Shared
savings payments to ACOs and shared
savings losses repaid by ACOs to CMS
have the potential to overlap with EPM
reconciliation payments. As with CJR,
we proposed to attribute savings
achieved during an EPM episode to the
EPM participant, and to include EPM
reconciliation payments for ACOaligned beneficiaries as ACO
expenditures. In order to address
comments received during rulemaking
for CJR, we proposed to test an
alternative strategy to address ACO
overlap. Specifically, we proposed to
exclude beneficiaries from EPMs who
are aligned to ACOs in the Next
Generation ACO model and End Stage
Renal Disease (ESRD) Seamless Care
Organizations (ESCOs) in the
Comprehensive ESRD Care model in
tracks with downside risk for financial
losses. We did not propose to exclude
beneficiaries assigned to Shared Savings
Program ACOs in Tracks 1, 2, or 3.
However, we sought comment on
excluding beneficiaries from EPMs that
are prospectively assigned to Shared
Savings Program Track 3 ACOs as well
as to other financial risk tracks. The
Shared Savings Program is a national
program. We do not believe that testing
a new approach to addressing overlap,
which could potentially disrupt ACO
investments, operations, and care
redesign activities, would be
appropriate for all Shared Savings
Program ACOs at this time prior to a test
with a smaller population. As we stated
in the proposed rule, we plan to monitor
and learn from the test of excluding
beneficiaries prospectively assigned to
an ACO from risk tracks and to consider
these results and comments in future
rule-making.
Several strong considerations drive us
to otherwise follow CJR precedent for
addressing ACO overlap. As we stated
in the proposed rule, CMS continues to
avoid double payment of savings and
double recoupment of losses, which is
an important principle of successful
payment reform. Further, in
implementing the EPMs, there would be
no additional operational effort due to
consistency in ACO overlap policies
across models. In this respect, we
anticipate little to no difficulty in
replicating prior policy as new episode
payment models are introduced. Third,
this would have no negative financial
impact on EPM participants, an
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important consideration for future
EPMs. The payment reconciliation for
EPM participants is described in section
III.D.5. of the proposed rule.
Therefore, we proposed to follow the
policy set forth in the CJR Final Rule for
accounting for overlap between EPMs
and the Shared Savings Program and
ACO models other than the Next
Generation ACO and CEC models listed
previously.
Additionally, for programmatic
consistency among ACO models and
programs, given that our ACO models
generally are tested for the purpose of
informing future potential changes to
the Shared Savings Program, we believe
that the ACO model overlap adjustment
policy should be aligned with the
Shared Savings Program policy. Thus,
we proposed that under EPMs, we
would make an adjustment to the
reconciliation amount to account for
any of the applicable discount for an
episode resulting in Medicare savings
that is paid back through shared savings
under the Shared Savings Program or
any other ACO model, but only when an
EPM hospital also participates in the
ACO and the beneficiary in the EPM
episode is also assigned to that ACO.
This adjustment would be necessary to
ensure that the applicable discount
under the EPM is not reduced because
a portion of that discount is paid out in
shared savings to the ACO and thus,
indirectly, back to the hospital.
However, we proposed not to make an
adjustment under EPMs when a
beneficiary receives an AMI, SHFFT, or
CABG at a hospital participating in the
corresponding EPM and is assigned to
an ACO in which the hospital is not
participating. While this proposal
would leave overlap unaccounted for in
such situations, we do not believe it
would be appropriate to hold
responsible for repayment the hospital
that managed the beneficiary during the
episode through an EPM adjustment,
given that the participant may have
engaged in care redesign and reduced
spending during the EPM episode. The
participant may be unaware that the
beneficiary is also assigned to an ACO.
However, we recognize that as proposed
this policy would allow an unrelated
ACO full credit for the Medicare savings
achieved during the episode. The
evaluation of each of the EPMs, as
discussed in section IV of the proposed
rule, would examine overlap in such
situations and the potential effect on
Medicare savings.
We note that our proposed policy as
outlined in the proposed rule would
entail CMS reclaiming from the EPM
participant any discount percentage
paid out as shared savings for the
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Shared Savings Program or ACO models
only when the hospital is an ACO
participant and the beneficiary is
assigned to that ACO, while other total
cost of care models such as the
Comprehensive Primary Care Plus
initiative (CPC+) would adjust for the
discount percentage in their
calculations. We believe that other ACO
models in testing that share operating
principles with the Shared Savings
Program should follow the same
policies as the EPM Shared Savings
Program adjustment for certain
overlapping ACO beneficiaries. As the
landscape of CMS models and programs
changes, we may revisit this policy
through future rulemaking.
However, there are circumstances
when an alternative option may be
appropriate to consider. Therefore, we
are also considering an EPM–ACO
overlap policy that would exclude from
EPMs beneficiaries who are assigned to
ACOs in the Next Generation ACO
model and ESCOs in the Comprehensive
ESRD Care model in tracks with
downside risk for financial losses. Some
ACOs have successfully managed acute
care and post-acute care expenditures
below regional or national mean costs,
and expressed that the current CJR and
BPCI ACO overlap policies deprives
them of a key source of savings. We are
aware of situations in certain markets
that seem to reduce opportunities for
ACOs to achieve savings given historic
experience that indicates these
particular ACOs are able to manage the
care within episodes as successfully as
EPM participants. Attributing savings to
participants in episode payment
models, such as CJR participants and
EPM participants under the proposed
rule, creates a problem where the ACO
is accountable for coordinating a
beneficiary’s care over a performance
year but is not able to benefit from
savings achieved from episodes
completed during the performance year.
Data shows that post-acute care
spending is among the most significant
sources of savings for ACOs currently,
and where they focus significant
investments.86 87 As we discussed in the
proposed rule certain considerations
86 McWilliams, J. Michael, Laura A. Hatfield,
Michael E. Chernew, Bruce E. Landon, and Aaron
L. Schwartz. ‘‘Early Performance of Accountable
Care Organizations in Medicare—NEJM.’’ N Engl J
Med. Massachusetts Medical Society, 13 Apr. 2016.
Web. 02 May 2016. https://www.ncbi.nlm.nih.gov/
pubmed/27075832.
87 McWilliams, J. Michael, Michael E. Chernew,
Bruce E. Landon, and Aaron L. Schwartz.
‘‘Performance Differences in Year 1 of Pioneer
Accountable Care Organizations.’’ N Engl J Med.
(2015); 372(20): 1927–936. Massachusetts Medical
Society, 15 Apr. 2015. Web. 02 May 2016. https://
www.ncbi.nlm.nih.gov/pubmed/25875195.
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weigh against exclusion of all ACOassigned beneficiaries from
participation in EPM episodes. Such a
blanket exclusion would remove a large
proportion of Medicare FFS
beneficiaries from the EPMs, many of
whom would inevitably receive care at
EPM participants. This would dilute the
power of the EPM test and
generalizability of EPM findings.
Additionally, differences between ACO
beneficiary assignment algorithms do
not support a blanket exclusion. It is
more operationally feasible to identify
and exclude beneficiaries who are
prospectively assigned to ACOs. In
retrospective assignment models,
beneficiaries may be assigned to an ACO
at the end of the performance year,
before the performance year, or
preliminarily assigned to one ACO
before the performance year and
subsequently assigned to a different
ACO after all qualifying services are
considered. In retrospective assignment,
there will be significant numbers of
beneficiaries assigned at final
reconciliation to a given ACO who were
not identified as preliminarily assigned
to that ACO prior to the performance
year. That is, they were identified either
as unassigned to any ACO or assigned
to a different ACO. In prospective
assignment models and tracks, the list of
assigned beneficiaries is available prior
to the start of the performance year and
a beneficiary’s assignment does not
change on the basis of his or her
utilization in the performance year
(subject to various exclusions made on
a quarterly basis, such as a beneficiary’s
election into a Medicare Advantage
plan).
Because ACOs in two-sided risk
arrangements share in both savings and
losses, they have stronger incentives
than those in one-sided risk
arrangements that share only in savings
to reduce total cost of care. Given the
possibility of paying CMS shared losses,
we believe that ACOs in two-sided risk
arrangements may be best positioned to
assume the risk associated with EPM
episodes, while ACOs in one-sided risk
arrangements may be less wellpositioned to do so. ACOs in one-sided
risk arrangements, such as those in the
Shared Savings Program Track 1, do not
bear the risk of owing losses to CMS. In
contrast, ACOs in two-sided risk
arrangements, such as the Next
Generation ACO model, are held to as
much as 80 percent to 100 percent of
first dollar losses. Thus, we explained
our belief that pursuing a blanket
exclusion from EPMs of assigned
beneficiaries from all ACOs would
inappropriately disadvantage EPM
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participants that carry significant
financial risk under EPMs.
This proposed ACO overlap policy
would grant ACOs in models and tracks
with the highest levels of downside risk
for financial losses—the Next
Generation ACO model and tracks of the
Comprehensive ESRD Care model with
downside risk for financial losses—
paramount financial opportunity in
exchange for accepting total cost of care
responsibility for their beneficiaries.
EPM participants may still realize
opportunities to save by partnering with
ACOs, but outside of the EPM
arrangement. Specifically, we refer to
section III.I. of the proposed rule which
describes opportunities for gainsharing
allowed under these models.
As we stated in the proposed rule,
this policy tests the effects of such an
ACO-assigned beneficiary exclusion
policy within a broader test of the
effectiveness of EPMs. We can learn its
impact on EPM participants and ACOs
that have beneficiaries excluded from
EPMs, as well as ACOs that do not have
beneficiaries excluded from EPMs. This
will improve our understanding about
the appropriate entity to hold
accountable for the costs within the
episode. For this reason we
recommended this test be limited to the
AMI, CABG, and SHFFT, and CJR
models, and ACO models being
conducted under CMS’ Innovation
Center, and did not propose to
implement the policy more broadly to
other ACOs, such as those in the Shared
Savings Program. In proposing the
exclusion of beneficiaries in only a
limited number of ACO initiatives we
attempted to balance the desire to build
a new payment reform initiative while
mitigating the potential challenges to
existing shared savings models and
programs. We sought comment on this
proposal as well as input on extending
the proposal to CJR and other ACOs
accepting two-sided risk, such as those
ACOs in the Shared Savings Program
Track 3.
We have investigated CMS data
related to the services under
consideration in the AMI, CABG and
SHFFT models. A small fraction of total
beneficiaries assigned to ACOs
qualifying for this exclusion in fact have
relevant anchor hospitalizations that
would initiate an EPM in a given
calendar year. For instance, from 2013
through 2015, about 2.4 percent of
beneficiaries aligned to Pioneer ACO
model participants had an anchor
hospitalization that would have
initiated an AMI, CABG or SHFFT
model.
We considered several additional
options to account for EPM–ACO
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335
beneficiary overlap prior to proposing
the strategy outlined previously. We
considered whether to split the risk,
including at an equal sharing rate, at the
time of financial reconciliation between
EPM participants and ACOs when
episodes included overlapping
beneficiaries. This has the advantage of
mitigating the supposed ‘‘carve out’’ of
ACO expenditures, but requires CMS to
arbitrarily declare a level of risk sharing.
We are also concerned about the
operational feasibility of such
calculations, given that reconciliation
would have to occur in tandem,
resulting in long delays in payments or
recoupments for both EPM participants
and ACOs. We also considered whether
to attribute to ACOs the more favorable
of either the episode-specific target
price or the actual expenditures
incurred by the beneficiary during the
episode time period. However, this
policy would result in significant losses
to the Medicare Trust Fund, as the
double payment of savings/losses would
be a certainty.
We established the proposal to
exclude from the EPMs beneficiaries
who are assigned to an ACO in the Next
Generation ACO Model or
Comprehensive ESRD Care Initiative at
§ 512.230(f). We established the
proposal to attribute savings achieved
during an EPM episode to the EPM
participant, and include EPM
reconciliation payments for other ACOassigned beneficiaries as ACO
expenditures at § 512.305 and § 512.307.
We sought comment on our proposals to
account for beneficiary overlap with
shared savings models and programs.
The following is a summary of the
comments received and our responses.
Comment: We received numerous
comments in response to our proposed
policies for handling overlap between
ACOs and EPMs.
A number of commenters expressed
concern that ACOs should not be
competing with bundled payment
models and that CMS needs a
sustainable overlap policy that would
allow both models to thrive. Related to
this, many commenters expressed
concern over the difficulty of
understanding the different model
policies, and the need for a rigorous
analysis of how different programs
interact and impact participating
providers as well as patients. A few
commenters believed more information
on the effect of overlapping value based
models was necessary before moving
forward with additional models.
A commenter wrote to support the
current overlap policy and
recommended that EPM participants be
allowed to execute arrangements to
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share or shift risk to an ACO but
recommended against automatically
excluding certain categories of
beneficiaries assigned to ACOs. Only if
the ACO and EPM fail to come to
agreement on a distribution arrangement
should the proposed rule be
implemented. Another commenter
wrote that giving priority to ACOs over
EPMs could subordinate ‘‘provider led’’
models and sought further clarification
on how this policy might function with
future physician led EPMs. A
commenter suggested that in the
absence of an agreement, ACOs should
be allowed to accept EPM assignment
for ACO beneficiaries where an ACO
participant served as the ‘‘attending
physician’’ during the anchor stay.
Under this policy a beneficiary would
only be excluded from an EPM if they
are actively being managed by an
attending physician associated with the
ACO and the provider managed episode
would take precedence over the EPM
participant which was an institutional
provider.
On the other hand, a significant
number of commenters wrote to support
the proposed exclusion of beneficiaries
assigned to ACOs in either the Next
Generation ACO or Comprehensive
ESRD Care models. A substantial
number of these commenters supported
extending the exclusion to beneficiaries
assigned to Shared Savings Program
Track 3 ACOs. A number of these
commenters recommended extending
the exclusion even further to include
more ACO related exclusions from
EPMs and expressed concern that the
current approach undermines ACOs.
These commenters believed it was
important to give preference to
population based models versus those
focused on more limited episodes.
While bundling may give short term
savings, it was noted, they do not focus
on the total cost of care and have the
potential to increase total utilization. In
support of this perspective, several
commenters recommended the
exclusion be extended to include
beneficiaries assigned to any ACO
unless a collaboration agreement is in
place. If there is no collaborative
agreement in place between an EPM
participant hospital and an ACO that it
is not part of, then beneficiaries
assigned to that ACO should be
excluded from the EPM episodes. A
commenter suggested that CMS should
allow for ‘‘more flexible, market-based
options where parties can mutually
agree’’ to share the risk of an episode
rather than the proposed exclusion. A
commenter recommended that CMS
allow for prospective alignment for all
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types of ACOs regardless of the risk
sharing arrangement with CMS. The
commenter disagreed with our
statement that ACOs that didn’t share
downside risk might be less able to
manage risk and expressed the view that
EPMs had an even lower risk threshold.
Extending the option for prospective
alignment to all ACOs with downside
risk, they noted, could incentivize ACOs
to assume more financial risk. Another
suggested excluding beneficiaries based
on preliminary prospective assignment
with retrospective reconciliation if the
EPM participant is not a member of the
ACO or does not have a collaboration
agreement with the ACO. Other
commenters suggested that ACO
participant hospitals be totally excluded
from EPMs.
Response: We acknowledge the range
of perspectives expressed by
commenters and appreciate the many
specific suggestions for handling these
overlaps. We also acknowledge the
operational challenge both ACOs and
EPMs face and the financial impacts on
both when there are overlaps. We
believe the level and range of responses
reflect the challenge in balancing
multiple perspectives as was reflected
in the discussion in the proposed rule.
The predominance of commenters
supported our proposal to exclude from
EPMs those beneficiaries assigned to
Next Generation ACOs and the
downside risk track of Comprehensive
ESRD Care models, and a significant
number of commenters also supported
extending this exclusion to Shared
Savings Program Track 3 ACOs which
also have beneficiaries prospectively
assigned and share downside risk. We
believe it is appropriate to test the
impact of granting full-risk ACO models
the opportunity to ‘‘hold the risk’’
associated with the care throughout the
performance year, rather than defaulting
to the EPM participant; ACOs have
stated that they are the appropriate
accountable entity for beneficiaries for
whom they remain financially
responsible, even in the event an
assigned beneficiary experiences an
episode at an EPM hospital. CMS
believes there is significant value in
testing an alternative approach which
would also not significantly deplete the
total number of EPMS. We are less
convinced that all beneficiaries assigned
to ACOs, regardless of model or track,
should be excluded from EPMs and,
among other issues, believe that would
significantly deplete the volume of EPM
episodes. We also remain concerned
that excluding all ACO beneficiaries
could ultimately exclude patients from
EPMs that end up not being assigned to
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any model. We recognize the broader,
more comprehensive perspective of
ACOs and encourage the development
of collaborative partnership agreements
with EPMs. We do not, however, believe
it is appropriate for CMS to mandate
such agreements or the detailed terms of
such agreements, or believe it is
practical to tie exclusions to the
presence of hospital and ACO specific
agreements that may be in place for
specific episodes.
In sum, we are convinced that there
is merit in extending our proposed
beneficiary exclusion from EPMs to
include those beneficiaries assigned to
Shared Savings Program Track 3 ACOs.
We also note that CMS has recently
announced that it will re-open
applications for new participants in the
Next Generation Accountable Care
Organization (ACO) model for the 2018
performance year. Therefore we are
finalizing our proposal with one
modification: The exclusion of ACO
beneficiaries assigned to Shared Savings
Program Track 3 ACOs from the EPMs.
Comment: A few commenters stated
that, while bundled payments may
provide savings to Medicare in the short
term, the EPMs do not sufficiently
address volume or total cost of care.
Commenters suggested that because
ACOs focus on total cost of care and
population health, while episode and
bundled payments focus on specific
disease states, issues such as the
utilization or volume of services and
selection or type of services such as
preventative services could be better
managed by ACOs. These commenters
believed that the EPMs actually threaten
the long term success of ACOs and that
further, the EPMs could potentially
increase overall Medicare costs.
Response: We appreciate these
commenters’ concerns. The goals of the
EPMs are to test methods to improve the
quality of care furnished to beneficiaries
and reduce spending during episodes in
specific geographic areas. While we
understand that overlaps between ACOs
and EPMs exist, we believe the policies
for handling overlap, which we are
finalizing with slight modification in
this final rule (that is Shared Savings
Program Track 3 ACOs will be excluded
from the EPMs), adequately and
appropriately address and account for
overlap with other Innovation Center
Models.
With respect to commenters’
assertions that ACOs can better manage
patient care and/or lower costs of health
care, we believe we must also continue
to assess the extent to which ACOs
contribute to lowering costs and
improving care, as research around this
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issue continues to evolve.88 89 We will
continue rigorous, independent
evaluations that examine each particular
payment model and how overlapping
models affect Medicare beneficiaries so
as to determine the need to require
participation in these episode models to
enhance learning around the best
approaches to improving quality while
containing costs. We will also continue
to monitor the impact of testing
alternative payment approaches and
consider volume effects as part of that
process.
We refer readers to section III.G. of
this final rule for discussion of
monitoring and beneficiary protections
under this model which we believe will
address the commenters’ concerns about
potential increases to overall Medicare
spending. We also refer readers to
section IV of this final rule where we
discuss the evaluation of the EPMs,
including consideration of the impact of
the EPMs on the total number of
episodes, total cost of care and potential
beneficiary risk selection.
Comment: Many commenters
expressed concern about the challenge
of having accurate and timely
information on patient attribution with
multiple models. They believed it was
unrealistic to expect hospital staff and
others to be able to accurately identify
patients in excluded ACO models and
questioned how EPM participants and
their partners would be able verify a
patient’s status. This was a particular
concern with patients who may travel
out of their home area to receive care,
either to referral centers or due to living
out of the area for part of the year.
Response: We appreciate the
operational challenges that EPM
participants and their collaborating
partners face in an environment where
there are many, potentially overlapping,
models in place. CMS is doing what we
can to reduce operational barriers where
we can practically and effectively do so.
To this end we are in the process of
developing a web portal where EPM
participants can, at the point of care,
look up and identify beneficiaries
prospectively assigned to ACOs who
will be excluded from EPMs. This
system is currently in testing, and is
expected to be operational when EPMs
are implemented in July 2017. CMS will
provide more specific information as it
is rolled out.
Comment: A commenter stated that
they are concerned with our inability to
88 Song Z., Fisher E.S. The ACO experiment in
infancy—looking back and looking forward. JAMA.
2016;316(7):705–706.
89 Schulman K.A., Richman B.D. Reassessing
ACOs and health care reform. JAMA.
2016;316(7):707–708.
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fully model the estimated impact of the
EPMs on beneficiaries who are also
aligned or attributed to a Medicare
Shared Savings Program participant or
an ACO model initiated by the CMS
Innovation Center. The commenter
stated that CMS should delay
implementation of EPMs until this issue
can be evaluated. Further, they believe
CMS should release the data necessary
to study this issue.
Response: We understand the
commenter’s desire to understand the
full effect of EPMs in relation to other
CMS initiatives. As discussed in the
proposed rule (81 FR 50989 through
51002), the high uncertainty associated
with concurrent EPM and ACO and/or
Shared Savings Program attribution is a
limitation in our modeling of the
impacts of the interaction between these
models and programs. We do not
believe that delaying EPMs would
enable prospective modeling of the
potential interaction. We refer readers to
section III.D.6.c. of this final rule for a
discussion of our approach to
accounting for beneficiaries who are
simultaneously receiving care under the
EPMs and other alternative payment
models such as BPCI or CJR. We refer
readers to section III.G. for a discussion
of the Monitoring and Beneficiary
Protections which will be implemented
in the EPMs. We will monitor the
impact of the EPMs on other CMS
initiatives such as ACOs to ensure
quality of care in these programs is not
being adversely impacted by the EPMs.
As discussed in section III.G. of this
final rule, we plan to publish data as
part of the EPM evaluations to promote
transparency and an understanding of
the EPM effects, including impacts on
other models and programs such as
ACOs.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal, with
modification, to exclude from eligibility
for EPMs not only beneficiaries assigned
to Next Generation ACOs and
Comprehensive ESRD Care Initiative
models but also beneficiaries
prospectively assigned to Shared
Savings Program Track 3 ACOs.
However, for the reasons previously
specified in this section, we do not
believe it is appropriate to change the
proposed policy, as implemented in the
CJR model, for handling overlaps
between EPMs and other ACOs (ACOs
whose beneficiaries are not excluded
from the EPMs) to attribute savings
achieved during an EPM episode to the
EPM participant, and to include EPM
reconciliation payments for ACOassigned beneficiaries as ACO
expenditures. We also note that we will
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337
implement an on-line system for
verification of attribution to support
EPM participants in their ability to
identify such exclusions.
d. Payment Reconciliation of Overlap
With Non-ACO CMS Models and
Programs
In general, Per-Beneficiary Per-Month
(PBPM) payments are for new or
enhanced provider or supplier services
that share the goal of improving quality
of care overall and reducing Medicare
expenditures for services that could be
avoided through improved care
coordination. Some of these PBPM
payments may be made for services
furnished to a beneficiary that is in
another Innovation Center model at the
same time that the beneficiary is in an
EPM, but the clinical relationship
between the services paid for by the
PBPM payments and the EPM will vary.
For purposes of the proposed rule, we
considered clinically related services
paid for by PBPM payments that are for
the purpose of care coordination and
care management of any beneficiary
diagnosis or hospital admission not
excluded from an EPM’s episode
definition, as discussed in section III.C.
of the proposed rule. As with CJR, we
proposed to include PBPM payments for
new and enhanced services in EPM
reconciliation calculations if we
determine, on a model by model basis,
that the services paid for by the PBPM
payments are (1) not excluded from an
EPM model’s episode definition; (2)
rendered during the episode; and (3)
paid for from the Medicare Part A or
Part B Trust Funds. That is, we would
include the clinically related services
paid for by a PBPM payment if the
services would not otherwise be
excluded based on the principal
diagnosis code on the claim, as
discussed in section III.C. of the
proposed rule. The PBPM payments for
clinically related services would not be
excluded from the EPMs’ historical
episodes used to calculate target prices
when the PBPM payments are made
from the Part A or Part B Trust Fund,
and they would not be excluded from
calculation of actual episode
expenditures during an EPM’s
performance period. PBPM model
payments that we determine are
clinically unrelated would be excluded,
regardless of the funding mechanism or
diagnosis codes on claims for those
payments. We note that in the case of
PBPM model payments, principal
diagnosis codes on a Part B claim
(which are used to identify exclusions
from EPMs, as discussed in section III.C.
of the proposed rule) would not be the
only mechanism for exclusion of a
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service from an EPM. All such PBPM
model payments that we determine are
clinically unrelated would be excluded
as discussed in the proposed rule.
Finally, all services paid for by PBPM
payments funded through the
Innovation Center’s appropriation under
section 1115A of the Act would be
excluded from the EPMs, without a
specific determination of their clinical
relationship to an EPM. We believe
including such PBPM payments funded
under the Innovation Center’s
appropriation and not included on
claims would be operationally
burdensome and could significantly
delay any reconciliation payments and
repayments for the EPMs. In addition,
because these services are not paid for
from the Medicare Parts A or B Trust
Funds, we are not confident that they
would be covered by Medicare under
existing law. Therefore, we believe the
services paid for by these PBPM
payments are most appropriately
excluded from the EPMs. Our proposal
for the treatment of services paid for by
PBPM payments in the EPMs would
pertain to all existing models with
PBPM payments, as well as future
models and programs that incorporate
PBPM payments. As we stated in the
proposed rule, we believe that this is
fully consistent with our goal of
including all related Part A and Part B
services in the EPMs, as discussed in
section III.C. of the proposed rule.
As with CJR, we propose to exclude
the PBPM payments for the OCM and
Medicare Care Choices Model (MCCM)
from the AMI, CABG, and SHFFT
episode definitions. These PBPM
payments (listed on the CMS Web page
at https://innovation.cms.gov/Files/x/
cjr-pbpmexclusions.xlsx) would be
excluded from EPM reconciliation
calculations. While the OCM will pay
for new or enhanced services through
PBPM payments funded by the
Medicare Part B Trust Fund, we do not
believe these services are clinically
related to the EPMs. The OCM
incorporates episode-based payment
initiated by chemotherapy treatment, a
service generally reported with ICD–9–
CM and ICD–10–CM codes that will be
excluded from the AMI, CABG, and
SHFFT episode definition in section
III.C. of the proposed rule. We believe
the care coordination and management
services paid for by OCM PBPM
payments would be focused on
chemotherapy services and their
complications, so the services would be
clinically unrelated to AMI, CABG and
SHFFT model episodes. Therefore, we
proposed that services paid for by PBPM
payments under the OCM be excluded
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from the AMI, CABG, and SHFFT
models. Similarly, we proposed to
exclude services paid for by PBPM
payments under the MCCM. The MCCM
focuses on providing care coordination
and palliative care services for
beneficiaries with certain conditions
certified as terminally ill with a life
expectancy of 6 months or less that have
not elected the Medicare hospice
benefit. The MCCM seeks to test
whether providing palliative care
services, without beneficiaries having to
forgo curative care, incentivizes
beneficiaries to elect hospice sooner.
This is aimed at addressing the large
percentage of hospice beneficiaries who
elect the hospice benefit too late to fully
benefit from the range of services that
hospice has to offer at end of life. Since
the purpose of the MCCM is to test
whether providing palliative care
services to beneficiaries who are
otherwise eligible to elect the Medicare
hospice benefit without requiring the
beneficiary to forgo curative care results
in beneficiaries electing the hospice
benefit sooner, we will not include such
payments in the AMI, CABG and SHFFT
models’ episode spending calculations.
In addition, unlike the regular hospice
benefits, which are furnished to
beneficiaries in lieu of curative care and
which therefore can be coordinated
during an AMI, CABG or SHFFT model
episode, the services furnished under
the MCCM will be in addition to
curative services. We note that we are
including such curative services in the
EPM episode, as they are consistent
with our episode definition described in
III.C. of the proposed rule, but not the
services represented by the PBPM
payment, which are provided in
addition to curative services.
Beneficiaries electing the hospice
benefit could have lower episode
spending because they have forgone
curative care. However beneficiaries
included in the MCCM may have higher
episode spending because they are
receiving both curative care and the
services represented by the PBPM. We
do not want to create incentives that
deter providers from enrolling
beneficiaries in the MCCM.
We acknowledge there may be new
models that could incorporate a PBPM
payment for new or enhanced services.
We plan to make our determination
about whether services paid by a new
model PBPM payment that is funded
under the Medicare Trust Funds are
clinically related to EPM episodes
through the same sub regulatory
approach that we have proposed to use
to update the episode definitions
(excluded MS–DRGs and ICD–CM
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diagnosis codes). We would assess each
model’s PBPM payment to determine if
it would be primarily used for care
coordination or care management
services for excluded clinical conditions
in the EPMs based on the standards we
proposed to use to update EPM episode
definitions that are discussed in section
III.C. of the proposed rule.
If we determine that a PBPM payment
would primarily be used to pay for
services to manage an excluded clinical
condition, we would exclude the PBPM
payment from the EPM on the basis that
it pays for unrelated services. If we
determine that the PBPM payment
could primarily be used for services to
manage an included clinical condition,
we would include the PBPM payment in
the EPM if the diagnosis code on the
claim for the PBPM payment was not
excluded from the episode, following
our usual process for determining
excluded claims for Part B services in
accordance with the EPM episode
definitions discussed in section III.C. of
the proposed rule. To allow for public
input on our planned application of
these standards, we will post our
proposed determination about whether
the PBPM payment will be included in
the episode on the CMS Web site. After
our consideration of any public input
received, we will make a final
determination on the inclusion of the
PBPM payment and will then post the
final updated overlap list, reflecting any
changes made to PBPM payment
inclusions, to the CMS Web site.
With the publication of this final rule,
we are initiating the sub-regulatory
update process described in the
preceding paragraphs to review
potential additions to the PBPM
exclusion lists for the EPMs. We did not
consider the 2017 PBPM changes in the
EPM proposed rule, because we limited
our PBPM proposals to those models
that were active when the proposed rule
was published in the Federal Register
on August 2, 2016. Since the proposed
rule was published, other PBPM models
have become active, such as the Million
Hearts® Cardiovascular Disease (CVD)
Risk Reduction Model and the
Comprehensive Primary Care Plus
(CPC+) model. These would be
examples of PBPMs we will review for
calendar year 2017 under the subregulatory update process we are
establishing in this final rule. The
potential modifications to the PBPM
exclusion list for each EPM are posted
on the CMS Web site at https://
innovation.cms.gov/initiatives/epm. We
request that public input on the
potential modifications be sent to epm@
cms.hhs.gov through 11:59 p.m. Eastern
Standard Time on January 27, 2017.
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After receiving and reviewing public
input on potential revised exclusions,
we will post the final revised PBPM
exclusion lists by February 24, 2017,
and will also specify via web post when
the revisions will take effect and to
which episodes they will apply.
The payment reconciliation process is
described in section III.D.5. of the
proposed rule. As with CJR, it is
important that other models and
programs in which providers are
accountable for the total cost of care be
able to account for the full Medicare
payment, including EPM-related
reconciliation payments and
repayments as described in section
III.D.5. of the proposed rule, for
beneficiaries who are also in EPM
episodes.
We established the proposal for
accounting for non-ACO services and
payments in the EPM reconciliation
process at § 512.210. We sought
comment on this proposal.
The following is a summary of the
comments received and our responses.
We did not receive any specific
comments relating to how we have
proposed to handle PBPM payments
from non-ACO models in the EPM
reconciliation process
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal, without
modification, to include PBPM
payments for new and enhanced
services in EPM reconciliation
calculations if we determine, on a
model by model basis, that the services
paid for by the PBPM payments are (1)
not excluded from an EPM model’s
episode definition; (2) rendered during
the episode; and (3) paid for from the
Medicare Part A or Part B Trust Funds.
We will post our list of PBPM payments
which we propose to exclude from EPM
episode spending calculations on the
CMS Web site at https://
innovation.cms.gov/initiatives/epm
model exclusion and request that public
input on the potential PBPM exclusions
be sent to epm@cms.hhs.gov through
11:59 p.m. Eastern Standard Time on
January 27th, 2017. After receiving and
reviewing public input on potential
PBPM exclusions, we will post the final
PBPM exclusions by February 24th,
2017 including providing information
about when the PBPM exclusions will
take effect.
7. Limits or Adjustments to EPM
Participants’ Financial Responsibility
a. Overview
We recognized that hospitals that
would be designated for participation in
the proposed EPMs currently vary with
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respect to their readiness to function
under an EPM with regard to their
organizational and systems capacity and
structure, as well as their beneficiary
population served. That is, some EPM
participants may be more quickly able
to demonstrate high quality
performance and savings than others,
even though we proposed that the EPMepisode benchmark prices be based
predominantly on the participant’s own
historical EPM-episode utilization in the
early years of the EPMs. We also noted
that providers may be incentivized to
excessively reduce or shift utilization
outside of an EPM’s episode by the
proposed payment policies of the EPMs.
In order to mitigate any excessive
repayment responsibility for EPM
participants or reduction or shifting of
care outside an EPM episode, especially
beginning in performance year 2 of the
EPMs when we proposed to begin to
phase in responsibility for repaying
Medicare for excess EPM-episode
payments, we proposed several specific
policies as follows (81 FR 50872).
b. Limit on Actual EPM-Episode
Payment Contribution to Repayment
Amounts and Reconciliation Payments
(1) Limit on Actual EPM-Episode
Payment Contribution to Repayment
Amounts
As discussed in section III.D.3.d. of
the proposed rule regarding our
proposed pricing adjustment for high
payment EPM episodes (81 FR 50846),
EPM participants would not bear
financial responsibility for actual EPMepisode payments greater than a ceiling
set at 2 standard deviations above the
mean regional EPM-episode payment.
Nevertheless, EPM participants would
begin to bear repayment responsibility
beginning performance year 2 (DR) for
those EPM episodes where actual EPMepisode payments are greater than the
EPM quality-adjusted target prices up to
the level of the regional EPM-episode
ceiling. When aggregated across all EPM
episodes in a model, the total money
owed to Medicare by an EPM
participant for actual EPM-episode
payments above the applicable EPM
quality-adjusted target price could be
substantial if a participant’s EPM
episodes generally had high payments.
As an extreme example, if a participants
had all of its EPM episodes paid at 2
standard deviations above the mean
regional EPM-episode payment, the
EPM participant would need to repay
Medicare a large amount of money,
especially if the number of EPM
episodes was large.
To limit a participant’s overall
repayment responsibility for actual
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339
EPM-episode payments under the EPMs,
(hereafter called a ‘‘stop-loss limit’’), we
proposed to establish the same stop-loss
limits that were adopted for the CJR
model (80 FR 73401); except, that they
would apply beginning in the second
rather than first quarter of performance
year 2 (81 FR 50872 through 50873).
Specifically, we proposed a 5 percent
stop-loss limit in performance year 2
(DR), a 10 percent stop-loss limit in
performance year 3, and a 20 percent
stop-loss limit for performance years 4
and 5 for each EPM. That is, beginning
in the second quarter of performance
year 2, the EPM participant would owe
Medicare under each proposed EPM no
more than 5 percent of the sum of the
EPM quality-adjusted target prices for
all of the EPM participant’s EPM
episodes during performance year 2
(DR). This responsibility would
gradually phase up to 20 percent by
performance year 4.
For performance year 2, the
comparison against the stop loss limit
would only apply for NPRA attributable
to episodes ending in performance year
2 (DR). As described in section III.D.5.
of the proposed rule, when calculating
the NPRA for performance year 2, we
would ensure the NPRA attributable to
episodes ending during performance
year 2 (NDR) was not less than zero and
that NPRA attributable to episodes
ending during performance year 2 (DR)
did not exceed the stop-loss limit of 5
percent of the sum of quality-adjusted
target prices for episodes that ended
during performance year 2 (DR).
Similarly, when conducting the
subsequent reconciliation calculation to
reassess actual EPM-episode payments
for performance year 2 (which would
occur concurrently with the
reconciliation for performance year 3),
we would combine the performance
year 2 (NDR) NPRA and the result of the
subsequent reconciliation calculation
for performance year 2 (NDR) to ensure
the result was not less than zero. Also,
we would combine the performance
year 2 (DR) NPRA and the result of the
subsequent reconciliation calculation
for performance year 2 (DR) to ensure
the stop-loss limit was not exceeded.
For performance years 3 through 5, it
would not be necessary to split the
performance years to ensure that the
stop-loss limit was not exceeded as a
single stop-loss limit would apply in
each year. For example, as described in
section III.D.5. of the proposed rule,
when calculating the NPRA for
performance year 3,, we would ensure
the NPRA did not exceed the stop-loss
limit of 10 percent of the sum of qualityadjusted target prices. Similarly when
conducting the subsequent
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reconciliation calculation to reassess
actual EPM-episode payments for
performance year 3 (which would occur
concurrently with the reconciliation for
performance year 4), we would combine
the performance year 3 NPRA and the
result of the subsequent reconciliation
calculation for performance year 3 to
ensure the stop-loss limit was not
exceeded.
Note that, as described in sections
III.D.5.b. and III.D.6.b.(2) of the
proposed rule (81 FR 50865 through
50867 and 50869 through 50871), the
result of the post-episode spending
calculation and ACO overlap
calculation that would occur
concurrently with the subsequent
reconciliation calculation for a given
performance year would not be subject
to the stop-loss limit. The result of these
calculations would be added to the
NPRA and subsequent reconciliation
calculation to create the repayment
amount or reconciliation payment. We
believed that these limits would both
offer EPM participants reasonable
protections while maintaining
incentives to improve care quality and
efficiency. We noted that in addition to
the CJR model, we apply a similar
ultimate 20 percent stop-loss limit to
payments under the BPCI initiative.
The proposal to limit participants’
overall payment responsibility under
the models was included in
§ 512.305(c)(2)(iii)(A). We sought
comment on our proposal to limit
hospitals’ overall payment
responsibility.
The following is a summary of the
comments received and our responses.
Comment: Commenters offered a
variety of perspectives on the proposal
to limit hospitals’ payment
responsibility under the models. A
number of commenters requested that
CMS include additional protection to
participants by delaying the phase-in
period under which the limits would
increase, or reducing the limits acrossthe-board or for certain hospital types,
for example, participants treating a large
percentage of complex cases or
vulnerable populations. One commenter
recommended that the limits remain at
a statistically equivalent level of case
complexity provided that the
participants are improving with respect
to their performance measures.
Another commenter recommended
that in lieu of a blanket stop loss
protection, CMS should instead make
outlier payments for high-cost cases as
they believed it would provide a better
safety net to the small percentage of
extremely high-cost episodes. One
commenter recommended that hospitals
with fewer than 20 episodes not be
required to participate and if they did,
their stop-loss threshold should be
increased. Another commenter
suggested that CMS include additional
stop-loss protections for participants
that provide services to complex
patients and patients with comorbidities. The commenter also
seemed to suggest that the additional
stop-loss protections be offered where
beneficiaries receive hospice services
during an episode.
Response: We appreciate the
comments we received either in support
of our proposal or to modify the
proposal. While we are not persuaded
by comments to reduce the stop-loss
limits or modify our proposed
mechanism for offering participant
hospitals protections against significant
financial loss, we are delaying the
phase-in period under which the stoploss limits would increase to conform
with our policy to delay when EPM
participants would be required to accept
downside risk under the EPMs as
described in section III.D.2.c. of this
final. Thus, under our final policy,
except for those EPM participants with
additional stop-loss protections as
discussed in section III.D.7.c.(1) of this
final rule, the limits on a EPM
participant’s repayment responsibility
as displayed in Table 19 are—
• For performance year 2, 5 percent
for EPM participants that voluntarily
elect downside risk for that year; and
• For performance years 3, 4 and 5, 5
percent, 10 percent, and 20 percent
respectively.
TABLE 19—PROPOSED AND FINAL STOP-LOSS LIMITS BY PY
PY1
PY3
(percent)
PY2
PY4
(percent)
PY5
(percent)
Proposed Stop-Loss Limits
n/a as no downside risk in PY1 ......................
n/a during non–downside risk period and 5%
during downside risk period.
10
20
20
Final Stop–Loss Limits
Downside Risk for All Participants– DR effective for episodes ending on or after 1/1/2019 (anchor discharges occurring on or after 10/
4/2018)
n/a as no downside risk in PY1 and PY2 without election of voluntary downside risk for PY2
5
10
20
Voluntary Downside Risk—DR effective for episodes ending on or after 1/1/2018 (anchor discharges occurring on or after 10/4/2017)
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n/a as no downside risk in PY1 ......................
We believe that this policy in
conjunction with our policies to delay
when hospitals must assume downside
risk and cap high cost payments as well
as our plans to implement further risk
adjustment measures offer sufficient
protections to hospitals participating in
the model while maintaining incentives
that will encourage improvements in
care quality and efficiency.
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5% ..................................................................
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal, with
modification, to establish limits on
participants’ overall payment
responsibility. Our final policy on
participants’ overall payment
responsibility is included in
§ 512.305(c)(2)(iii)(A).
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5
10
20
(2) Limitation on Reconciliation
Payments
We believe limits on reconciliation
payments made under the proposed
EPMs would also be appropriate for
several reasons. Under our proposal, in
performance year 1, EPM participants
would have no repayment responsibility
for excess EPM episode spending above
the EPM quality-adjusted target price,
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and CMS would bear full financial
responsibility for Medicare actual EPMepisode payments for an EPM episode
that exceeds the EPM quality-adjusted
target price; however, we believe our
responsibility should have judicious
limits. In addition, our proposed rule
noted that beginning in performance
year 1, EPM participants would be
eligible for reconciliation payments due
to the NPRA if actual EPM-episode
payments are less than the qualityadjusted target prices. This proposal for
reconciliation payments due to the
NPRA was intended to provide a
financial incentive to EPM participants
from the beginning of the model to
manage and coordinate care throughout
the EPM episode with a focus on
ensuring that EPM beneficiaries receive
the lowest intensity, medically
appropriate care throughout the EPM
episode that results in high quality
outcomes. However, for purposes of
responsible stewardship of CMS
resources and concerns about
potentially excessive reductions in
utilization under the proposed EPMs
that could lead to beneficiary harm, we
also believed it would be reasonable and
hence proposed to cap an EPM
participant’s reconciliation payments
resulting from actual EPM-episode
payments for a given performance year
as a percentage of EPM-episode
payments.
In determining what would constitute
an appropriate reconciliation payment
limit due to actual episode spending
(hereafter called a ‘‘stop-gain limit’’), we
believe it should provide significant
opportunity for EPM participants to
receive reconciliation payments for
greater episode efficiency that includes
achievement of quality care and actual
EPM-episode payment reductions below
the quality-adjusted target price, while
avoiding the creation of significant
incentives to sharply reduce utilization
that could be harmful to EPM
beneficiaries. We also believe that
establishing parallel stop-gain and stoploss limits is important to provide
proportionately similar protections to
CMS and EPM participants for their
financial responsibilities under the
EPMs as well as to protect the health of
beneficiaries.
Accordingly, we proposed to establish
symmetrical stop-gain limits (81 FR
50873). Specifically, we proposed a 5
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percent stop-gain limit in performance
years 1 and 2, a 10 percent stop-gain
limit in performance year 3, and a 20
percent stop-gain limit for performance
years 4 and 5 for each EPM. That is, in
performance year 1 as we phased-in the
stop-gain limits, the reconciliation
payment that the EPM participant
would be eligible to receive under each
proposed EPM would be no more than
5 percent of the sum of the EPM qualityadjusted target prices for all of the EPM
participant’s EPM episodes during the
performance year. This limit would
gradually phase up to 20 percent by
performance year 4. As was also
indicated in the CJR Final Rule, we
wanted to ensure that any savings
achieved by EPM participants in the
early years of the EPM were not due to
random variation, and that changes
undertaken to improve efficiency
included achievement in care quality
and not sharp decreases in utilization
that could be harmful to beneficiaries
(80 FR 73402).
We clarified in our proposed rule that,
as with the stop-loss limits, we
proposed to determine whether an EPM
participant had met the stop-gain limit
by assessing the NPRA and subsequent
reconciliation for a given performance
year, if any. We noted that this approach
aligned with our goal to place limits on
the amount a participant may earn as a
reconciliation payment due to reduced
actual EPM-episode payments.
We also noted that we planned to
monitor beneficiary access and
utilization of services and the potential
contribution of the stop-gain limit to
any inappropriate reduction in EPMepisode services. We refer to section
III.G. of the proposed rule for our
discussion on monitoring and
addressing participants’ performance
under the proposed EPMs.
The proposal to establish a cap on an
EPM participant’s reconciliation
payment due to actual EPM-episode
payments for a given performance year
as a percentage of EPM-episode
payment was included in
§ 512.305(c)(2)(iii)(B). We sought
comment on this proposed cap.
The following is a summary of the
comments received and our responses.
Comment: Commenters addressing
how reconciliation payments would be
capped either opposed the caps or
recommended that CMS raise the dollar
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341
amount at which payments would be
capped. These commenters stated that
doing so would make additional
resources needed for infrastructure
development available or allow greater
rewards for savings achieved.
Response: We appreciate the
comments we received on our proposal,
but disagree with recommendations to
eliminate or raise the dollar amount at
which payments would be capped.
While the proposed models intend to
establish financial incentives to better
manage and coordinate care throughout
the EPM episode in a way that improves
both health care quality and efficiency,
we believe it is also necessary to
establish limits to discourage the
chances for excessive reductions in
utilization under the proposed EPMs
that could lead to beneficiary harm. We
believe our proposed cap on
reconciliation payments achieves an
appropriate balance that both provides
incentives for participants to improve
care quality and efficiency without also
encouraging excessive and
inappropriate reductions in utilization.
Also, as previously stated, we believe
it is important that stop-gain and stoploss limits under the models be
established in a way that provides
proportionately similar protections to
CMS and EPM participants for their
financial responsibilities under the
EPMs as well as to protect the health of
beneficiaries. As such, we proposed to
establish stop-gain limits under the
models that were symmetrical with our
stop-loss limits.
As we previously noted in section
III.D.7.b.(1), in delaying when EPM
participants would be required to accept
downside risk under the EPMs as
described in section III.D.2.c. of this
final rule, our final policy includes
conforming adjustments to the limits on
EPM participants’ overall payment
responsibility. These conforming
adjustments also necessitate
adjustments to the stop-gains limits
under the model for consistency with
our policy for symmetrical stop-loss and
stop-gain limits. Accordingly, the final
stop-gain limits are 5 percent in
performance years 1, 2, and 3; 10
percent in performance year 4; and 20
percent in performance year 5 for each
EPM (see Table 20).
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TABLE 20—PROPOSCED AND FINAL STOP-GAIN LIMITS AND FINAL STOP-LOSS LIMITS BY PY
PY1
PY3
(percent)
PY2
PY4
(percent)
PY5
(percent)
Proposed Stop-Gain Limits
5% ...................................................................
5% ..................................................................
10
20
20
5
10
20
5
10
20
5
10
20
Final Stop-Gain Limits
5% ...................................................................
5% ..................................................................
Final Stop-Loss Limits: Downside Risk for All Participants *
n/a as no downside risk ..................................
n/a as no downside risk .................................
Final Stop-Loss Limits: Voluntary Downside Risk in PY2 *
n/a as no downside risk ..................................
5% ..................................................................
* Limits apply to hospitals other than those eligible for the separate stop-loss limits discussed in section III.D.7.c.(1) of this final rule.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal, with
modification, to establish a cap on an
EPM participant’s reconciliation
payment due to actual EPM-episode
payments for a given performance year
as a percentage of EPM-episode
payment. Our final policy on the
proposed cap, which includes
conforming adjustments so that the
stop-loss and stop-gain limits are
symmetrical, is included in
§ 512.305(c)(2)(iii)(B).
c. Additional Protections for Certain
EPM Participants
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(1) Policies for Certain EPM Participants
to Further Limit Repayment
Responsibility
While the aforementioned proposals
generally provide additional safeguards
to ensure that EPM participants would
have limited repayment responsibility,
we proposed additional protections for
certain groups of EPM participants that
may have a lower risk tolerance and less
infrastructure and support to achieve
efficiencies for high-payment EPM
episodes (81 FR 50873 through 50874).
Specifically, we proposed additional
protections for rural hospitals, SCHs,
Medicare Dependent Hospitals, and
Rural Referral Centers (RRCs). We note
that these categories of hospitals often
have special payment protections or
additional payment benefits under
Medicare because we recognize the
importance of preserving Medicare
beneficiaries’ access to care from these
hospitals.
For the purpose of these models, we
proposed to define a Rural Hospital as
an IPPS hospital that is either located in
a rural area in accordance with
§ 412.64(b) or in a rural census tract
within an MSA defined at
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§ 412.103(a)(1) or has reclassified to
rural in accordance with § 412.103.
We proposed to define a Sole
Community Hospital as it is defined in
§ 412.92. That is, hospitals paid under
the IPPS can qualify for SCH status if
they meet one of the following criteria:
• Located at least 35 miles from other
like hospitals.
• Located in a rural area, located
between 25 and 35 miles from other like
hospitals, and no more than 25 percent
of residents or Medicare beneficiaries
who become hospital inpatients in the
hospital’s service area are admitted to
other like hospitals located within a 35mile radius of the hospital or the
hospital has fewer than 50 beds and
would meet the 25 percent criterion if
not for the fact that some beneficiaries
or residents were forced to seek
specialized care outside of the service
area due to the unavailability of
necessary specialty services at the
hospital.
• Hospital is rural and located
between 15 and 25 miles from other like
hospitals but because of local
topography or periods of prolonged
severe weather conditions, the other like
hospitals are inaccessible for at least 30
days in each of 2 out of 3 years.
• Hospital is rural and the travel time
between the hospital and the nearest
like hospital is at least 45 minutes.
We proposed to define a Medicare
Dependent Hospital (MDH) as it is
defined in § 412.108. That is, an MDH
is a hospital that meets the following
criteria:
• Located in a rural area.
• Has 100 beds or less.
• Is not a SCH.
• Sixty percent of the hospital’s
inpatient days or discharges were
attributable to individuals entitled to
Medicare Part A benefits during
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specified time periods as provided in
§ 412.108.
We proposed to define a Rural
Referral Center as it is defined in
§ 412.96. Specifically, RRCs are defined
as IPPS hospitals with at least 275 beds
that meet the following criteria:
• Fifty percent of the hospital’s
Medicare patients are referred from
other hospitals or from physicians who
are not on the staff of the hospital.
• At least 60 percent of the hospital’s
Medicare patients live more than 25
miles from the hospital.
• At least 60 percent of all services
the hospital furnishes to Medicare
patients are furnished to patients who
live more than 25 miles from the
hospital.
If a hospital does not meet these
criteria, a hospital can also qualify for
RRC status if a hospital meets the
following criteria:
• For specified period of time, the
hospital has a case-mix that equals at
least the lower of the median case mix
index (CMI) value for all urban hospitals
nationally; or the median CMI value for
urban hospitals located in its region,
excluding those hospitals receiving
indirect medical education payments.
• Its number of discharges is at
least—
++ 5,000 (or 3,000 for an osteopathic
hospital); or
++ The median number of discharges
for urban hospitals in the census region
in which it is located, set by the CMS
through IPPS rulemaking.
• Additionally, a hospital must meet
one of the following criteria:
++ More than 50 percent of its active
medical staff are specialists who meet
the conditions specified at
§ 412.96(c)(3).
++ At least 60 percent of all
discharges are for inpatients who reside
more than 25 miles from the hospital.
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++ At least 40 percent of all
inpatients treated are referred from
other hospitals or from physicians who
are not on the hospital’s staff.
Additional information on these
hospitals can be found in the CJR Final
Rule at 80 FR 73403 through 73405.
In the CJR Final Rule, we established
the same stop-gain limits for these
hospitals as for hospitals in general (that
is, 5 percent in performance years 1 and
2, 10 percent in performance year 3, and
20 percent in performance years 4 and
5); however, we limited losses for rural
hospitals, SCHs, Medicare Dependent
Hospitals and RRCs to 3 percent in
performance year 2, and 5 percent in
performance years 3 through 5 (80 FR
73406). In that Final Rule, we noted that
these hospitals can face unique
challenges that do not exist for most
other hospitals. For example, these
hospitals may be the only source of
health care services for beneficiaries or
certain beneficiaries living in rural
areas, and may be in areas with fewer
providers including fewer physicians
and post-acute care facilities. Further,
these hospitals may have more limited
options in coordinating care and
reducing spending while maintaining
quality of care. We continue to believe
that urban hospitals may not have
similar concerns as they are often in
areas with many other providers and
have a greater opportunity to develop
efficiencies under the EPMs. Given
these circumstances, for the CJR model
we determined that we should have a
more protective stop-loss limit policy
for these hospitals. Given the similarity
between the CJR model and the
proposed EPMs, we had similar
concerns, which we believed should be
addressed by establishing greater
protections for these hospitals when
they are EPM participants. Accordingly,
we proposed the same stop-loss
thresholds for these hospitals
participating in the proposed EPMs as
were adopted for the CJR model except
that the thresholds would begin in
performance year 2 (DR)—specifically, 3
percent in performance year 2 (DR), and
5 percent for performance years 3
through 5 for each EPM.
The proposal to establish separate
financial loss limits for certain hospitals
that could be less able to tolerate risk
was included in § 512.305(c)(2)(iii)(C).
We sought comment on our proposed
limit on financial loss for these
hospitals.
The following is a summary of the
comments received and our responses.
Comment: Many commenters
supported the proposal to establish
separate financial loss limits for certain
hospitals. One commenter
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recommended that CMS provide
additional protection to these providers
by waiving downside risk for them for
the entire duration of the models as well
as to retaining the proposed protections
to MDHs in the event the MDH status
expires during the period of the models.
Some commenters requested that CMS
extend to participants with a low
volume of episodes or to hospitals that
serve a large portion of vulnerable
populations these same financial loss
limits because they likely lacked the
infrastructure and support to achieve
greater efficiencies or served
beneficiaries with more complex and
diverse treatment needs. Some
commenters provided data in support of
their request suggesting that hospitals
with fewer episodes had the widest
range in gains and losses largest year-toyear variation in episode spending
relative to target prices. One commenter
suggested that CMS determine eligibility
for these separate financial loss limits
based on the same thresholds that
would be applied for determining
whether a participant’s EPM-episode
benchmark prices would be based only
on regional historical EPM-episode
payments.
Response: We appreciate and agree
with the comments supporting our
proposal to establish separate financial
loss limits for certain hospitals. We do
not agree with the suggestion that we
instead waive downside risk entirely for
these hospitals. Given their lower
tolerance of risk, more limited
infrastructure and support to achieve
efficiencies, and special status under
Medicare to preserve Medicare
beneficiaries’ access to care from these
hospitals, we recognize that certain
adjustments to the model are warranted
for these hospitals. However, we believe
our proposed financial loss limits offer
sufficient protection to these hospitals
while allowing us to maintain an
appropriate balance of incentives to
encourage care quality and efficiency
improvements as would exist for the
other hospitals that would be
participating under the models.
Under current law, the MDH program
will continue through September 30,
2017, but will expire absent additional
legislative authority. As we stated in the
CJR Final Rule (80 FR 73406), we
understand the concern that with the
expiration of MDH status, hospitals will
lose their MDH designation and
additional Medicare FFS payments
provided under the MDH designation.
Additionally, under the expiration of
MDH status, hospitals would no longer
qualify for the protective stop-loss limit
tied to that status under the EPM
models. We believe it would be
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343
inconsistent to apply the additional
benefit of protective stop-loss limits to
former MDHs when by law, those
hospitals are not permitted to retain the
other Medicare payment benefits
provided to MDHs. We would note,
however, that should a participant’s
MDH payment status expire, some
MDHs may apply with their MACs to
determine if they qualify as an RRC or
SCH and would be able to maintain the
protective stop-loss limits.
The requests commenters made to
extend separate financial loss limits to
hospitals with a low volume of episodes
have persuaded us to extend these
separate limits under the EPMs under
certain specific circumstances. We
conducted an analysis of cost variation
for episodes under the EPMs and found
greater variation in episode-level
spending for episodes occurring among
low-volume than high-volume hospitals.
Under a range of low-volume
thresholds, this analysis showed the
standard deviation of historical AMI
episode spending at low-volume
hospitals in selected MSAs was 10 to 32
percent higher than high-volume
hospitals in selected AMI model MSAs.
Likewise, the standard deviation of
historical SHFFT episode spending at
low-volume hospitals was 14 to 18
percent above high-volume hospitals in
selected AMI model MSAs, and the
standard deviation of historical CABG
episode spending was 6 to 19 percent
higher above high volume hospitals in
selected CABG model MSAs.90 Based on
the results of our analysis, we share
commenters’ concerns that when there
is a low volume of episodes under a
model, an EPM participant could
potentially be held responsible for
random variation in spending that
occurs under that model. Thus, we have
been persuaded to extend the separate
financial loss limits that apply to rural
hospitals, SCHs, MDHs, and RRCs to
EPM participants determined to have a
low volume of episodes under an EPM,
which we will refer to as ‘‘EPM volume
protection hospitals.’’
In contrast to rural hospitals, SCHs,
MDHs, and RRCs, however, we will
apply the separate loss limits to EPM
volume protection hospitals at the
model level as we will apply loss limits
to most other hospitals under the EPMs
rather than at the hospital level as is the
case for these specific types of hospitals
eligible for separate loss limits.
Accordingly, this means we could
90 Episodes for AMI, SHFFT, and CABG
beneficiaries initiated by all U.S. IPPS hospitals in
MSAs selected for EPMs and constructed using
standardized Medicare FFS Parts A and B claims,
as proposed in this rule that began in CYs 2012–
2014.
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extend the separate loss limits to an
EPM volume protection hospital for one
or more EPMs but not necessarily all of
the EPMs, depending on whether their
historical EPM episode volume
exceeded the threshold number for the
specific model.
An EPM participant will qualify as an
EPM volume protection hospital if their
volume of historical EPM episodes that
started in calendar years 2013 through
2015 is at or below the 10th percentile
of the number of hospital-specific
historical EPM episodes for hospitals
located in the MSAs eligible for
selection into that specific EPM. For
purposes of determining the 10th
percentile threshold, we will use
historical episodes for the same
historical periods used to determine an
EPM participant’s benchmark and
quality-adjusted target prices for
performance year 1 based on hospitals
with one or more historical episodes
under that model in the applicable
MSAs. This would include hospitals
such as rural hospitals, MDHs, SCHs,
and RRCs. While we considered both
higher and lower thresholds, we believe
the 10th percentile achieves the most
appropriate balance with respect to
focusing our policy on those hospitals
that would uniquely have a low volume
of episodes under an EPM. Though our
analysis of episode volume from 2012–
2014, suggests that around 10 percent of
hospitals with any episodes would be
subject to these additional protections,
we expect that only around 1 percent or
less of episode volume would be subject
to the additional protections.
We also note that a participant could
potentially be eligible for the separate
loss limits based on their being either an
EPM volume protection hospital or
meeting the criteria for being one of the
other eligible hospital types such as a
rural hospital, MDH, SCH, or RRCs. We
wish to clarify that in these cases we
would extend the separate loss limits
based on the criteria for the latter
hospitals as their separate loss limits
would apply at the hospital rather than
the model level. Also, we would note
that the stop-loss protections would not
be additive whereby a participant
benefitted from the stop-loss protections
under both eligibility criteria.
For each EPM, we will post the
applicable historical EPM episode
number threshold used to determine
whether EPM participants are EPM
volume protection hospitals and a list of
the CCNs of EPM participants that are
classified as EPM volume protection
hospitals to the CMS Web site before the
beginning of performance year 1. We
will also indicate to each EPM
participant whether it is classified as an
EPM volume protection hospital at the
same time that we prospectively
communicate quality-adjusted target
prices to EPM participants, as described
in section III.D.4.a. of this final rule.
While the threshold for each EPM will
be set for all five performance years so
that EPM participants can know before
the beginning of the first EPM
performance year their hospital status
for the five years of the EPM, we make
technical revisions to the list of EPM
volume protection hospitals to account
for changes in business practices, like
mergers, acquisitions, or the opening of
new hospitals. For example if an EPM
participant that was an EPM volume
protection hospital merged with another
EPM participant and the merged entity
continued to use the CCN of the EPM
volume protection hospital, we would
consider the historical episode volume
at both EPM participants to determine
whether the merged entity would
continue to be an EPM volume
protection hospital.
We are not adopting the suggestion to
determine an EPM participant’s
eligibility for the separate protections
using the same thresholds that are
applied for determining whether their
EPM-episode benchmark prices would
be based only on regional historical
EPM-episode payments. While these
thresholds are appropriate for purposes
of ensuring reliable estimates when
establishing prices under the models,
the measure would not be an effective
metric for distinguishing hospitals with
a low volume of episodes from other
hospitals. Rather, it would result in too
high a share of hospitals qualifying for
the separate protections and thus would
be too crude a metric for distinguishing
hospitals with a low volume of
episodes.
While we appreciate the comment
suggesting that we extend the separate
stop-loss limits to hospitals treating a
large portion of vulnerable patients, we
are not adopting this suggestion at this
time. As discussed in the following
section of this final rule, however, we
requested comments on issues specific
to hospitals serving a high percentage of
potentially vulnerable populations and
their opportunities to advance the goals
of the EPMs. As we discuss in that
section, while we will not be
incorporating the suggestions we
received in this rule, we will share the
comments and suggestions we received
with the Assistant Secretary for
Planning and Evaluation for their
consideration as well as consider their
potential applicability, where
appropriate, in future rulemaking.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal, with
modification, to establish separate
financial loss protections for certain
hospitals. Once again, we would note
that in delaying when EPM participants
would be required to accept downside
risk under the EPMs as is described in
section III.D.2.c. of this final rule, our
final policy includes conforming
adjustments to the separate financial
loss limits on participants’ overall
payment responsibility. We will extend
the separate financial loss protections to
EPM participants determined to have a
low volume of episodes within a model.
Thus, under our final policy, the
separate financial loss limits for rural
hospitals, SCHs, MDHs, RRCs, and EPM
volume protection hospitals as
displayed in Table 21 are—
• For performance year 2, 3 percent
for EPM participants that voluntarily
elect downside risk for that year; and
• For performance years 3, 4 and 5, 3
percent, 5 percent, and 5 percent
respectively.
TABLE 21—PROPOSED AND FINAL SEPARATE STOP-LOSS LIMITS BY PY
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PY1
PY3
(percent)
PY2
PY4
(percent)
PY5
(percent)
Proposed Separate Stop-Loss Limits Rural Hospitals, SCHs, MDHs, and RRCs
n/a as no downside risk in PY1 ......................
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n/a during non-downside risk period and 3%
during downside risk period.
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345
TABLE 21—PROPOSED AND FINAL SEPARATE STOP-LOSS LIMITS BY PY—Continued
PY1
PY3
(percent)
PY2
PY4
(percent)
PY5
(percent)
Final Separate Stop-Loss Limits Rural Hospitals, SCHs, MDHs, RRCs, and EPM Volume Protection Hospitals
Downside Risk for All Participants—DR effective for episodes ending on or after 1/1/2019 (anchor discharges occurring on or after 10/
4/2018)
n/a as no downside risk in PY1 and PY2 without election of voluntary downside risk for PY2
3
5
5
Voluntary Downside Risk—DR effective for episodes ending on or after 1/1/2018 (anchor discharges occurring on or after 10/4/2017)
n/a as no downside risk in PY1 ......................
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Our final policies for the separate
financial loss protections in included in
§ 512.305(c)(2)(iii)(C) and
§ 512.305(c)(2)(iii)(D).
(2) Considerations for Hospitals Serving
a High Percentage of Potentially
Vulnerable Populations
In addition to the aforementioned
hospitals, our proposed rule noted our
recognition that other EPM participants,
for which we did not propose additional
protections, could also face factors
affecting their ability to achieve savings
under the proposed EPMs, and that
these factors could be unrelated to their
practice patterns but instead could
reflect the EPM participants’
responsibilities for a relatively high
percentage of potentially vulnerable
populations with higher than average
historical spending and/or less
opportunities for efficiencies. For
example, this could include hospitals
that serve a relatively high percentage of
beneficiaries that are dually eligible for
both Medicare and Medicaid or whose
total Medicare payments include a
relatively high proportion of
disproportionate share hospital
payments under 1886(d)(5)(F) of the
Act. Some of these hospitals are located
in rural areas and would thus likely be
classified as a type of hospital for which
we proposed additional protections.
However, most hospitals that serve a
relatively high percentage of
beneficiaries that are dually eligible for
both Medicare and Medicaid or whose
total Medicare payments include a
relatively high proportion of
disproportionate share hospital
payments are located in urban areas,
and very few are classified as a rural
hospital, RRC, MDH, or SCH that would
be subject to the additional protections
we proposed. For the first 2
performance years of the EPMs, where
quality-adjusted target prices are set
predominantly based on EPMparticipant hospital-specific data,
factors affecting these hospitals may be
of less concern than in the final 3
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3% ..................................................................
performance years of the EPMs where
pricing is either predominantly or
totally based on regional data.
Our proposed rule also noted that the
potential challenges posed by these
kinds of factors is highlighted in Section
2(d) of the Improving Medicare PostAcute Care Transformation ‘‘IMPACT’’
Act of 2014 (Pub. L. 113–183).
Specifically, Section 2(d) requires the
Secretary to conduct a study that
examines the effect of individuals’
socioeconomic status, including their
Medicaid eligibility, on quality
measures and resource use and other
measures for individuals under the
Medicare program, in recognition that
less healthy individuals may require
more intensive interventions. The
Secretary is required to submit a report
on the results of this study within 2
years of enactment of the IMPACT Act.
The IMPACT Act also requires the
Secretary to conduct a second study that
examines the impact of various risk
factors, as well as race, health literacy,
limited English proficiency (LEP), and
Medicare beneficiary activation, on
quality measures and resource use and
other measures under the Medicare
program in order to recognize that less
healthy individuals may require more
intensive interventions. The Secretary
must submit a report on the results of
this study within 5 years of enactment
of the IMPACT Act.
If these studies find a relationship
between the factors examined in the
studies and quality measures and
resource use and other measures, then
the Secretary shall provide
recommendations for, among other
things, how CMS should account for
such factors in quality measures,
resource use measures, and other
measures under Medicare; and in
determining payment adjustments based
on such measures in other applicable
provisions related to the program.
Likewise, taking into account these
studies and their recommendations as
well as other relevant information, the
Secretary is required to routinely, as
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5
5
determined appropriate and based on an
individual’s health status and other
factors, assess appropriate adjustments
to quality measures, resource use
measures, and other measures under the
Medicare program; and assess and
implement appropriate adjustments to
Medicare payments based on these
measures. The Assistant Secretary for
Planning and Evaluation is responsible
for these studies and a report on the
results of the first one is forthcoming.
Our proposed rule noted that upon
issuance of these studies’ reports, we
planned to consider their results as we
implemented the proposed EPMs. We
also planned to monitor the influence of
beneficiary characteristics such as
socioeconomic status on EPM
participants’ performance during our
implementation and evaluation of the
EPMs. Given that the performance of
EPM participants would be compared
largely against their own historical
episode cost performance data for the
first 2 years of the models, however, we
did not anticipate that the
aforementioned factors should
materially affect participants’ ability to
achieve savings. However, as we
increasingly began to rely more on
regional cost performance data to
determine episode benchmarks and
quality-adjusted target prices in
performance year 3, these factors could
become more germane. Thus, in the
event we identified the need for
adjustments, we could consider
proposing additional policies through
subsequent rulemaking. Additionally,
we planned to use information collected
as part of our efforts to monitor
beneficiary access to care and quality of
care as discussed in sections III.G.4. and
III.G.5. of the proposed rule (81 FR
50914 through 50915) to inform if
potential adjustments would be needed
in future years of the model.
Protections for EPM participants were
discussed in section III.D.7.b.(1) and
III.D.7.c.(1) of the proposed rule (81 FR
50872 through 50874). We sought
comment about all issues specific to
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hospitals serving a high percentage of
potentially vulnerable populations and
their opportunities to advance the goals
of the EPMs (81 FR 50875). In
particular, we sought comment,
including data analysis, about
approaches to identifying these
hospitals; their opportunities to achieve
high quality episode performance;
specific considerations about their
opportunities to achieve efficient care
for the clinical conditions included in
the AMI, CABG, and SHFFT models;
potential approaches to risk adjustment;
potential approaches to additional
protections that could be considered for
the future modeled after our proposals
in section III.D.7.b.(1) of this final rule
for certain other EPM participants or
other alternatives; and evaluation
methodologies to ensure that we include
appropriate comparison groups and
monitor and evaluate the most relevant
outcomes.
The following is a summary of the
comments received and our responses.
Comment: Commenters urged CMS to
provide greater financial protections for
providers serving a high portion of
vulnerable populations, and
recommended that CMS apply lower
caps on such providers’ losses. While
these commenters suggested that further
study was needed, they recommended
that, at a minimum, CMS should extend
the 5 percent cap to include all of
performance year 3, and reduce the cap
in PY4 and PY5 to 10 percent. These
commenters also noted that CMS would
establish a definition of vulnerable
populations, which should account for
Medicaid and uninsured populations,
and should seek public comment on this
definition. For example, one commenter
suggested that CMS consider section
1900 of the Social Security Act to
identify hospitals serving a high number
of vulnerable patients. Another
commenter expressed their appreciation
for CMS’ highlighting of this issue,
recommended that adjustments for
socio-demographic variables would be
logical starting point, and providers that
care for vulnerable patients and
populations should be treated equally.
Response: We appreciate the
comments we received on these issues
and agree that further study is needed.
While we will not be incorporating
suggestions we received in this rule, we
will share the comments and
suggestions we received with the
Assistant Secretary for Planning and
Evaluation for their consideration as
well as consider their potential
applicability, where appropriate, in
future rulemaking.
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d. Application of Stop-Gain and StopLoss Limits
Because participants could be
participating in the proposed AMI,
CABG, and SHFFT models concurrently
with the CJR model, our proposed rule
noted that an additional consideration
concerns the level at which the stop-loss
and stop-gain thresholds would be
applied, for example, at the participant’s
level, as is currently the case for the CJR
model, or at some other level, for
example, at the model level. We
indicated that our intention was to
establish appropriate incentives and
protections for participants under the
proposed EPMs and the CJR model
without creating unnecessary
administrative complexity. Further, this
issue would become especially relevant
to the proposed EPMs and CJR model
given that the CJR model and proposed
EPMs would be operating at different
points within their performance
periods. That is, episodes under the
proposed EPMs would always lag 1
performance year behind those in the
CJR model. Thus, SHFFT model
participants that would begin the first
SHFFT model performance year in 2017
would already be participating in their
second performance year under the CJR
model. Consequently, in this example, a
stop-loss limit could apply to the
performance year 2 episodes under the
CJR model but not to the performance
year 1 SHFFT model episodes under the
SHFFT model as SHFFT model
participants would not have repayment
responsibility in SHFFT model
performance year 1 under our proposal.
In contrast, for this example, the stopgain limits would be the same for both
the SHFFT and CJR model since the
limit for both performance year 1 and 2
would be 5 percent.
Continuing with this example for a
later performance year (performance
year 4 for the CJR model and
performance year 3 for the SHFFT
model), any stop-loss limits that applied
would be different. That is, the stop-loss
limits for the CJR model episodes in
performance year 4 would be 20 percent
in contrast to the 10 percent stop-loss
limit that would apply to the SHFFT
model episodes in performance year 3.
The proposed stop-gain limits would
likewise diverge in this example as they
are proposed to be symmetrical with the
stop-loss limits.
Given these differences, we
considered two options for setting stopgain and stop-loss limits for hospitals
participating in more than one of the
AMI, CABG, SHFFT, and CJR models
(81 FR 50875 through 50876). Under the
first option, we would determine stop-
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loss and stop-gain limits, in total, at the
participant level based on weighted
thresholds. Specifically, CMS would
calculate a single weighted stop-loss/
gain threshold based on the total
spending under each model. Thus,
using the aforementioned example
where CJR model episodes would be in
performance year 4 of their model and
SHFFT model episodes would be in
performance year 3, assuming 50
percent of total spending under the CJR
and SHFFT models is for CJR model
episodes and the remaining 50 percent
is for SHFFT model episodes, the
weighted stop-loss limit for the two
models at the participant level would be
15 percent: (0.50 × 0.20 for CJR model
episodes) + (0.5 × 0.10 for SHFFT model
episodes) = 0.15. Although this option
would allow the application of a single
stop-loss threshold to a participant’s
total repayment under the models, we
are concerned that computing a single
limit such as this could either dilute or
magnify the intended protections of the
stop-loss limit under each model. As
such, a participant that would have
been protected from repayment
exceeding 10 percent of its SHFFT
model quality-adjusted target prices
multiplied by the number of SHFFT
model episodes for performance year 3
would only be protected for costs above
the higher 15 percent level. Conversely,
a participant that would have been
protected only for repayment above 20
percent of its CJR model qualityadjusted target prices multiple by the
number of CJR model episodes for
performance year 3 would be protected
against repayment above the lower 15
percent threshold.
Alternatively, we considered
establishing stop-loss and stop-gain
thresholds at the model level; that is,
separately for each of the AMI, CABG,
and SHFFT models, in addition to the
limits that already exist for the CJR
model. Under this option, we would
separately apply the CJR-applicable
stop-loss and stop-gain limits to CJR
model episodes, the AMI-applicable
limits to AMI model episodes, and so
forth. Thus, considering the
aforementioned example, the stop-loss
limit for CJR model episodes in
performance year 4 would be 20 percent
for the hospital’s CJR model episodes,
while the stop-loss limit for SHFFT
model episodes for performance year 3
would be 10 percent. While we might
choose to aggregate these amounts to
conduct a single financial transaction
with a hospital participating in more
than one model, we believe this option
that would apply stop-loss and stopgain limits at the model level for
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hospitals participating in more than one
model is superior to first option in that
it better maintains appropriate
incentives and protections under each
of the models.
The proposal to establish stop-gain
and stop-loss limits at the model level
was included in § 512.305(c)(2)(iii)(D).
We sought comment on our proposal to
establish stop-gain and stop-loss limits
at the model level.
The following is a summary of the
comments received and our responses.
Comment: Some commenters
expressed concerns that a blanket stoploss policy could offer insufficient
protection to participants with a low
volume of cases. Thus, one commenter
recommended that the stop-loss
provision be calculated on an episodespecific basis for each provider as the
degree of outcome variability will differ
significantly based on the provider’s
volume and starting price position
relative to the region. Another
commenter recommended that CMS
apply stop-loss limits at the episode
level separately for low, medium, and
high volume providers rather than at the
model or program level so that the level
of protection would vary by the number
of episodes. In their view, this approach
would offer hospitals, particularly those
with lower volume, greater protection
against exceptionally high costs.
Response: We appreciate the
comment generally supporting our
proposal as well as the suggestions to
modify our proposal. As discussed
elsewhere in this rule, in addition to
protections we had proposed with
respect to capping high-cost cases with
respect to our financial calculations (see
section III.D.3.d.), we are finalizing
policies that would offer to hospitals
with a low volume of episodes under a
model the same stop-loss protections
that would apply to certain other
hospitals (see section III.D.7.c.) as well
as further adjustments for risk that we
anticipate making effective beginning in
PY3 (see section III.D.4.a.2). We believe
these protections are sufficient and are
thus not adopting the recommended
modifications to the application of stoploss protections.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal, without
modification, to establish stop-gain and
stop-loss limits at the model level. Our
final policy for establishing these limits
is included in § 512.305(c)(2)(iii)(E).
e. EPM Participant Responsibility for
Increased Post-Episode Payments
Our proposed rule noted that while
episodes under the proposed EPMs
would extend 90 days post-discharge
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from the anchor or chained anchor
hospitalization, some EPM participants
may have an incentive to withhold or
delay medically-necessary care until
after an EPM episode ends to reduce its
actual EPM-episode payments. This
inappropriate shifting could include
both those services that are related to
the episode (for which the hospital
would bear financial responsibility as
such services would be included in the
actual EPM-episode payment
calculation) and those that are unrelated
(which would not be included in the
actual EPM-episode payment
calculation), because an EPM
participant engaged in shifting of
medically-necessary services outside the
EPM episode for potential financial
reward may be unlikely to clearly
distinguish whether the services were
related to the EPM episode or not in the
hospital’s decisions.
We also stated our belief that this
inappropriate shifting would not be
typical, especially given the relatively
long EPM episode duration. However, in
order to identify and address
inappropriate shifting of care, we
proposed to calculate for each EPM
performance year the total Medicare
Parts A and B expenditures in the 30day period following completion of each
EPM episode for all services covered
under Medicare Parts A and B,
regardless of whether the services are
included in the proposed EPM episode
definition (sections III.C.3. and III.C.4 of
the proposed rule, (81 FR 50829 through
50843). This proposal is consistent with
our processes for BPCI Model 2 and the
CJR model (80 FR 73407 through
73408).
We proposed that the post-episode
spending calculation for a performance
year would occur at the same time we
performed the subsequent reconciliation
calculation for that same year (81 FR
50876 through 50877). We believe this
timeframe would allow sufficient time
for claims run out in order to set a
reliable regional threshold for
determining the post-episode spending.
For example, we would conduct
reconciliation for performance year 1 in
the spring of 2018. The post-episode
spending calculation for performance
year 1 would occur during the next
reconciliation process (spring 2019),
when we conduct the subsequent
reconciliation calculation for
performance year 1 and account for
overlap with other models and
programs.
Our proposed calculation would
include prorated payments for services
that extend beyond the EPM episode as
discussed in section III.D.3.c. of the
proposed rule (81 FR 50846).
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347
Specifically, we would identify whether
the average 30-day post-episode
spending for an EPM participant in any
given EPM performance year is greater
than 3 standard deviations above the
regional average 30-day post-episode
spending, based on the 30-day postepisode spending for episodes attributed
to all regional hospitals participating in
the EPM in the same region as the EPM
participant. We proposed that if the
EPM participant’s average post-episode
spending exceeds this threshold, the
EPM participant would repay Medicare
for the amount that exceeds such
threshold. We noted that, consistent
with CJR, an EPM participant’s
responsibility for post-episode spending
would not be subject to the stop-loss
and stop-gain limits proposed in section
III.D.7.b. and III.D.7.c.(1) of the
proposed rule (81 FR 50872 through
50875). Also, although we believed that
cases in which an EPM participant
would be responsible for repayment of
post-episode spending that exceeds the
threshold would be rare, our intention
was to identify and hold EPM
participants responsible for situations in
which those participants have
significantly increased spending on
services in the 30 days following the
end of an EPM episode in order to
inappropriately shift services out of
EPM episodes. This policy is consistent
with our proposal for the CJR model in
section V.D.1. of the proposed rule (81
FR 50951 through 50952).
We also noted that based on our
experience with BPCI, we have not
found that this proposal, including our
proposal to include all Medicare Parts A
and B expenditures to measure 30-day
post-episode spending, would
inappropriately penalize EPM
participants. To that end, however, we
believed that our proposed threshold of
3 standard deviations above the regional
average is a high threshold, and we only
proposed that an EPM participant
would repay Medicare for the amount
that exceeds such threshold. We further
noted that those EPM participants that
are eligible for reconciliation payments
in an EPM performance year and also
have average 30-day post-episode
spending that is higher than 3 standard
deviations above the regional average
30-day post-episode spending would
have their reconciliation payments
reduced by the amount by which
spending exceeds 3 standard deviations.
The proposals to determine if a
participant’s post-episode spending 30
days after the end of an episode exceeds
3 standard deviations of average
spending in their region for that period,
and require those participants exceeding
that threshold to repay Medicare for the
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amounts in excess of 3 standard
deviations were included in
§ 512.307(c). We sought comment on
our proposals to determine if a
participant exceeds this threshold and
to repay amounts in excess of the
threshold.
The following is a summary of the
comments received and our responses.
Comment: One commenter expressed
support for the proposal as it could help
identify participants that withhold or
delay medically necessary care until
after an episode ends in order to reduce
their actual episode spending. This
commenter further suggested that CMS
also implement a financial penalty for
participants that are found to
inappropriately delay beneficiaries’
care.
Response: We appreciate the
comments in support of our proposal.
As noted in section III.F.2. of this final
rule, we have finalized various
compliance tools for the EPMs that
complement existing laws and
regulations prohibiting care stinting,
provision of substandard care, or denial
of medically necessary care. As
discussed in section III.F.2., when an
EPM participant or its related EPM
collaborator, collaboration agent, or
downstream collaboration agent engages
in these noncompliant behaviors, CMS
may take remedial action, including
reducing or eliminating the EPM
participant’s reconciliation payment or
reducing or eliminating the EPM
participant’s CR incentive payment
amount. In addition, under
circumstances where CMS has required
a corrective action plan, the EPM
participant owes a repayment amount to
CMS, and the EPM participant fails to
timely comply with the corrective
action plan or is noncompliant with the
EPM’s requirements, CMS may add 25
percent to a repayment amount on an
EPM participant’s reconciliation report.
We believe these tools and structure for
the financial penalty is consistent with
the request of the commenter.
Comment: Some commenters viewed
the proposal as unnecessary in light of
other enforcement mechanisms to
address hospitals that are willfully
committing potential fraud and abuse or
that the proposal effectively extends the
episode duration from 90 to 120 days.
One commenter stated that for cases
where 30-day post-episode spending
exceeded a certain threshold, these
expenditures were likely necessary for
treatment of a patient’s clinical needs
rather than representing an intentional
delay in providing care to Medicare
beneficiaries to game the system for
greater financial rewards.
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Response: We disagree with the view
that our proposal is unnecessary in light
of other enforcement actions. We
believe that our proposal in conjunction
with our policies related to monitoring
and enforcement actions is an
appropriate means to discourage the
occurrence of instances where access to
high quality care might be impeded, and
believe this deterrence is preferable to
having to take enforcement actions
subsequent to such an instance. We also
do not agree with the comment that we
are effectively extending episodes or
that expenditures beyond our thresholds
would typically be necessary for the
care of a beneficiary. We also note that
in the event that CMS identifies
excessive post-episode spending at an
EPM participant greater than 3 standard
deviations above the regional average
30-day post-episode spending, the EPM
participant will only be required to pay
back the amount by which post-episode
spending for episodes attributed to the
EPM participant exceeds 3 standard
deviations above the regional average
30-day post-episode spending. We note
that this does not hold the EPM
participant responsible for all postepisode spending as would be the case
with 120 day episodes. Moreover, we
believe that this threshold is sufficiently
high to account for all clinically
necessary care that would occur in the
30 days following an episode. As we
noted in the CJR Final Rule (80 FR
73407), we believe that monitoring for
30 day post-episode spending is an
appropriate tool to identify
inappropriate shifts in car based on our
experience with BPCI.
Comment: Some commenters raised
concerns that care or services that are
excluded from or unrelated to an
episode would be included in the
calculation of post-episode spending
and recommended that we exclude
these services from post-episode
payment calculations. One commenter
requested that CMS identify care
situations that are ‘‘unrelated’’ to the
EPM episode diagnosis with regard to
calculating post-episode spending costs.
Response: As we stated in the CJR
Final Rule (80 FR 73407), we disagree
that we should exclude the same set of
services that are excluded from the
episode definition in the 30 day postepisode spending calculations because
of concerns that the models could lead
to shifting of both related and unrelated
(those not included in the episode
definition) services due to some
providers encouraging delays of services
for beneficiaries that are not
immediately necessary, without
discriminating between those services
that are in and out of the episode
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definition. Additionally, our experience
with BPCI that similarly includes all
costs when monitoring for 30 day postepisode spending has helped to inform
our policy for the CJR and the proposed
EPMs. Based on our experience with
BPCI, we have not found that by
including all costs to measure 30 day
post-episode spending, that we are
inappropriately penalizing hospitals.
While we understand commenters’
concerns that hospitals could be held
responsible for high cost conditions that
are not included in the episode
definition, our policy aims to strike a
balance to hold participating hospitals
accountable for inappropriate shifts or
delays in care and to provide hospitals
with safeguards on financial risk for 30day post-episode spending. Thus, we
have set a high threshold where only
hospitals that have a 30-day postepisode spending average that is 3
standard deviations above the regional
average would be subject to repay that
difference to Medicare, and in the case
where the hospital’s average 30-day
post-episode spending exceeds regional
average 30-day post-episode spending,
the participant would repay Medicare
for the amount that exceeds such
threshold.
Comment: Some commenters opposed
the proposal to exclude post-episode
spending from the stop-loss for the
proposed EPM models in part because
they viewed the provision overall as
unnecessary and because of potential
harm to those hospitals that might
result.
Response: We have established the
stop-loss policy to account for clinical
variation or other high expenditures that
are not accounted for by the target price
methodology, which is not directly
comparable to excessive spending that
occurs during the 30 days after an
episode. We believe that the postepisode spending policy sets a
sufficiently high threshold to identify
situations with clear increases in postepisode spending due to shifting of
services to maximize financial gain
under the EPMs, and thus that the stoploss policy should not apply to any
potential amount that an EPM
participant owes CMS under the postepisode spending policy.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal, without
modification, to determine if a
participant’s post-episode spending 30
days after the end of an episode exceeds
3 standard deviations of average
spending in their region for that period,
and require those participants exceeding
that threshold to repay Medicare for the
amounts in excess of 3 standard
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deviations. Our final policy for this is
included at VII.
Collection of Information Requirements
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8. Appeals Process
a. Overview
Consistent with the BPCI initiative
and CJR model, we proposed to institute
appeals processes for the EPMs that
would allow EPM participants to appeal
matters related to payment, such as CR
incentive payments, reconciliation
amounts, repayment amounts,
determinations associated with quality
measures affecting payment (the use of
quality measure results in determining
the composite quality score, or the
application of the composite quality
score during reconciliation) as well as
non-payment related issues, such as
enforcement matters. These matters are
discussed respectively throughout
section III.D. and III.F. of this final rule.
We sought comment on the proposal
to institute appeals processes for the
EPMs.
The following is a summary of the
comments received and our responses.
Comment: A commenter requested
clarification on how CMS will handle
an EPM participant’s appeal of a
potential calculation error when the
beneficiary has substance abuse and/or
behavioral health claims which cannot
be shared with the EPM participant. The
commenter expressed concern regarding
the balance between privacy restrictions
around substance abuse and behavioral
health claims and information that is
provided to EPM participants in order to
verify the calculations. The commenter
stated that EPM participants will have
to assume CMS has performed all
calculations correctly, and as this is not
a desirable situation, according to the
commenter, the commenter
recommended CMS exclude these
claims from the episode calculation or
provide the information to the EPM
participants.
Response: While we appreciate the
commenters’ position, we believe that
the inclusion of these substance use
disorder claims in the episode target
and actual price calculations is
necessary for accurately pricing the
episodes.
Our proposal to exclude this
information from the claims shared with
model participants is consistent with
our usual treatment of these data with
other similar CMS programs and models
where providers must take on risk in
managing the care of their beneficiaries,
such as the Shared Savings Program,
BPCI and the CJR model. We would note
that, based on our experience to date,
we are unaware of this policy being a
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significant impediment to the
operations of these efforts. We do
understand that by not receiving this
data, EPM participants are unable to
fully verify the accuracy of CMS’
calculations. However, as these claims
typically represent less than 0.1 percent
of episode spending (based on an
analysis of 2015/2016 claims data used
in current BPCI episodes) we do not
believe their exclusion from the data
that we provide to participants will
produce material differences in the
replication of target/actual prices.
Further, Section 1115A of the Act
does not authorize the waiver of the
requirements under 42 CFR part 2
which govern the release of substance
use disorder claims. We note, though,
that we may be able to share these
claims with participants in the near
future based on proposals outlined in
the Confidentiality of Substance Use
Disorder Patient Records proposed rule
published to the Federal Register by
SAMHSA on February 9, 2016 (81 FR
6987), which updates the 42 CFR part 2
regulations (referred to hereafter as the
Part 2 Rule).
These regulations govern the
confidentiality of substance use disorder
records. Significant changes have
occurred within the U.S. health care
system that were not envisioned by the
current regulations, including new
models of integrated care that are built
on a foundation of information sharing
to support coordination of patient care,
the development of an electronic
infrastructure for managing and
exchanging patient information, and a
new focus on performance measurement
within the health care system. In the
proposed rule, SAMHSA states that it
strives to facilitate information
exchange within new health care
models while addressing the legitimate
privacy concerns of patients seeking
treatment for a substance use disorder.
In section 2.53 of the proposed rule,
SAMHSA also proposes to permit the
disclosure of Part 2 data necessary to a
regulated ACO or similar CMS-regulated
organization (including a CMS-regulated
Qualified Entity (QE)) for a Medicare,
Medicaid, Children’s Health Insurance
Program (CHIP), or related audit or
evaluation, under certain conditions. As
such, should this SAMHSA proposal
become final, EPM participants would
be considered CMS-regulated Qualified
Entities and would be able to receive
this data pursuant to this audit and
evaluation exception.
CMS will continue to consider the
feasibility of making de-identified
aggregate substance use disorder data
available in a way that is both
meaningful to EPM participants and in
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349
compliance with the Part 2 Rule. This
issue is discussed in further detail in the
data sharing section.
Comment: Commenters expressed
concern regarding the data files and
reconciliation reports received from the
contractors administering our programs
based on their experiences thus far with
BPCI and CJR. Commenters stated the
monthly data feeds from CMS regularly
omit data elements that are used by the
contractor to identify and reconcile
episodes to target prices. Specifically,
commenters stated that the master
beneficiary files contained errors in the
DOD and MSCD 1–12 fields. These
fields either contained inaccurate or
missing information. Commenters stated
without these data elements, it is
impossible to replicate the
reconciliation results calculated by
CMS. Participants are left to assume the
contractor’s calculations are accurate.
Commenters stated that the ability to
replicate the reconciliation results helps
maintain a transparent and open
relationship among the EPM
participants, CMS, and CMS’ contractor.
Commenters also recommended CMS
provide a mechanism for EPM
participants to challenge and correct
payment results that are not accurate.
Commenters request the ability to
provide evidence contradicting errors.
Commenters stated currently there is no
process or data system in place for this
function. Commenters stated that the
lack of a feedback loop will be an
increasingly critical barrier to
participation as the current system has
been known to make errors.
Response: We thank commenters for
their feedback. We understand
commenters’ concern regarding missing
data elements but we note that some of
these elements are deliberately excluded
in compliance with the constraints of 42
CFR part 2 and we are currently unable
to provide such data. However, the
comment response discussed previously
outlines the potential changes that may
be forthcoming regarding the data
sharing constraints in 42 CFR part 2.
Regarding the master beneficiary files
that contained errors in the DOD and
MSCD 1–12 fields, CMS will work with
their contractors to insure that the data
provided is accurate. We appreciate the
feedback regarding these operational
concerns and we will work with the
EPM payment contractor to establish a
tracking and feedback process for
participants to ask questions of CMS
regarding payment calculations and
potential incorrect amounts and be
provided more detailed information
regarding their reconciliation report and
calculation error reports for the EPM
models.
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Comment: A commenter
recommended that CMS change the time
period to recoup monies owed to CMS
from EPM participants from 30 days to
60 days from the issuance of the
Reconciliation Report.
Response: We thank the commenter
for the comment. However, because the
operational processes used in payment/
recoupment actions are part of a
standard system that operates across
multiple models, including BPCI and
CJR, as well as standard FFS operational
timelines, we are unable to
accommodate a system change and the
recoupment time frame will be finalized
at 30 days.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal without
modification.
b. Notice of Calculation Error (First
Level Appeal)
We proposed the following
calculation error process for EPM
participants to contest matters related to
payment or reconciliation, of which the
following is a non-exhaustive list: The
calculation of the EPM participant’s
reconciliation amount or repayment
amount as reflected in the reconciliation
report; the calculation of the EPM
participant’s CR incentive payment as
reflected in the CR incentive payment
report; the calculation of NPRA; the use
of quality measure results in
determining the composite quality
score, or the application of the
composite quality score during
reconciliation; and the successful
reporting of the voluntary PRO THA/
TKA data. EPM participants would
review their reconciliation report and
CR incentive payment report and be
required to provide written notice of
any error, in a calculation error form
that must be submitted in a form and
manner specified by CMS. Unless the
EPM participant provides such notice,
the reconciliation report and CR
incentive report would be deemed final
within 45 calendar days after it is
issued, and CMS would proceed with
payment or repayment. If CMS receives
a timely notice of an error in the
calculation, CMS would respond in
writing within 30 calendar days to
either confirm or refute the calculation
error, although CMS would reserve the
right to an extension upon written
notice to the participant. We proposed
that if an EPM participant does not
submit timely notice of a calculation
error, that is notice within 45 calendar
days of the issuance of the
reconciliation report and CR incentive
payment report, the EPM participant
would be precluded from later
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contesting any of the following matters
contained in the reconciliation report or
CR incentive payment report for that
performance year; any matter involving
the calculation of the EPM participant’s
reconciliation amount or repayment
amount as reflected in the reconciliation
report; any matter involving the
calculation of the EPM participant’s CR
incentive payment as reflected in the CR
incentive payment report; any matter
involving the calculation of NPRA; the
use of quality measure results in
determining the composite quality
score, or the application of the
composite quality score during
reconciliation; and the successful
reporting of the voluntary PRO THA/
TKA data. Given that EPM participants
bear the financial risk in the EPM
model, we proposed that only EPM
participants might use the dispute
resolution process described in this
section.
In summary, we proposed the
following requirements in § 512.310 (a)
for notice of calculation error:
• Subject to the limitations on review
in subpart D of this part, if an EPM
participant wishes to dispute the
calculation that involves a matter
related to payment, a CR incentive
payment, reconciliation amounts,
repayment amounts, or determinations
associated with quality measures
affecting payment, the EPM participant
is required to provide timely written
notice of the calculation error, in a form
and manner specified by CMS.
• Unless the EPM participant
provides such notice, CMS deems final
the reconciliation report and CR
incentive payment report 45 calendar
days after the reconciliation report or
CR incentive payment report is issued
and proceeds with the payment or
repayment processes as applicable.
• If CMS receives a notice of a
calculation error within 45 calendar
days of the issuance of the
reconciliation report or CR incentive
payment report, CMS responds in
writing within 30 calendar days to
either confirm that there was an error in
the calculation or verify that the
calculation is correct, although CMS
reserves the right to an extension upon
written notice to the EPM participant.
• Only EPM participants may use the
notice of calculation error process
described in this part.
We sought comment on the proposed
notice of calculation error requirements.
The following is a summary of the
comments received and our responses.
Comment: Commenters recommended
development of a fair and transparent
process for providers to appeal
reconciliation report information.
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Commenters stated EPM participants
must be given adequate notice that their
reconciliation reports are available, and
must be provided with sufficient time to
review their data. Commenters stated
that, in many cases, the reconciliation
reports may need to be reviewed by
multiple providers at multiple locations,
including both EPM participants and
post-acute care providers. Commenters
recommended that in order for EPM
participants to access, review, and
contest data in 45 days, they would be
required to ignore the demands of
patient care and competing priorities
providers face on a daily basis.
Commenters recommended extending
the appeals process to no less than 90
days. A commenter suggested the appeal
process be extended to 90 days for at
least the first 2 performance years.
Another commenter recommend that
the 45 days for hospitals to provide
written notice of error should not begin
until it is mutually agreed upon by the
contractor and stated hospital that a
complete report, which includes all data
elements used by the contractor to
identify and reconcile episodes to target
prices, has been received.
Commenters also disagreed that a
reconciliation would be considered final
if a notice is not provided in the time
window. Commenters stated that they
understood that there must be a
timeframe to finalize these payments
and that a disputed amount cannot be
brought forth for an indefinite amount
of time. However, commenters also
stated that it is important for EPM
participants to have an opportunity to
submit a notice for substantial errors
over a longer period of time.
Commenters suggested that for
submitted participant-caused errors that
are greater than 20 percent of the
payment amount, a 180-day window
should be allowed. Due to the size of the
potential error, commenters stated that
EPM participants may require
additional time to gather the necessary
information and conduct the
appropriate analysis to provide to CMS
stating the rationale for their request.
Commenters stated that many EPM
participants will be new to the EPMs
and this recommendation is an
important safeguard for potential ‘‘large
ticket’’ errors. Commenters concurred
with CMS’ proposal to provide a
response within 30 days of receiving a
request, including CMS reserving the
right to an extension of that 30 days if
CMS provides this notice to participants
in writing.
Response: We appreciate these
comments and are sympathetic to the
requests from commenters for more time
to submit a notice of calculation error.
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However, we are also conscious of the
need to distribute funds to providers
with positive NPRAs in a timely fashion
and the payment/reconciliation
disbursement/recoupment system is
designed such that no funds can be
released until notices of calculation
errors are received by CMS. In balancing
these needs, consistent with our
rationale in the CJR model, we believe
that 45 days is sufficient time for EPM
participants to review reconciliation
reports, and if they choose, to submit
notices of calculation error. We believe
that 45 days is the appropriate
timeframe to allow for this process, as
it allows for a reasonable time to review
reconciliation reports and does not
seriously delay payment of
reconciliation payments. Specifically,
CMS currently uses the following
established operational procedures for
appeals in both BPCI and CJR that we
are finalizing in section III.D.8. of this
final rule.
The procedures for processing and
issuing reconciliation payments and
repayments require that we submit the
payment files for EPM participants to
the payment systems in batches. CMS
uses this batch processing method for
several reasons. It is administratively
more efficient to continue to use MACs
to issue payments to all providers and
suppliers that furnish services to
beneficiaries during an EPM, so as not
to disrupt the timing of FFS payments
that providers and suppliers normally
receive. For reconciliation payments
and repayments, CMS has developed
and implemented a process for handling
these payments, which is already in use
for other CMS models. This current
process is the result of a substantial
number of infrastructure changes to
payment and recoupment procedures
that were made over a period of several
years. As a result, we believe it is
appropriate to utilize those processes for
the EPMs, given that the challenges
associated with establishing these
processes, as well as the fact that they
were created for other CMS models.
The effect of these processes is that
the batches are sent at specified
intervals. The first batch is sent after the
calculation error timeframe closes. The
second batch is sent after CMS has
responded to the notices of calculation
error of EPM participants and those
EPM participants choose to not proceed
with the dispute resolution process
detailed in section III.D.8.c. of this final
rule. The final batch is sent after CMS
has adjudicated all of the
reconsideration reviews for those
participants that selected to utilize the
dispute resolution process.
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Given these established operating
processes, any extension in the
timeframe allowed for submission of
notices of calculation error delays
payment not only to EPM participants
that choose to utilize the calculation
error and dispute resolution processes,
but also those EPM participants that
choose not to engage in these processes.
Historically, 90 percent of BPCI
awardees do not file a notice of
calculation error form. As such, we
believe the need for extending the
deadline for submission of notices of
calculation error should be balanced
with CMS’ goal to issue reconciliation
payments and repayments promptly, as
an extension for these submissions
would delay the processing of
reconciliation payments for all
participants for a significant period of
time. EPM participants have stated these
monies will be used for implementing
both IT and care redesign. We believe
that an extension beyond the 45 days
proposed would cause undue burden on
non-appealing EPM participants.
We also considered the commenters’
requests to extend the time frame for
notice of participant-caused errors that
are greater than 20 percent of the
payment amount to 90 or 180 days, but
we rejected these recommendations
because we note that the calculation
error form represents the first step in a
two-step appeals process. Where an
EPM participant submits a calculation
form and is dissatisfied with CMS’
response, the dispute resolution option
is available to the EPM participant via
a reconsideration review request. Upon
receipt of a reconsideration review
request, the date of such a review would
be scheduled by CMS approximately
115 days from the issue date of the
reconciliation report. Thus, we believe
that the option for reconsideration
review, at a much later date, provides
EPM participants with adequate
additional time to analyze the data on
reconciliation reports, that a 90 or 180
day submission deadline for the
calculation error form is unnecessary.
Finally, we believe the 45 days
appropriately balances the goal of CMS
to process reconciliation payments on a
timely basis with the needs of EPM
participants to have adequate time to
review their reconciliation reports and
submit notices of calculation error.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal to allow 45 days
for participants to advise CMS of errors
without modification.
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c. Dispute Resolution Process (Second
Level of Appeal)
We proposed the following dispute
resolution process. First, we proposed
that only an EPM participant may
utilize the dispute resolution process.
Second, in order to access the dispute
resolution process a participant must
have timely submitted a calculation
error form, as previously discussed, for
any matters related to payment. We
proposed these matters would include
any amount or calculation indicated on
a reconciliation report or CR incentive
payment report, including calculations
not specifically reflected on a
reconciliation report or CR incentive
payment report but which generated
figures or amounts reflected on a
reconciliation report or a CR incentive
payment report. The following is a nonexhaustive list of the matters that we
proposed would need to be first
adjudicated by the calculation error
process as previously detailed:
Calculations of reconciliation or
repayment amounts; calculation of CR
incentive payment amounts;
calculations of NPRA; and any
calculations or percentile distribution
involving quality measures that we
proposed that could affect reconciliation
or repayment amounts. If an EPM
participant wants to engage in the
dispute resolution process with regard
to one of these matters, we proposed it
would first need to submit a calculation
error form. Where the EPM participant
does not timely submit a calculation
error form, we proposed the dispute
resolution process would not be
available to the EPM participant with
regard to those matters for the
reconciliation report or CR incentive
payment report for that performance
year.
If the EPM participant did timely
submit a calculation error form and the
EPM participant is dissatisfied with
CMS’ response to the EPM participant’s
notice of calculation error, the EPM
participant would be permitted to
request reconsideration review by a
CMS reconsideration official. The
reconsideration review request would
be submitted in a form and manner and
to an individual or office specified by
CMS. The reconsideration review
request would provide a detailed
explanation of the basis for the dispute
and include supporting documentation
for the EPM participant’s assertion that
CMS or its representatives did not
accurately calculate the NPRA, the CR
incentive payment, or post-episode
spending amount in accordance with
EPM rules. The following is a non-
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exhaustive list of representative
payment matters:
• Calculations of NPRA, calculations
of the CR incentive payment, postepisode spending amount, target prices
or any items listed on a reconciliation
report or CR incentive payment report.
• The use of quality measure results
in determining the composite quality
score, the application of the composite
quality score during reconciliation, or
the successful reporting of the voluntary
PRO THA/TKA data.
• Any contestation based on the
grounds that CMS or its representative
made an error in calculating or
recording such amounts.
Where the matter is unrelated to
payment, such as termination from the
model, we proposed that the EPM
participant need not submit a
calculation error form. We proposed to
require the EPM participant to timely
submit a request for reconsideration
review, in a form and manner to be
determined by CMS. Where such a
request is timely received, we proposed
CMS would process the request as
discussed later in this section.
We proposed that the reconsideration
review would be an on-the-record
review (a review of briefs and evidence
only). The CMS reconsideration official
would make reasonable efforts to notify
the EPM participant in writing within
15 calendar days of receiving the EPM
participant’s reconsideration review
request of the date and time of the
review, the issues in dispute, the review
procedures, and the procedures
(including format and deadlines) for
submission of evidence (the
‘‘Scheduling Notice’’). The CMS
reconsideration official would make
reasonable efforts to schedule the
review to occur no later than 30 days
after the date of the Scheduling Notice.
The provisions at § 425.804(b), (c), and
(e) (as in effect on the publication date
of this final rule) would apply to
reviews conducted pursuant to the
reconsideration review process for EPM.
The CMS reconsideration official would
make reasonable efforts to issue a
written determination within 30 days of
the review. The determination would be
final and binding.
We solicited comment on our
proposals related to appeals rights
under this model. The two-step appeal
process for payment matters—(1)
calculation error form, and (2)
reconsideration review—is used broadly
in other CMS models. We sought
comment on whether we should
develop an alternative appeal process.
We are also interested in whether there
should be appeal rights for reductions or
eliminations of NPRA as a result of
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enforcement actions, as discussed in
section III.F. of the proposed rule, and
if so, whether the process for such
appeals should differ from the processes
proposed here.
In summary, we proposed the
following requirements in § 512.310(b)
for the reconsideration process:
• If the EPM participant is
dissatisfied with CMS’ response to the
notice of a calculation error, the EPM
participant may request a
reconsideration review in a form and
manner as specified by CMS.
• The reconsideration request must
provide a detailed explanation of the
basis for the dispute and include
supporting documentation for the EPM
participant’s assertion that CMS or its
representatives did not accurately
calculate the NPRA, the reconciliation
payment, the CR incentive payment or
the repayment amount in accordance
with subpart D of this part.
• If CMS does not receive a request
for reconsideration from the EPM
participant within 10 calendar days of
the issue date of CMS’ response to the
EPM participant’s notice of calculation
error, then CMS’ response to the
calculation error is deemed final and
CMS proceeds with reconciliation
payment or repayment processes, as
applicable, as described in § 512.305.
• The CMS reconsideration official
notifies the EPM participant in writing
within 15 calendar days of receiving the
EPM participant’s review request of the
following:
++ The date, time, and location of the
review.
++ The issues in dispute.
++ The review procedures.
++ The procedures (including format
and deadlines) for submission of
evidence.
• The CMS reconsideration official
takes all reasonable efforts to schedule
the review to occur no later than 30
days after the date of receipt of
notification.
• The provisions at § 425.804(b), (c),
and (e) of this chapter are applicable to
reviews conducted in accordance with
the reconsideration review process for
the EPM.
• The CMS reconsideration official
issues a written determination within 30
days of the review. The determination is
final and binding.
Only EPM participants may utilize the
dispute resolution process described in
this subpart. We sought comment on the
proposed reconsideration process for
the EPMs.
The following is a summary of the
comments received and our responses.
Comment: Commenters were
concerned with the timing proposed in
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the second level appeal to submit a
reconsideration request, arguing 10
calendar days is insufficient.
Commenters stated that 10 calendar
days is grossly inadequate for providers
to analyze and seek any necessary
clarification from CMS on the response,
to conduct any further necessary
analysis and to submit the
reconsideration request. Commenters
stated that the timeframe should be no
less than 60 calendar days. Commenters
believed this should provide sufficient
time for providers to gather the
necessary information and make the
request. Commenters also stated that
this extension accounts for other timing
issues, such as holidays, that do not
make 10 calendar days reasonable.
Commenters also criticized the proposal
regarding timeframes required for CMS
responses, arguing these are not firm
timeframes and that they are
contradictory to those timeframes that
CMS is proposing to implement for EPM
participants. Commenters stated that
while CMS states they will make every
reasonable effort to meet these
timeframes, there are no proposed
consequences to CMS should they not
meet them.
Response: We appreciate these
comments and are sympathetic to the
requests from commenters for more time
to resubmit a reconsideration request.
However, we believe that a longer
timeframe for submission of the
reconsideration request is not
appropriate for the EPMs. We note the
EPM participant must make the request
within this timeframe and provide an
explanation of the basis of the dispute.
CMS will make all reasonable efforts to
schedule the review to occur no later
than 30 days after the date of receipt of
the notification. This rule does not
prevent an EPM participant from
supplying supplemental documentation
after they submit the request to support
their basis. As such we believe that 10
days to make the request is sufficient
since this deadline requires only that
the EPM participant submit the request
and an explanation of the basis for the
dispute. Upon submitting the request for
dispute resolution, the rule allows the
EPM participant to submit additional
supporting documentation in the
interim period prior to the final review
by the CMS reconsideration official.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal without
modification.
d. Exception to the Notice of Calculation
Error Process and Notice of Termination
Similar to the CJR model and BPCI
initiative, if the EPM participant
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contests a matter that does not involve
an issue contained in, or a calculation
which contributes to, an EPM
reconciliation report or a CR incentive
report, a notice of calculation error is
not required. Consistent with III.D.8(c)
in the proposed rule (81 FR 50878), in
instances where a notice of calculation
error is not required, for example an
EPM participant’s termination from the
EPM, we proposed the EPM participant
provide a written notice to CMS
requesting review within 10 calendar
days of the notice. CMS has 30 days to
respond to the EPM participant’s
request for review. If the EPM
participant fails to notify CMS, the
decision is deemed final.
In summary, we proposed the
following requirements in § 512.310(c)
for an exception to the notice of
calculation error process:
• If the EPM participant contests a
matter that does not involve an issue
contained in, or a calculation which
contributes to a reconciliation report or
CR incentive payment report, a notice of
calculation error is not required. In
these instances, if CMS does not receive
a request for reconsideration from the
EPM participant within 10 calendar
days of the notice of the initial
determination, the initial determination
is deemed final and CMS proceeds with
the action indicated in the initial
determination. This does not apply to
the limitations on review in subparagraph (e).
In summary, we proposed the
following requirements in § 512.310(d)
for notice of termination:
• If an EPM participant receives
notification that it has been terminated
from the EPM and wishes to appeal
such termination, it must provide a
written notice to CMS requesting review
of the termination within 10 calendar
days of the notice. CMS has 30 days to
respond to the EPM participant’s
request for review. If the participant
fails to notify CMS, the termination is
deemed final.
We sought comment on the proposed
exception to the notice of calculation
error process and notice of termination.
The following is a summary of the
comments received and our responses.
Final Decision: CMS did not receive
any comments regarding this section.
Therefore, we are finalizing the proposal
without modification.
e. Limitations on Review
In summary, we proposed the
following requirements in § 512.310 (e)
for limitations on review:
• In accordance with section
1115A(d)(2) of the Act, there is no
administrative or judicial review under
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sections 1869 or 1878 of the Act or
otherwise for the following:
++ The selection of models for testing
or expansion under section 1115A of the
Act.
++ The selection of organizations,
sites, or participants to test those
models selected.
++ The elements, parameters, scope,
and duration of such models for testing
or dissemination.
++ Determinations regarding budget
neutrality under section 1115A(b)(3) of
the Act.
++ The termination or modification of
the design and implementation of a
model under section 1115A(b)(3)(B) of
Act.
++ Decisions to expand the duration
and scope of a model under section
1115A(c) of the Act, including the
determination that a model is not
expected to meet criteria described in
paragraph (e)(1) or (2) of this section.
We sought comment on the proposed
limitations on review.
The following is a summary of the
comments received and our responses.
Final Decision: CMS did not receive
any comments on this section.
Therefore, we are finalizing the proposal
without modification.
E. EPM Quality Measures, Public
Display, and Use of Quality Measures in
the EPM Payment Methodology
1. Background
As discussed in the CJR model final
rule, Medicare payment policy has
moved away from FFS payments
unlinked to quality and towards
payments that are linked to quality of
care (80 FR 73358). Through the
Medicare Modernization Act and the
Affordable Care Act, we have
implemented specific IPPS programs
like the HIQR Program (section
1886(b)(3)(B) of the Act), the HVBP
Program (subsection (o) of section 1886),
the Hospital Acquired Condition
Reduction Program (HACRP)
(subsection (q) of section 1886), and the
Hospital Readmissions Reduction
Program (HRRP) (subsection (p) of
section 1886), where quality of care is
linked to payment. We have also
implemented the Shared Savings
Program, an ACO program that links
shared savings payment to quality
performance. The CJR model similarly
incorporates pay-for-performance
through the potential for financial
reward to participants based on the
hospital’s level of quality performance,
while also including an incentive for
quality improvement if the hospital’s
current level of quality is relatively low
(80 FR 73374).
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353
We proposed pay-for-performance
methodologies similar to the CJR model
for the proposed EPMs. Specifically, we
proposed to financially reward higher
quality in an EPM episode by reducing
the effective discount factor used to
calculate EPM quality-adjusted target
prices at reconciliation. We would
establish the effective discount factor
based on the EPM participant’s overall
quality performance and improvement
on the EPM’s quality measures as
reflected in the EPM participant’s EPM
composite quality score. We would
calculate the EPM participant’s
composite quality score for each EPM
performance year at the time of
reconciliation. The EPM composite
quality score would also determine
whether an EPM participant is eligible
for a reconciliation payment if savings
are achieved beyond the EPM qualityadjusted target price by setting a
minimum EPM composite quality score
for reconciliation payment eligibility.
We note that we continue to believe
that EPMs should include pay-forperformance methodologies that
incentivize improvements in patient
outcomes while simultaneously
lowering health care spending (80 FR
73465). We believe that improved
quality of care, specifically achieved
through coordination and
communication among providers in
conjunction with patients and their
caregivers, can favorably influence
performance on patient outcomes. Like
the CJR model, we also believe that the
proposed three new EPMs would
provide the opportunity for EPM
participants to improve the quality of
care based on timely reported patient
experience, including communications
with doctors and nurses, and
responsiveness of hospital staff (80 FR
7065). Finally, we strive to align as
many measures as possible in CMS’s
proposed new EPMs with those in
ongoing models and programs. Our goal
is to focus provider improvement efforts
and minimize burden on EPM
participants in needing to become
familiar with and report new measures,
while still allowing us to appropriately
capture meaningful quality data and use
it in the EPMs’ pay-for-performance
methodologies.
More specifically, similar to our final
decision for the CJR model, we did not
propose to use any readmissions
measures that could apply to clinical
conditions in these EPMs but that are
already in place or have been finalized
for the HRRP, specifically the Hospital
30-day all-cause risk-standardized
readmission rate (RSRR) following AMI
hospitalization (NQF #0505) and the
Hospital 30-day all-cause, unplanned,
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RSRR following CABG surgery (NQF
#2515), due to the incentives, already in
place by the HRRP, for hospitals to
lower excess readmission rates (80 FR
73479). While we consider these
readmissions measure rates to be
important metrics for providing
information about AMI and CABG
hospital performance in the HRRP and
HIQR Program for payment and public
reporting, respectively, other proposed
measures for the AMI and CABG models
support the intent of these models to
reduce actual payments in an EPM
episode while ensuring that quality of
care for AMI and CABG model
beneficiaries is improved.
Furthermore, while we recognize the
lack of complete alignment between
EPM beneficiaries and the proposed
cohorts for the EPM quality measures,
we believe the proposed measures
provide meaningful information about
EPM participant quality performance
and improvement that are relevant to
EPM beneficiaries. For the AMI and
CABG models in particular,
beneficiaries included in the proposed
episode-specific measures would
significantly overlap with beneficiaries
in AMI and CABG model episodes. We
note that for purposes of the EPMs
where we need to identify episodes that
are included in the EPMs, we proposed
to use the term anchor to identify
hospitalizations that initiate EPM
episodes for beneficiaries whose care is
included in the EPMs. In describing the
quality measures in detail in section
III.E.4. of this final rule, we use the term
index hospitalization to identify
hospitalizations of beneficiaries whose
outcomes are included in the measures.
Thus, anchor hospitalizations and index
hospitalizations would have varying
degrees of overlap depending on the
specific quality measure.
Moreover, we note that hospitals are
the unit of analysis for the EPMs and
that the proposed measures are hospitalcentric measures, both because these are
currently available measures that are
aligned with those in other CMS
programs and because one of the major
goals of the EPMs is to encourage
collaboration among different types of
providers in order to achieve better care
and reduced expenditures, while
holding acute care hospitals financially
responsible. For further discussion of
our proposal that hospitals be
accountable for EPM episodes, we refer
to section III.B.3. of this final rule.
We recognized that there are also
some gaps in the current proposed
measures relative to other settings in
which patients receive care posthospital discharge during EPM
episodes, as well as around important
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complications of care for clinical
conditions included in the three
models. However, we believe that these
hospital-level measures reasonably
assess how well EPM participants
provide care for EPM beneficiaries since
the measures, depending on the EPM,
assess—(1) important patient outcomes,
including mortality as well as
complications and days of acute care
following discharge from the index
hospitalization which can be costly; and
(2) patients’ perspectives on their
hospital experience, which include
patient feedback on communication
with doctors, communication with
nurses, responsiveness of hospital staff,
communication about medicines,
discharge information, cleanliness of the
hospital environment, quietness of the
hospital environment, and transition to
post-hospital care. As we gain more
experience with the EPMs, as well as
the CJR model currently in testing, and
future EPMs, we plan to work to create
a more robust set of episode quality
measures for these and future models.
As we stated in the proposed rule, we
will continue to assess the evolving
inventory of measures and will continue
to refine quality measures for potential
future rulemaking based on public
comments, changes to the EPMs’
payment methodologies,
recommendations from EPM
participants and their collaborators, and
new CMS episode measure development
activities as we learn more about the
impact of EPMs on quality improvement
and episode efficiency. We refer to
section III.E.4.e. of this final rule for a
discussion of potential future EPM
episode measures.
2. Selection of Quality Measures for the
EPMs
a. Overview of Quality Measure
Selection
The outcome and patient experience
measures proposed for the EPMs were
selected in order to: (1) Promote
alignment with the financial and quality
goals of the EPMs; (2) leverage hospitals’
familiarity with the measures due to
their use in other CMS hospital quality
programs, including programs that tie
payment to performance such as the
HVBP Program; (3) streamline EPM
measures for EPM participants testing
more than one EPM; and (4) ensure
consistency with CMS’s priorities to
reduce AMI and CABG mortality and
complications while improving patient
experience, as well as with CMS’s
priorities to reduce major LEJR surgery
complications while improving the
patient experience for SHFFT model
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beneficiaries, like those in the CJR
model.
b. AMI Model Quality Measures
In order to encourage care
collaboration among multiple providers
of AMI model beneficiaries, we
proposed three required measures and
one measure that relies on voluntary
data submission, in order to determine
AMI model participant episode quality
performance and improvement that
would be linked to the AMI model
payment methodology as discussed in
section III.E.3.f.(2) of this final rule. We
proposed the following measures for the
AMI model:
• Hospital 30-Day, All-Cause, RiskStandardized Mortality Rate (RSMR)
Following Acute Myocardial Infarction
(NQF #0230) (MORT–30–AMI).
• Excess Days in Acute Care after
Hospitalization for AMI (AMI Excess
Days).
• HCAHPS Survey (NQF #0166).
• Voluntary Hybrid Hospital 30-Day,
All-Cause, Risk-Standardized Mortality
Rate Following Acute Myocardial
Infarction (AMI) Hospitalization (NQF
#2473) (Hybrid AMI Mortality) data
submission.
I. We refer to sections III.E.4.a. and d.
of this final rule for a detailed
discussion of our proposals regarding
these measures for the AMI model,
including their importance as measures
of the quality-of-care for beneficiaries
treated for AMI. The proposals for the
AMI model measures are included in
§ 512.411, and the proposals for
reporting the measures are included in
§ 512.400. We sought comment on our
proposals for AMI model quality
measures.
The following is a summary of the
comments received and our responses.
Comment: A few commenters
supported the selection of these
measures as good indicators of quality
for AMI patients under the model.
Commenters expressed an appreciation
for the small size of the proposed
measure set, compared to the larger
more burdensome set of measures that
have been proposed in previous
demonstrations and CMS programs.
Response: We appreciate the support
expressed for the small, yet
comprehensive, set of measures selected
for this model. Our goal is to focus
provider improvement efforts and
minimize burden on EPM participants
in needing to become familiar with and
report new measures, while still
allowing us to appropriately capture
meaningful quality data and use it in the
EPMs’ pay for performance
methodologies and we believe the small
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set of measures we proposed will enable
us to achieve this goal.
Comment: Several commenters
expressed concern that the 30-Day All
cause Risk Standardized Mortality Rate
(RSMR) following Acute Myocardial
Infarction is not a good indicator of
quality for the EPM episode 90 day
episode of care. They stated that the
quality metrics proposed for AMI are
too hospital centric and will not assess
quality across the full continuum of
care. In contrast, a few other
commenters recommended that CMS
narrow the window for the AMI episode
from 90 days to 30 days, stating that it
is known from large randomized trials
of therapies for AMI patients that the
overwhelming majority of disease
related complications and poor
outcomes occur within the first 30 days.
Additionally, some commenters
expressed concern that reporting quality
data could discourage the treatment of
the most vulnerable and frail AMI
patients. Other commentators stated that
patients with AMI and serious
disability, frailty and concurrent
illnesses would not benefit from the
model quality measures as these
patients may have much higher
mortality rates. Commenters also
expressed concern that the proposed
quality metrics do not offer useful ways
to risk adjust for local patterns of care
regarding end of life care in hospitals for
these frail, high-risk patients. Several
commenters expressed concern that the
measures that were proposed are
misaligned with the cohort for this
model. Additionally, commenters were
concerned that the quality metrics as
proposed may not provide a meaningful
measure of the quality of care for those
targeted under the model.
Response: We appreciate comments
regarding the use of this measure in the
model, and the duration of the episodes.
While previous studies indicate that
most complications occur during the 30Day post discharge period, under this
model we are evaluating the impact of
a bundled payment on quality of care
for a 90 day episode. For consistency
sake across the model, we intend to
evaluate the impact of such payment
across a full 90 day period to ensure we
capture longer term outcomes for
patients. The models we proposed
define hospitals as the episode initiators
and financially accountable entities and
while we acknowledge that the
measures we proposed are hospitalcentric, we believe they are appropriate
for these hospital initiated models. We
are appreciative of the concern
regarding the quality of care for the
beneficiaries including the frail,
severely ill beneficiaries that may be
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included in the population on which
this model is focused and that is why
we proposed a comprehensive set of
measures that rely on quality metrics
that are readily available for use under
the model. While we recognize the lack
of complete alignment between EPM
beneficiaries and the proposed cohorts
for the EPM quality measures, we
believe the proposed measures provide
meaningful information about EPM
participant quality performance and
improvement that are relevant to EPM
beneficiaries. We acknowledge that
longer measures are needed and will
begin investigating the development of
measures to assess the quality of care
across the full 90 day episode and if
feasible, will incorporate such measures
into model if deemed appropriate.
Comment: We received a mix of
comments for and against the proposed
EDAC measure for the AMI model. A
few commenters urged CMS to remove
the EDAC measures from the AMI
model measure set, noting that the
proposed EDAC measure was adopted
for the FY 2018 hospital IQR program,
and is intended to capture ‘‘all-cause
acute care utilization’’ in the 30 days
after discharge for patients with a
discharge diagnosis of AMI.
Commenters further stated that in
contrast to the existing AMI hospital
readmission measure in IQR, the AMI
EDAC measure includes both emergency
department (ED) visits and observation
stays, in addition to hospital
readmissions. Commenters stated the
purpose of the bundled payment is to
create a financial incentive that aligns
with the care goal of improving the
patients’ health to the point where a
return to the hospital is unnecessary.
Measuring EDAC may be important
when the financial incentives push
toward greater numbers of hospital
encounters, as they do in the fee for
service system. However, in a bundled
payment model, the commenters stated
that this measure may not be as
meaningful. Commenters urged CMS to
alter how we think about what to
measure in the bundle, stating that
excess days in hospital care should not
be the focus. Additionally, commenters
were concerned that this measure
inappropriately overlaps with the
HRRP, thereby creating inconsistent
incentives to reduce readmissions.
Some stakeholders believe the use of
this measure may lead to mixed
performance signals between the
existing HRRP and EPM model,
potentially leading to hospitals doing
well in one program and poorly in
another. Some of these commenters
expressed concern that the EDAC
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355
measure lacks NQF endorsement and
has not yet been publicly reported on
Hospital Compare. Commenters stated
the hospital field has limited insight on
whether the measure is accurate and
reliable and also noted the lack of sociodemographic adjustment in the EDAC
measure as a potential problem.
Alternatively, commenters in support
of patients’ rights endorsed the EDAC
measure stating that it will capture all
hospital contact including emergency
room and observation stays. These
commenters supported EDAC as it
measures the full experience of a
patient’s stay which should be a
meaningful measure of hospital care
quality. Another commenter offering
support for the EDAC from a patients’
rights point of view stated that mortality
and excess days in acute care are
undoubtedly outcomes that matter to
beneficiaries and their families and
should absolutely be measured.
Response: We appreciate stakeholder
concerns regarding inclusion of the
EDAC measure in the model. Although
we received fewer comments supporting
the inclusion of this measure in the
model, we believe the points made in
favor of patients’ rights and the need to
measure the full hospital experience
from the patient point of view are valid
and relevant to this model that is
designed to improve quality of care for
the beneficiaries. We also note that the
AMI EDAC measure has been
recommended for endorsement without
risk adjustment for sociodemographic
status (SDS) and it will be publicly
reported starting July 2017.
Regarding concerns for measure
overlap with HRRP, we conducted
additional comparison analysis to
determine the degree to which the
EDAC and readmission measures
provide distinct information about
hospitals’ performance. In our analysis
we compared hospitals’ outlier status
using results from both sets of measures.
The findings demonstrate that more
hospitals are characterized as outliers by
the EDAC measures compared with the
readmission measures. Therefore, the
two sets of measures provide different
and directionally consistent information
about hospitals performance. Very few
hospitals are characterized in opposing
directions by the two sets of measures,
meaning that those few hospitals with
poorer performance on the readmission
measures tend to also perform poorly on
the EDAC measures.
We conclude that, with the inclusion
of this measure in the AMI EPM, nearly
all hospitals that are currently penalized
in the HRRP will also be poor
performers on the EDAC measure.
However, most poor performers on the
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AMI EDAC measure will not be
identified as poor performers on the
AMI readmissions measure. The total
overlap is minimal although there is a
risk that some hospitals will be
penalized in both the HRRP and AMI
EPM programs.
While some commenters suggest that
measuring EDAC may only be important
when the financial incentives push
toward greater numbers of hospital
encounters, as they do in the FFS
system, we believe tracking return visits
to the hospital is a good indicator of the
overall quality of care in an episode
payment model as well.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal, without
modifications, to the AMI measure set
as proposed.
c. CABG Model Quality Measures
In order to encourage care
collaboration among multiple providers
of CABG model beneficiaries, we
proposed two required measures, in
order to determine CABG model
participant episode quality performance
and improvement that would be linked
to the CABG model payment
methodology as discussed in section
III.E.3.f.(3) of this final rule. We
proposed the following measures for the
CABG model:
• Hospital 30-Day, All-Cause, RiskStandardized Mortality Rate (RSMR)
Following Coronary Artery Bypass Graft
(CABG) Surgery (NQF# 2558) (MORT–
30–CABG).
• HCAHPS Survey (NQF #0166).
We refer to sections III.E.4.b. and d. of
this final rule for a detailed discussion
of our proposals regarding these
measures for the CABG model,
including their importance as measures
of the quality-of-care for beneficiaries
treated with CABG.
II. The proposals for the CABG model
measures are included in § 512.412.,
and the proposals for reporting the
measures are included in § 512.400. We
sought comment on our proposals for
CABG model quality measures.
The following is a summary of the
comments received and our responses.
Comment: A few commenters support
our proposed CABG measures stating
that the measures represent a brief,
focused and relevant set of quality
metrics. They expressed support for the
use of the Thirty (30) day mortality
measure, stating that this measure
appropriately focuses on the key quality
metrics that matter in the domain of
cardiac care.
Response: We appreciate the support
for the model and quality metrics
proposed and we also believe that these
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measures reflect key quality metrics that
matter for cardiac care.
Comment: A commenter suggested
that CMS should also consider
including a quality measure to evaluate
blood transfusion rates during and after
CABG procedures, stating that
unnecessary blood transfusions during
and after CABG procedures are costly to
patients and to hospitals. Perioperative
red blood cell transfusion is the single
factor most reliably associated with
increased perioperative morbidity
events after CABG, such as serious
infections, prolonged ventilation
support and renal failure.
Response: We thank the commenter
for their suggestion. CMS believes the
30 Day All Cause Risk Standardized
Mortality rate will capture
complications that lead to death related
to the CABG procedures performed
under the model.
Comment: A group of commenters
recommended that the Society of
Thoracic Surgeons (STS) consensus
based outcomes be included for the
CABG measure set. The STS has a
robust, risk adjusted National Adult
Cardiac Database that tracks measures
for CABG Commenters stated that the
vast majority of cardiothoracic programs
and provides already report to and
participate in the Database.
Response: We agree with commenters
that the STS measure set is a
comprehensive NQF-endorsed
composite measure with strong
potential to meaningfully improve
quality. Although the STS measures
were not proposed as a measure initially
we intend to amend the measure set for
CABG to include a voluntary data
submission for various measures (there
are 11 distinct measures) within the STS
composite measure. Reporting of this
measure data will be voluntary and will
only help model participants. This
measure will count for 10 percent of the
score which will be worth 2 points. We
have re-weighted the CABG and
HCAHPS scores out of a total point basis
of 18. We will rank the overall scores
out of 18 to set the performance ranges
and then we offer 2 points on top of that
if participants voluntarily submit data
for this measure. The revised scoring
and weighting methodology for the
CABG model is discussed in detail in
the linking quality payment section III
E.4.f of this final rule.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal, with
modification, to incorporate the STS
composite measure data submission as a
voluntary option (would only help
participants) weighted at 10 percent of
the composite quality score as discussed
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in detail in section III E.4.f of this final
rule. CMS does not anticipate
significant operational difficulties as we
plan to work collaboratively with the
STS Registry to receive the data files
following each data collection period as
prescribed by the STS Registry. EPM
participants who are not members of the
STS Proprietary Registry, but are a HQR
participating facility would have access
to Secure File Transfer (SFT). Data files
can be securely sent via SFT in a
transitional submission format available
to systems using a spreadsheet-based
approach.
d. SHFFT Model Quality Measures
In order to encourage care
collaboration among multiple providers
of SHFFT model beneficiaries, we
proposed two required measures and
one measure that relies on voluntary
data submission, in order to determine
SHFFT model participant episode
quality performance and improvement
that would be linked to the SHFFT
model payment methodology as
discussed in section III.E.3.f.(4) of this
final rule. While we recognize that none
of the proposed measures specifically
target the care of SHFFT model
beneficiaries, these measures are the
same as those used for the CJR model
because SHFFT model episodes will be
tested along with the LEJR episodes in
the CJR model (80 FR 73501 and 73507)
at mostly the same hospitals. In
addition, as discussed further in section
III.E.3.e.(3) of this final rule, we propose
to calculate a hospital-level composite
quality score that would apply to
episode payment for both the CJR and
SHFFT models, consistent with our
proposal of the same measures for the
two models. We believe that due to the
inclusion of beneficiaries with hip
fracture in both the CJR and SHFFT
models and our desire to streamline
EPM participant measure reporting, as
well as the focus of both models on
major lower extremity orthopedic
surgery, the same set of quality
measures can be used for both models
to incentivize quality improvement in
lower extremity orthopedic surgery care
and episode efficiency. We are also
considering future measure
development focused specifically on hip
and femur fracture patients. We expect
that many of the physicians and other
providers collaborating with participant
hospitals in the SHFFT and CJR models
will be the same, such that certain care
pathways and episode efficiencies may
be coordinated for SHFFT and CJR
model beneficiaries regardless of the
model, potentially resulting in quality
improvement for beneficiaries in both
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models. We proposed the following
measures for the SHFFT model:
• Hospital-level RSCR following
elective primary THA and/or TKA (NQF
#1550) (Hip/Knee Complications).
• HCAHPS Survey (NQF #0166).
• Total Hip Arthroplasty (THA)/Total
Knee Arthroplasty (TKA) voluntary
patient-reported outcome (PRO) and
limited risk variable data submission
(Patient-reported outcomes and limited
risk variable data following elective
primary THA/TKA).
We considered an alternative
approach to the required quality
measures for the SHFFT model given
that the proposed measures do not
specifically target the SHFFT model
beneficiaries. This alternative approach
would not account for any hip-specific
measures (such as, Hospital-level RSCR
following elective primary THA and/or
TKA (NQF #1550) (Hip/Knee
Complications)) and would instead only
measure patient experience through the
HCAHPS Survey (NQF #0166).
Although there may be some rationale
for excluding measures that do not
specifically target SHFFT model
beneficiaries, we did not propose this
approach to SHFFT model quality
measures because we believe that it is
critical to include a measure of both
clinical and patient experience
outcomes in the setting of lower
extremity orthopedic surgery episodes.
Additionally, we believe that using
quality measures for SHFFT model
episodes that do not align with those in
the CJR model could generate confusion
at CJR model participant hospitals
where we proposed that the SHFFT
model be tested as discussed in section
III.B.4. of the proposed rule (81 FR
50794).
We refer to sections III.E.4.c. and d. of
this final rule for a detailed discussion
of our proposals regarding these
measures for the SHFFT model,
including their importance as measures
of the quality-of-care for beneficiaries
undergoing major lower extremity joint
replacement surgery.
The proposals for the SHFFT model
measures are included in § 512.413, and
the proposals for reporting the measures
are included in § 512.400. We sought
comment on our proposals for SHFFT
model quality measures.
The following is a summary of the
comments received and our responses.
Comment: Several commenters
expressed concern that using the
Hospital–level Risk Standardized
Complication Rate (RSCR) measure of
elective THA and/or TKA outcomes as
an elective measure is an inappropriate
proxy of SHFFT quality, as improving
quality for the emergency procedures
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covered under SHFFT has no impact on
RSCR. These commenters stated that the
program effectively incentivizes only
cutting costs without any beneficiary
protection related to the quality of care.
There is concern that use of this
measure may distort incentives toward
improving measures unrelated to care
with no regard for the actual quality of
an emergency SHFFT episode of care.
Response: We do not agree that the
measure only incentivizes cost cutting.
While we recognize that none of the
proposed measures specifically target
the care of SHFFT model beneficiaries,
these measures are the same as those
used for the CJR model because SHFFT
model episodes will be tested along
with the LEJR episodes in the CJR model
(80 FR 73501 and 73507) at mostly the
same hospitals. In addition, as
discussed further in section III.E.3.e.(3)
of this final rule, we proposed to
calculate a hospital-level composite
quality score that would apply to
episode payment for both the CJR and
SHFFT models, consistent with our
proposal of the same measures for the
two models. We continue to believe that
due to the inclusion of beneficiaries
with hip fracture in both the CJR and
SHFFT models and our desire to
streamline EPM participant measure
reporting, as well as the focus of both
models on major lower extremity
orthopedic surgery, the same set of
quality measures can be used for both
models to incentivize quality
improvement in lower extremity
orthopedic surgery care and episode
efficiency. We recognize that more
robust measures better targeted to the
SHFFT population are desirable and
will considering future measure
development focused specifically on hip
and femur fracture patients.
Comment: Several commenters
expressed support for the use of Patient
Reported Outcome Measures (PROM) in
SHFFT, and were supportive of plans to
incentivize model participants who
report PROMs.
Response: We appreciate the support
for collection of PRO data in this model
and believe that patient outcome data
which will help develop quality PROMs
can be helpful in measuring the quality
of care rendered under this model.
Comment: A few commenters
expressed concern that the model
doesn’t include functional outcome
measures and quality of life measures to
assess the quality of life for the patient
population. Commenters recommend
that we consider performance-measures
of function for the population such as
the Six-Minute Walk Test. Including
functional performance measures will
give CMS better data on the functional
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357
outcome of this patient population.
Commenters expressed concern that
while the measures proposed for use in
this model mirror those in the CJR
model, and considering the SHFFT
model will be operating alongside the
CJR episodes the SHFFT model
composition of mostly non-elective
cases precludes that the population
between the two models have stark
differences. Therefore, simply
transferring the data from one EPM to
another is not appropriate. Commenters
urged CMS to develop measures that
more accurately reflect the populations
included in the model specifically.
Response: We appreciate the
commenter thoughts regarding utilizing
quality metrics to accurately measure
and account for the patient population
served under the SHFFT model
specifically, in contrast to those in the
concurrent CJR model. We believe that
we have proposed a measure set of
readily available measures to assess the
quality of care across the SHFFT
episodes. We will continue to
investigate utilizing measures to more
accurately reflect the patient population
in this model.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal, without
modification, to the quality measures
proposed in the SHFFT model.
3. Use of Quality Measures in the EPM
Payment Methodologies
a. Overview of EPM Composite Quality
Score Methodology
We believe that the proposed EPMs
provide another mechanism for
hospitals to improve quality of care,
while also achieving cost efficiency.
Incentivizing high-value care through
episode payments for AMI, CABG, and
hip fracture care is a primary objective
of these proposed EPMs. Therefore,
incorporating quality performance into
the episode payment structure is an
essential component of the proposed
EPMs, just as it is for the CJR model (80
FR 73370). For the reasons stated
previously, we believe it is important
for the AMI, CABG, and SHFFT models
to link the financial reward opportunity
with performance and improvement in
the quality of care for Medicare
beneficiaries treated for AMI, CABG,
and hip fracture.
As discussed in section III.D.4.a. of
the proposed rule (81 FR 50794), which
outlines the pricing methodologies for
EPM episodes, for each EPM participant
we proposed to set an EPM-episode
benchmark price for each EPM episode.
We would apply the EPM participant’s
effective discount factor based on the
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participant’s quality performance and
improvement for the EPM performance
year to the EPM-episode benchmark
episode price to calculate the qualityadjusted target price for each EPM
episode. We refer to section III.E.3.f. of
this final rule for further discussion of
the relationship between an EPM
participant’s quality performance and
improvement and the effective discount
factor. As discussed in section
III.C.4.a.(5) of this final rule, we are not
finalizing our proposed AMI model
inpatient-to-inpatient transfer episode
initiation and attribution policy so we
will not use the terms chained anchor
hospitalization and price MS–DRG in
the final AMI episode definition and
quality discussion. Each EPM episode
includes an anchor hospitalization for
either AMI (AMI MS–DRG or PCI MS–
DRG with AMI ICD–10–CM diagnosis
code in the principal or secondary
diagnosis code position), CABG (CABG
MS–DRG), or SHFFT (SHFFT MS–DRG)
and a 90-day period after discharge from
the anchor hospitalization. An EPM
quality-adjusted target price would
represent expected spending on all
related Part A and Part B items and
services furnished during EPM episodes
based on historical EPM episodes, and
would incorporate the EPM
participant’s effective discount factor for
the EPM performance year. Participants
that achieve actual EPM-episode
payments below the quality-adjusted
target price for a given performance year
may be eligible for a reconciliation
payment from CMS, subject to the
proposed stop-gain limit policy as
discussed in section III.D.7.b. of the
proposed rule (81 FR 50794).
Participants that achieve actual EPMepisode payments that exceed the
quality-adjusted target price for a given
performance year may be required to
repay Medicare a portion or all of the
excess EPM-episode spending.
We proposed an EPM composite
quality score methodology for linking
quality and payment in the EPMs that
is similar to that methodology finalized
for the CJR model (80 FR 73363 to
73381). Similar to the CJR model, the
EPM-specific composite quality score
methodology would allow both
performance and improvement on each
EPM’s required quality measure to be
meaningfully valued in the EPMs’ payfor-performance methodology,
incentivizing and rewarding cost
savings in relation to the quality of
episode care provided by the EPM
participant (80 FR 73374 and 73370).
Specifically, the EPM composite quality
score is made up of the composite
performance score (which includes both
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patient experience and outcome
measures, including points for
voluntarily reported measures) and an
improvement score.
We believe the actual level of quality
performance achieved should be most
highly valued in the EPM composite
quality score to reward those EPM
participants furnishing high quality care
to EPM beneficiaries, with a smaller
contribution to the EPM composite
quality score made by improvement
points if measure result improvement is
achieved. We acknowledge that
substantial improvement on a quality
measure result is not the sole indicator
that an EPM episode-of-care is high
quality; yet, the improvement spurred
by the hospital’s participation in the
EPM deserves to be valued as the EPM
participant’s performance is moving in
a direction that is good for the health of
beneficiaries. Like the CJR model, the
EPMs involve a wide range of
participants that must participate if they
are located in the selected MSAs, and
the participants would be starting from
many different current levels of quality
performance. We note that the Shared
Savings Program utilizes a similar
scoring and weighting methodology,
which is described in detail in the CY
2011 Shared Savings Program Final
Rule (see § 425.502). The HVBP Program
and the HACRP also utilize a similar
scoring methodology, which applies
weights to various measures and assigns
an overall score to a hospital (79 FR
50049 and 50102). Despite the small
number of quality measures proposed
for the EPMs, the measures represent
both clinical outcomes and patient
experience, and each carries substantial
value in the EPM composite quality
score.
Although performance and
improvement on each measure would be
valued in the EPM composite quality
score methodology, it is the EPM
participant’s overall quality
performance under the EPM that would
be considered in the pay-forperformance approach, rather than
performance on each quality measure
individually determining the financial
opportunity under the EPM. The EPM
composite score methodology also
provides a framework for incorporating
additional measures of meaningful
outcomes for EPM episodes in the
future. Finally, while we believe that
high performance on all of the quality
measures represents goals of clinical
care that should be achievable by all
EPM participants that heighten their
focus on these measures, we appreciate
that many participants have room for
significant improvement in their current
measure performance. The EPM
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composite score methodology would
provide the potential for financial
reward for more EPM participants that
reach overall acceptable or better quality
performance, thus incentivizing their
continued efforts to improve the quality
and efficiency of EPM episodes.
We sought comment on our proposal
to use an EPM-specific composite
quality score in the pay-for-performance
methodologies of the AMI, CABG, and
SHFFT models.
Final Decision: No comments were
received on the EPM-specific composite
quality score in the pay-for-performance
methodologies of the AMI, CABG, and
SHFFT models. Therefore, we are
finalizing the proposal, without
modification.
b. Determining Quality Measure
Performance
Similar to our reasoning in the CJR
model, we believe that relative measure
performance for the EPM measures
would be the most appropriate way to
incorporate quality performance into the
EPMs because we do not have sufficient
information about participant
performance to set and use an absolute
performance result on each measure (80
FR 73371). Moreover, we believe that
participants nationally are currently
working to improve their performance
on the quality measures proposed for
the EPMs on an ongoing basis as these
are included in other CMS programs
such as the HIQR and HVBP Programs.
Therefore, while we expect that EPM
participants would have a heightened
focus on performance on these measures
as a result of the financial incentives
resulting from the EPM payment
methodology, we are not yet certain
what performance outcomes can be
achieved under best practices.
Thus, at the time of reconciliation for
an EPM performance year, we proposed
to assign each EPM participant’s
measure point estimate from the most
recent year as discussed in section
III.E.5. of this final rule to a performance
percentile based on the national
distribution of measure results for
subsection (d) hospitals that are eligible
for payment under the IPPS reporting
the measure that meet the minimum
patient case or survey count. This
proposal applies to the MORT–30–AMI
(NQF #0230) and AMI Excess Days
measure results for the AMI model; the
MORT–30–CABG (NQF #2558) measure
result for the CABG model; the Hip/
Knee Complications (NQF #1550)
measure result for the SHFFT model;
and the HCAHPS Survey (NQF #0166)
measure result for all of the EPMs.
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359
The measure-specific parameters that
would apply to developing the national
distributions are displayed in Table 22.
TABLE 22—REQUIREMENTS FOR USE OF SUBSECTION (d) HOSPITALS THAT ARE ELIGIBLE FOR PAYMENT UNDER THE
IPPS MEASURE RESULTS IN DEVELOPING NATIONAL DISTRIBUTION OF REQUIRED MEASURES FOR EPMS
Measure
Requirements for use in national distribution
MORT–30–AMI (NQF #0230) ..................................................................
AMI Excess Days .....................................................................................
MORT–30–CABG (NQF #2558) ...............................................................
Hip/Knee Complications (NQF #1550) .....................................................
HCAHPS Survey (#0166) .........................................................................
We would assign any low volume
EPM participant without a reportable
value for the measure, new hospitals
that are identified as EPM participants,
or EPM participants where We have
suppressed the measure value due to an
error in the data used to calculate the
measure to the 50th performance
percentile of the measure result, so as
not to disadvantage an EPM participant
based on its low volume or lack of
applicable cases because that
participant may in actuality provide
high quality care. We believe that
relative measures of quality
performance are most appropriate for
the EPMs as participants continue to
make progress nationally on improving
patient outcomes and experience.
Proposed measure-specific assignment
of points in the EPMs’ composite quality
scores based on relative quality measure
performance are discussed in sections
III.E.3.e.(1), (2), and (3) of the proposed
rule (81 FR 50794).
We sought comment on our proposed
overall approach to determining quality
measure performance based on
assigning the EPM participant’s measure
point estimate to a measure performance
percentile based on the national
distribution of measure results from
subsection (d) hospitals eligible for
payment under the IPPS.
No comments were received on this
proposal so we are finalizing without
modification.
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c. Determining Quality Measure
Improvement
Consistent with our reasoning for the
CJR model, we believe it would be
important in the EPMs to directly
reward EPM participants for quality
improvement, similar to the pay-forperformance policies under other
programs such as the HVBP Program
and the Shared Savings Program, in
order to provide a significant incentive
for quality improvement for EPM
participants at all current levels of
quality performance (70 FR 73379). For
the CJR model, we adopted a refinement
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At
At
At
At
At
least
least
least
least
least
25 patient cases in the 3–year measure
25 patient cases in the 3–year measure
25 patient cases in the 3–year measure
25 patient cases in the 3–year measure
100 completed surveys in the 4–quarter
to the composite quality score
methodology that would supplement
the composite quality score’s valuing of
quality performance in the pay-forperformance methodology of the CJR
model (80 FR 73379). As in the CJR
model, we believe the heightened focus
on EPM episode cost and quality
performance by participants in the
EPMs may lead to substantial year-overyear quality measure improvement over
the EPM performance years.
Nevertheless, we believe that the actual
level of quality performance achieved in
the EPMs should be most highly valued
in the EPM composite quality score to
reward those participants furnishing
high-quality care to EPM beneficiaries,
with a small contribution to the
composite quality score made by
improvement points if measure result
improvement is achieved. Thus, we
proposed adding into the EPM-specific
composite quality score up to 10 percent
of the maximum value for each EPM
quality measure to which improvement
could apply (excluding the voluntary
data submission measures) for those
EPM participants that demonstrate
substantial improvement from the prior
year’s measure performance on that
measure (80 FR 73379 through 73380).
The maximum EPM composite quality
score would be capped at 20 points
under this proposal. Proposed measurespecific assignment of points for
improvement in the EPMs’ composite
quality scores are discussed in sections
III.E.3.e.(1), (2), and (3).
For the AMI and CABG models, we
proposed to define measure
improvement differently than in the CJR
model, using an approach that is more
similar to the methodologies of other
CMS programs such as the HVBP
Program. The CJR model defined
measure improvement for model
participants relative to a national
performance distribution (80 FR 73380).
In contrast, we proposed to define
measure improvement as any
improvement in an AMI or CABG model
participant’s own measure point
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performance period.
performance period.
performance period.
performance period.
reporting period.
estimate from the previous year,
regardless of the participant’s measure
point estimate starting and ending
values, if the AMI or CABG model
participant falls into the top 10 percent
of participants based on the national
distribution of measure improvement
over the 2 years for subsection (d)
hospitals that are eligible for payment
under the IPPS reporting the measure
that meet the minimum patient case or
survey count. We proposed this
approach because it represents the
greatest confidence that we are
capturing meaningful improvement on a
measure by an AMI or CABG model
participant in comparison with
performance changes of other hospitals
yet, unlike the CJR and proposed SHFFT
model methodologies, is founded on an
AMI or CABG model participant’s own
measure performance change from yearto-year. We believe that moving toward
incorporating a model participant’s own
measure performance improvement in
the pay-for-performance methodologies
for EPMs strengthens the incentives in
the models for quality improvement,
especially for EPM participants at the
lower end of current measure
performance.
For the SHFFT model, we proposed to
modify the definition of improvement
used in the CJR model in two ways (80
FR 73379 through 73380). First, we
proposed to define measure
improvement as improving 2 deciles or
more in comparison to the national
distribution of measure results from the
prior year, based on a comparison of
relative quality measure performance
over the most recent 2 years of available
quality measure result data. This is the
same methodology as finalized for the
CJR model, except that it reduces the
threshold for improvement from 3
deciles to 2 deciles in order to reward
a broader range of improvement.
Second, we proposed to award up to 10
percent of the maximum measure
performance score on the outcome and
patient experience measures described
in III.E.3.e.(3) of the proposed rule (81
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FR 50794), with a cap of the SHFFT
model composite quality score at 20
points. This alters the CJR model
methodology, which calculates the
measure performance score, voluntary
reporting points, and measure
improvement score separately for a total
potential maximum score of 22. Taken
together, these two changes bring
calculation of the SHFFT model
composite quality score into greater
alignment with existing CMS programs,
such as the HVBP Program, by
expanding the number of SHFFT model
participants eligible for quality
improvement points but reducing the
number of participants who receive both
the highest quality performance score
on a measure and points for measure
improvement simultaneously.
In section V.E. of the proposed rule
(81 FR 50794), we proposed changes to
the CJR model composite quality score
calculation consistent with the SHFFT
model methodology described here,
allowing use of the same definition of
quality improvement for the SHFFT and
CJR models, because these models
would be tested in mostly the same
hospitals. We believe this approach
would provide SHFFT model
participants at all current levels of
quality performance, including those
historically lagging, with significant
incentives to achieve improvement
quality of care under the SHFFT model.
Using a common approach to measuring
quality improvement for the SHFFT and
CJR models would provide a single
participant-level composite quality
score that can be applied at
reconciliation for each model to
determine the payment policies that
would apply to the participant for the
CJR and SHFFT model episodes, taking
into consideration the different model
performance years.
The proposals to determine quality
measure improvement for the AMI,
CABG, and SHFFT models are included
in § 512.315(b)(3), (c)(3), and (d)(3),
respectively. We sought comment on
our proposals to determine quality
measure improvement for the AMI,
CABG, and SHFFT models.
The following is a summary of the
comments received and our responses.
Comment: A few commenters
expressed concern that the
improvement thresholds are
inappropriate, and are not feasible to
allow a hospital to earn improvement
points. Commenters suggested the CMS
consider a scoring methodology similar
to the Hospital Value Based Purchasing
scoring methodology in this model.
Response: We appreciate the concern
regarding measuring improvement
under the model. We did not propose to
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use the HBVP methodology that assigns
either improvement or performance
points to quality measures. We believe
the actual level of quality performance
achieved should be most highly valued
in the EPM composite quality score to
reward those EPM participants
furnishing high quality care to EPM
beneficiaries, with a smaller
contribution to the EPM composite
quality score made by improvement
points if measure result improvement is
achieved. We acknowledge that
substantial improvement on a quality
measure result is not the sole indicator
that an EPM episode-of-care is high
quality; yet, the improvement spurred
by the hospital’s participation in the
EPM deserves to be valued as the EPM
participant’s performance is moving in
a direction that is good for the health of
beneficiaries. Thus, the EPM
methodology, in comparison with
HVBP, provides improvement points as
a bonus on top of performance points.
We believe improvement points should
be awarded only when meaningful
improvement is achieved and hospitals
will be able to receive improvement
points when they achieve meaningful
improvement performance For example,
if the AMI or CABG model participant
falls into the top 10 percent of
participants based on the national
distribution of measure improvement
over the 2 years for subsection (d)
hospitals that are eligible for payment
under the IPPS reporting the measure
that meet the minimum patient case or
survey count. We propose this approach
because it represents the greatest
confidence that we are capturing
meaningful improvement on a measure
by an AMI or CABG model participant
in comparison with performance
changes of other hospitals yet, unlike
the CJR and proposed SHFFT model
methodologies, is founded on an AMI or
CABG model participant’s own measure
performance change from year-to-year.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal, without
modification to methodology to
determine quality measure
improvement for AMI, CABG and
SHFFT models.
d. Determining Successful Submission
of Voluntary Data for AMI and SHFFT
Models
(1) Hybrid AMI Mortality (NQF #2473)
Voluntary Data
Similar to the CJR model, we
proposed that AMI model participants
that successfully submit the Hybrid AMI
Mortality (NQF #2473) measure
voluntary data would be eligible for
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points in the AMI model composite
quality score (80 FR 73375, 73381).
Encouraging collection and submission
of the Hybrid AMI Mortality (NQF
#2473) measure voluntary data through
the AMI model would increase hospital
familiarity with submitting hybrid
quality measures based on claims data
and data submitted from electronic
health records; further develop an
outcome measure that provides
meaningful information on outcomes for
AMI hospitalizations that are commonly
experienced by Medicare beneficiaries;
provide another quality measure that
may be incorporated into the AMI
model pay-for-performance
methodology in future years, pending
successful implementation testing of the
measure; and inform the quality strategy
of future payment models.
The proposed requirements for
determining successful submission of
Hybrid AMI Mortality (NQF #2473)
measure voluntary data are included in
§ 512.411(b)(2) and discussed in detail
in section III.E.4.a.(3)(vii) of the
proposed rule (81 FR 50794). We sought
comment on our proposals for
determining successful submission of
voluntary data for each AMI model
performance year.
Final Decision: No comments were
received on this proposal. Therefore we
are finalizing the proposal, without
modification.
(2) Patient-Reported Outcomes and
Limited Risk Variable Voluntary Data
Following Elective Primary THA/TKA
Like the CJR model, we proposed that
SHFFT model participants that
successfully submit Patient-reported
outcomes and limited risk variable
voluntary data following elective
primary THA/TKA be eligible for points
in the SHFFT model composite quality
score (80 FR 73375, 73381). We note
that SHFFT model participants that are
also participating in the CJR model
would not need to submit data twice to
satisfy the successful submission
requirements of both models. If those
hospitals successfully submit voluntary
data for the CJR model they would be
credited with successful submission
under the SHFFT model.
The proposed requirements for
determining successful submission of
Patient-reported outcomes and limited
risk variable voluntary data following
elective primary THA/TKA are included
in § 512.13(b)(2) and discussed in detail
in section III.E.4.c.(2)(viii) of the
proposed rule (81 FR 50794). We sought
comment on our proposals for
determining successful submission of
voluntary data for each SHFFT model
performance year.
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Final Decision: No comments were
received on this proposal. Therefore we
are finalizing the proposal without
modification.
e. Calculation of the EPM-Specific
Composite Quality Score
(1) AMI Model Composite Quality Score
We proposed to assign each
participant an AMI model composite
quality score, calculated as the sum of
quality score. Each quality measure
performance would be assigned a
weight in the AMI model composite
quality score, and possible scores for the
measures would be set to reflect those
weights. We would weight AMI model
participant performance on each of the
three required measures and successful
submission of Hybrid AMI Mortality
(NQF #2473) voluntary data according
to the measure weights displayed in
Table 23.
the individual quality measure
performance scores (including
successful submission of Hybrid AMI
Mortality (NQF #2473) measure
voluntary data if applicable) and
improvement scores. The quality
measure performance scores would be
set to reflect the intended weights for
each of the quality measures and the
successful submission of the Hybrid
AMI Mortality (NQF #2473) voluntary
data in the AMI model composite
TABLE 23—MEASURES AND ASSOCIATED PERFORMANCE WEIGHTS IN AMI MODEL COMPOSITE QUALITY SCORE
Weight in
composite
quality score
(%)
Quality measure
MORT–30–AMI (NQF #0230) .........................................................................
AMI Excess Days ...........................................................................................
Hybrid AMI Mortality (NQF #2473) Voluntary Data ........................................
HCAHPS Survey (NQF #0166) ......................................................................
We would assign the lowest weight of
10 percent to the submission of Hybrid
AMI Mortality (NQF #2473) measure
voluntary data because these data
represent an AMI model participant’s
meaningful participation in advancing
the quality measurement of AMI
outcomes in keeping with our goal to
move toward the use of electronic
health records (EHRs) for measures, and
in response to stakeholder feedback to
include clinical data in outcome
measures. Given the importance of AMI
mortality as an extremely serious AMI
outcome, we proposed to assign the
highest individual measure weight of 50
percent to the MORT–30–AMI (NQF
#0230) measure. We proposed to assign
another 20 percent of the weight to the
AMI Excess Days measure that is also
included in the outcome quality
domain. The remaining 20 percent of
the AMI model composite quality score
weight would be assigned to the
HCAHPS Survey (NQF #0166) measure
because we believe that incorporating
this quality measure, which reflects
performance regarding patients’
perspectives on care, including
50
20
10
20
Quality domain/weight
Outcome/80%.
Patient Experience/20%.
communication, care transitions, and
discharge information, is a meaningful
patient experience measure of AMI
model episode quality. This proposal of
weights for the outcome and patient
experience quality domains for the AMI
model composite quality score is similar
to the proposal of weights for the CABG
model composite quality score
described later in this section. We
would assign the highest overall weight
to the outcome quality domain
(consisting of two measures and
voluntary data submission) because the
measures in this quality domain are
specific to meaningful outcomes for
AMI model beneficiaries. We did not
propose to assign the HCAHPS survey
(NQF #0166) measure the highest
weight of the quality and patient
experience domains, as the measure is
not specific to AMI model episodes, but
rather to all clinical conditions treated
by AMI model participants. Unlike the
CJR model where the quality measure
weights in the CJR model composite
quality score relatively evenly balance
the outcome and patient experience
quality domains, we would assign the
highest weight in the AMI model to the
outcome quality domain (consisting of
two measures and voluntary data
submission) because the measures in
this quality domain are specific to
meaningful, serious outcomes for AMI
model beneficiaries, especially mortality
which is not an outcome measure used
in the CJR model composite quality
score (80 FR 73375).
Under such an approach, we would
first score individually each AMI model
participant on the MORT–30–AMI (NQF
#0230) measure; AMI Excess Days
measure; and HCAHPS Survey (NQF
#0166) measure based on the AMI
model participant’s performance
percentile as compared to the national
distribution of subsection (d) hospitals
that are eligible for payment under the
IPPS measure performance, assigning
scores according to the point values
displayed in Table 24. These individual
measure scores have been set to reflect
the measure weights included in Table
23 so they can ultimately be summed
without adjustment in calculating the
AMI model composite quality score.
TABLE 24—INDIVIDUAL MEASURE PERFORMANCE SCORING FOR THREE REQUIRED AMI QUALITY MEASURES
MORT–30–
AMI
(points)
asabaliauskas on DSK3SPTVN1PROD with RULES
Performance percentile
≥90th ............................................................................................................................................
≥80th and <90th ...........................................................................................................................
≥70th and <80th ...........................................................................................................................
≥60th and <70th ...........................................................................................................................
≥50th and <60th ...........................................................................................................................
≥40th and <50th ...........................................................................................................................
≥30th and <40th ...........................................................................................................................
<30th ............................................................................................................................................
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10.00
9.25
8.50
7.75
7.00
6.25
5.50
0.00
03JAR2
AMI excess
days
(points)
4.00
3.70
3.40
3.10
2.80
2.50
2.20
0.00
HCAHPS
survey
(points)
4.00
3.70
3.40
3.10
2.80
2.50
2.20
0.00
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Given the current national
distribution of subsection (d) hospitals
eligible for payment under the IPPS
performance on these measures, we
believe that small point increments
related to higher measure performance
deciles would be the most appropriate
way to assign more points to reflect
meaningfully higher quality
performance on the measures. The
absolute differences for each decile
among the three measures reflect the
intended weight of the measure in the
AMI model composite quality score.
These three measures are wellestablished measures in use under CMS
hospital programs, so we do not believe
that scores below the 30th percentile
reflect quality performance such that
they should be assigned any individual
quality measure score points under the
AMI model.
Additionally, we would assign a
measure quality score of 2 points for
AMI model participants that
successfully submit Hybrid AMI
Mortality (NQF #2473) measure
voluntary data and 0 points for
participants that do not successfully
submit these data. Because we would
not use the actual Hybrid AMI Mortality
(NQF #2473) measure result as an
outcome measure in assessing AMI
episode quality performance under the
AMI model, we proposed this
straightforward binary approach to
scoring the submission of Hybrid AMI
Mortality (NQF #2473) measure
voluntary data for hybrid outcome
measure testing.
CMS may, in future regulations,
require hospitals to report additional
data elements from EHRs and proposed
additional hybrid measures in this and
other models and programs, such as the
HIQR Program. If, in future regulations,
hospitals are required to report these
same five data elements (age; heart rate;
systolic blood pressure; troponin,
creatinine) and six linking variables
(CMS Certification Number (CCN),
Medicare Health Insurance Claim (HIC)
Number, date of birth, sex, admission
date, and discharge date) that are
included in the Hybrid AMI Mortality
(NQF #2473) measure to support
measurement through another CMS
program, such as the HIQR Program,
CMS may propose changes to the AMI
model measures and the methodology
for assigning the AMI model composite
quality score.
Finally, we would award
improvement scores on a measure-bymeasure basis to those AMI model
participants that demonstrate
improvement on the measure;
improvement points would be awarded
for up to 10 percent of the maximum
measure performance points available,
with the total AMI model composite
quality score capped at 20. Thus,
improvement scores would be up to 1.0
points for the MORT–30–AMI (NQF
#0230) measure; up to 0.4 points for the
AMI Excess Days measure; and up to 0.4
points for the HCAHPS Survey (NQF
#0166) measure.
We would sum the performance and
improvement scores on the three quality
measures and the score on successful
submission of Hybrid AMI Mortality
(NQF #2473) measure voluntary data to
calculate an AMI composite quality
score for each AMI model participant.
The proposal for the methodology to
calculate the AMI model composite
quality score is included in
§ 512.315(b)(1)–(4). We sought comment
on our proposed methodology to
calculate the AMI model composite
quality score.
The following is a summary of the
comments received and our responses.
Comment: A group of commenters
believe the 30 Day Mortality measure is
weighted too heavily under the
proposed model. Several commenters
expressed concern that this measure
will not accurately measure quality of
care across the proposed 90-day episode
of care and therefore should not be
weighted so heavily.
Response: We appreciate the
comments regarding the heavy
weighting that was proposed for the 30Day Mortality measure. Mortality is a
very serious outcome for AMI care and
is one that model participants should
manage to avoid. We have chosen to
weight this measure so heavily because
there at not many measures that will
accurately measure quality for the EPM
model. The mortality measure will
assess a specific serious outcomes for
these episodes, therefore we proposed
high weights for this measure in the
scoring methodology.
Comment: Several commenters
expressed concerned that HCAHPS are
inappropriate and misaligned quality
metric for this model. Several
commenters have stated that this
measure is hospital centric and will not
address the patient experience of care
for the entire episode therefore
weighting this measure in the scoring
methodology is an inappropriate
approach to hold participants
accountable for the overall beneficiary
satisfaction during an episode. There is
a general consensus that these measures
are poorly aligned with the proposed
cohorts.
Response: We appreciate the concern
that the use of HCAHPS may not
accurately assess patient satisfaction
and quality related to the model
specifically. However we have proposed
the use of this instrument to access the
patient satisfaction under the model as
a readily available instrument to assess
quality of care for patients. We will
include the HCAHPS survey measure
instrument until other alternative
measures are available.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal, without
modification to the AMI composite
quality scoring methodology.
(2) CABG Model Composite Quality
Score
We proposed to assign each
participant a CABG model composite
quality score, calculated as the sum of
the individual quality measure
performance and improvement scores.
The quality measure performance scores
would be set to reflect the intended
weights for each of the quality
measures. Each quality measure
performance would be assigned a
weight in the CABG model composite
quality score and possible scores for the
measures would be set to reflect those
weights. We would weight CABG model
participant performance on each of the
two required measures according to the
measure weights displayed in Table 25.
asabaliauskas on DSK3SPTVN1PROD with RULES
TABLE 25—MEASURES AND ASSOCIATED PERFORMANCE WEIGHTS IN CABG MODEL COMPOSITE QUALITY SCORE
Weight in
composite
quality score
(%)
Quality measure
MORT–30–CABG (NQF #2558) .....................................................................
HCAHPS Survey (NQF #0166) ......................................................................
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75
25
Quality domain/weight
Outcome/75%.
Patient Experience/25%.
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We proposed to assign 75 percent of
the weight in the CABG model
composite quality score to the outcome
quality domain, assigning all weight to
the MORT–30–CABG (NQF #2558)
measure, and the remaining 25 percent
of the CABG model composite quality
score weight to the HCAHPS Survey
(NQF #0166) measure representing the
patient experience quality domain. This
proposal of weights for the outcome and
patient experience quality domains for
the CABG model composite quality
score is similar to the proposal of
weights for the AMI model composite
quality score described previously in
this section. CABG mortality is an
extremely serious outcome and, like our
proposal for the Mort–30–AMI (NQF
#230) measure in the AMI model
composite quality score, we proposed
that the MORT–30–CABG (NQF #2558)
measure would have the highest
individual measure weight in the CABG
model composite quality score. We
would assign 25 percent of the weight
to the HCAHPS survey measure (NQF
#0166) because we believe that
incorporating this quality measure,
which reflects performance regarding
patients’ perspectives on care, including
communication, care transitions, and
discharge information, is a meaningful
patient experience measure of CABG
model episode quality. We would assign
the highest overall weight to the
outcome quality domain (consisting of
one measure) because it is specific to
meaningful outcomes for CABG surgery
for CABG model beneficiaries. We did
not propose to assign the HCAHPS
survey (NQF #0166) measure the highest
weight of the quality and patient
experience quality domains, as the
measure is not specific to CABG model
episodes, but rather to all clinical
conditions treated by CABG model
participants. Unlike the CJR model
where the measure weights in the CJR
model composite quality score relatively
363
evenly balance the outcome and patient
experience quality domains, CABG
mortality representing the outcome
quality domain is a serious outcome
specific to CABG model beneficiaries
such that we believe it deserves a high
weight in the proposed CABG model
composite quality score (80 FR 73375).
Under such an approach, we would
first score individually each CABG
model participant on the MORT–30–
CABG (NQF #2558) measure; and
HCAHPS Survey (NQF #0166) measure
based on the participant’s performance
percentile as compared to the national
distribution of subsection (d) hospitals
that are eligible for payment under the
IPPS measure performance, assigning
scores according to the point values
displayed in Table 26. These individual
measure scores have been set to reflect
the measure weights included in Table
25 so they can ultimately be summed
without adjustment in calculating the
CABG model composite quality score.
TABLE 26—INDIVIDUAL SCORING FOR TWO REQUIRED CABG QUALITY MEASURES
MORT–30–
CABG
(points)
Performance percentile
asabaliauskas on DSK3SPTVN1PROD with RULES
≥90th ........................................................................................................................................................................
≥80th and <90th ......................................................................................................................................................
≥70th and <80th ......................................................................................................................................................
≥60th and <70th ......................................................................................................................................................
≥50th and <60th ......................................................................................................................................................
≥40th and <50th ......................................................................................................................................................
≥30th and <40th ......................................................................................................................................................
<30th ........................................................................................................................................................................
Given the current national
distribution of subsection (d) hospitals
that are eligible for payment under the
IPPS performance on these measures,
we believe that small point increments
related to higher measure performance
deciles would be the most appropriate
way to assign more points to reflect
meaningfully higher quality
performance on the measures. The
absolute differences for each decile
among the two measures reflect the
intended weight of the measure in the
CABG model composite quality score.
These two measures are wellestablished measures in use under CMS
hospital programs, so we do not believe
that scores below the 30th percentile
reflect quality performance such that
they should be assigned any individual
quality measure score points under the
CABG model.
Finally, we would award
improvement scores on a measure-bymeasure basis to those CABG model
participants that demonstrate
improvement on the measure;
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improvement points would be awarded
for up to 10 percent of the maximum
measure performance points available,
with the total CABG model composite
quality score capped at 20. Thus,
improvement scores would be up to 1.5
points for the MORT–30–CABG (NQF
#2558) measure; and up to 0.5 points for
the HCAHPS Survey (NQF #0166)
measure.
We would sum the performance and
improvement scores on the two quality
measures to calculate a CABG model
composite quality score for each CABG
model participant.
The proposal for the methodology to
calculate the CABG model composite
quality score is included in
§ 512.315(c)(1) through (4). We sought
comment on our proposed methodology
to calculate the CABG model composite
quality score.
The following is a summary of the
comments received and our responses.
Comment: A group of commenters
believe the 30 Day Mortality measure is
weighted too heavily under the
proposed model. Several commenters
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15.00
13.88
12.75
11.63
10.50
9.38
8.25
0.00
HCAHPS
survey
(points)
5.00
4.63
4.25
3.88
3.50
3.13
2.75
0.00
expressed concern that this measure
will not accurately measure quality of
care across the proposed 90-day episode
of care and therefore should not be
weighted so heavily. Several
commenters expressed concern about
the proposed weighting of the MORT–
30–CABG at 50 percent pf the composite
quality score because the high weight
assigned to the (RSMR) 30 day-mortality
rate could encourage inappropriate
treatment such as total revascularization
even when not clinically indicated at
the time of the acute event.
Response: We appreciate the
comments regarding the heavy
weighting that was proposed for the 30Day Mortality measure. Mortality is a
very serious outcome for CABG care and
is one that model participants should
manage to avoid. We have chosen to
weight this measure so heavily because
there at not many measures that will
accurately measure quality for the EPM
model. The mortality measure will
assess a specific serious outcomes for
these episodes, therefore we proposed
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high weights for this measure in the
scoring methodology. We do not believe
the use of this measure will lead to
inappropriate treatment and intend to
monitor for such activities under the
model. However, we note that we will
be making a slight downward
adjustment in the weight this measure
carries, from 75 percent to 70 percent in
response to comments asking us to
incorporate the STS composite CABG
measure in our CABG model.
Comment: Several commenters
expressed that the use of HCAHPS is
inappropriate in the model and
recommended removal of these
measures. These is concern that the
HCAHP scores reflect an entire patient
population and not just those included
in the EPM episodes specifically. There
is also concern that HCAHPS fail to
address several important aspects of the
EPM episode, and instead focus on
aspects of care that not are germane to
the episode like ‘‘quietness’’ of a
hospital for example. Commenters
believe the use of these measures and
weighting of the measures for this
model is inappropriate and a misaligned
approach to linking quality of care to
payment under the model.
Response: We appreciate the concerns
regarding HCAHPS and as mentioned in
the proposed rule recognizes the
misalignment of measures that exists for
the patient population and cohort under
the model. However, there are limited
instruments available to measure patient
experience available at this time. We
have chosen to rely on these metrics to
assess patient satisfaction under the
model. The HCAHPS are a reliable set
of metrics widely accepted to
adequately measure patient experience.
However, we note that we will be
making a slight downward adjustment
in the weight this measure carries, from
25 percent to 20: Percent in response to
comments asking us to incorporate the
STS composite CABG measure in our
CABG model.
Comment: A group of commenters
recommended that the STS measure set
be included in the CABG measure set as
a comprehensive set of measures
currently utilized by several providers
to access the quality of care for patients.
Response: We appreciate the feedback
regarding the inclusion of the STS
measures into the CABG model to offer
a more comprehensive measure set. As
a result the CABG quality composite
score will be revised to include these
measures be reported as a voluntary
measures. Following our standing
policy for CJR and for the other models
in this final rule, voluntary measures are
set to a composite score weight of 10
percent. Since we had previously
allocated 100 percent of the composite
weight over the two proposed measures,
to be responsive to these comments we
also need to adjust the proposed
weighting for the mortality and
HCAHPS measures. The revised
weighting for the CABG measures is
shown in the following revised tables 27
and 28:
TABLE 27—MEASURES AND ASSOCIATED PERFORMANCE WEIGHTS IN CABG MODEL COMPOSITE QUALITY SCORE
Weight in
composite
quality score
(%)
Quality measure
MORT–30–CABG (NQF #2558) .....................................................................
STS Composite CABG voluntary data submission (NQF #0696) ..................
HCAHPS Survey (NQF #0166) ......................................................................
70
10
20
Quality domain/weight
Outcome/80%.
Patient Experience/20%.
TABLE 28—INDIVIDUAL SCORING FOR TWO REQUIRED CABG QUALITY MEASURES
MORT–30–
CABG
(points)
Performance percentile
≥90th ........................................................................................................................................................................
≥80th and <90th ......................................................................................................................................................
≥70th and <80th ......................................................................................................................................................
≥60th and <70th ......................................................................................................................................................
≥50th and <60th ......................................................................................................................................................
≥40th and <50th ......................................................................................................................................................
≥30th and <40th ......................................................................................................................................................
<30th ........................................................................................................................................................................
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Final Decision: After consideration of
the public comments received, we are
finalizing the proposal, with
modification, to include the STS
measures as voluntary measures with
the revised weights displayed in Tables
27 and 28.
(3) SHFFT Model Composite Quality
Score
We proposed to adopt the same
calculation of the SHFFT model
composite quality score as the CJR
model, including the proposed changes
to the CJR model composite quality
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score methodology described in section
V.E. of the proposed rule (81 FR 50794).
For those participants in both SHFFT
and CJR models, the SHFFT model
composite quality score calculated each
year would be the same as the CJR
model composite quality score (80 FR
73370 through 73381). We proposed to
assign each SHFFT model participant a
SHFFT model composite quality score,
capped at 20 points and calculated as
the sum of the individual quality
measure and improvement scores as
well as successful submission of THA/
TKA voluntary PRO and limited risk
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14
12.95
11.90
10.85
9.80
8.75
7.70
0
HCAHPS
survey
(points)
4
3.7
3.4
3.1
2.8
2.5
2.2
0
variable data if applicable. The quality
measure performance scores would be
set to reflect the intended weights for
each of the quality measures. Each
quality measure performance would be
assigned a weight in the SHFFT model
composite quality score and possible
scores for the measures would be set to
reflect those weights. We would weight
SHFFT model participant performance
on each of the two required measures
and successful submission of THA/TKA
voluntary PRO and limited risk variable
data according to the measure weights
displayed in Table 41.
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TABLE 29—MEASURES AND ASSOCIATED PERFORMANCE WEIGHTS IN SHFFT MODEL COMPOSITE QUALITY SCORE
Weight in
composite
quality score
(%)
Quality measure
Hip/Knee Complications (NQF #1550 ............................................................
THA/TKA voluntary PRO and limited risk variable submission .....................
HCAHPS Survey (NQF #0166) ......................................................................
Consistent with the CJR model, we
proposed to assign 50 percent of the
weight in the SHFFT model composite
quality score to the outcome quality
domain, assigning 50 percent of the
weight to the Hip/Knee Complications
(NQF #1550) measure. We proposed to
assign 50 percent of the weight to the
patient experience quality domain,
specifically 10 percent of the weight in
that quality domain to the THA/TKA
voluntary PRO and limited risk variable
submission. We would assign 40
percent of the weight to the HCAHPS
survey measure (NQF #0166)
representing the patient experience (80
FR 73375). We would assign 40 percent
to the HCAHPS survey measure (NQF
#0166) because we believe that
incorporating this quality measure,
50
10
40
Quality domain/weight
Outcome/50%.
Patient Experience/50%.
which reflects performance regarding
patients’ perspectives on care, including
communication, care transitions, and
discharge information, is a highly
meaningful outcome measure of SHFFT
episode quality under the SHFFT
model, and because doing so ensures
that there is a consistent methodology
for linking quality performance and
improvement to payment for SHFFT
model participants that are also
participating in the CJR model. As in the
CJR model, we believe this weighting
appropriately balances patient
experience with meaningful health
outcomes for beneficiaries (80 FR
73375).
Under such an approach, we would
first score individually each SHFFT
model participant on the Hip/Knee
Complications (NQF #1550) measure;
and HCAHPS Survey (NQF #0166)
measure based on the participant’s
performance percentile as compared to
the national distribution of subsection
(d) hospitals that are eligible for
payment under the IPPS measure
performance, assigning scores according
to the point values displayed in Table
30. These individual measure scores
have been set to reflect the measure
weights included in Table 29 so they
can ultimately be summed without
adjustment in calculating the SHFFT
model composite quality score. We note
that the point score for each decile for
the two measures for the SHFFT model
is the same as that used for other CJR
model.
TABLE 30—INDIVIDUAL SCORING FOR TWO REQUIRED SHFFT QUALITY MEASURES
Hip/Knee
complications
(points)
Performance percentile
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≥90th ........................................................................................................................................................................
≥80th and <90th ......................................................................................................................................................
≥70th and <80th ......................................................................................................................................................
≥60th and <70th ......................................................................................................................................................
≥50th and <60th ......................................................................................................................................................
≥40th and <50th ......................................................................................................................................................
≥30th and <40th ......................................................................................................................................................
<30th ........................................................................................................................................................................
Given the current national
distribution of subsection (d) hospitals
that are eligible for payment under the
IPPS performance on these measures,
we believe that small point increments
related to higher measure performance
deciles would be the most appropriate
way to assign more points to reflect
meaningfully higher quality
performance on the measures. The
absolute differences for each decile
among the three measures reflect the
intended weight of the measure in the
SHFFT model composite quality score.
These two measures are wellestablished measures in use under CMS
hospital programs, so we do not believe
that scores below the 30th percentile
reflect quality performance such that
they should be assigned any individual
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quality measure score points under the
SHFFT model.
As in the CJR model, we proposed to
assign a measure quality score of 2
points for SHFFT model participants
that successfully submit THA/TKA
voluntary PRO and limited risk variable
data and 0 points for participants that
do not successfully submit these data
(80 FR 73376).
Finally, we would award
improvement scores on a measure-bymeasure basis to those SHFFT model
participants that demonstrate
improvement on the measure (defined
as year-over-year improvement of 2 or
more deciles in the performance
distribution); improvement points
would be awarded for up to 10 percent
of the maximum measure performance
points available, with the total SHFFT
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10.00
9.25
8.50
7.75
7.00
6.25
5.50
0.00
HCAHPS
survey quality
score
(points)
8.00
7.40
6.80
6.20
5.60
5.00
4.40
0.00
model composite quality score capped
at 20. Thus, improvement scores would
be up to 1.0 points for the Hip/Knee
Complications (NQF #1550) measure;
and up to 0.8 points for the HCAHPS
Survey (NQF #0166) measure.
We would sum the performance and
improvement scores on the two required
quality measures and the score on
successful submission of THA/TKA
voluntary PRO and limited risk variable
data to calculate a SHFFT model
composite quality score for each SHFFT
model participant. For those CJR model
participants (the majority of SHFFT
model participants), the SHFFT model
composite quality score would be the
same as the participant’s score for the
CJR model.
The proposal for the methodology to
calculate the SHFFT model composite
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quality score is included in
§ 512.315(d)(1) through (4). We sought
comment on our proposed methodology
to calculate the SHFFT model
composite quality score.
The following is a summary of the
comments received and our responses.
Comment: Several commenters
expressed that the use of HCAHPS is
inappropriate in the model and
recommended removal of these
measures. These is concern that the
HCAHP scores reflect an entire patient
population and not just those included
in the EPM episodes specifically. There
is also concern that HCAHPS fail to
address several important aspects of the
EPM episode, and instead focus on
aspects of care that not germane to the
episode like ‘‘quietness’’ of a hospital
for example. Commenters believe the
use of these measures and weighting of
the measures for this model is
inappropriate and a misaligned
approach to linking quality of care to
payment under the model.
Response: We appreciate the concerns
regarding HCAHPS and as mentioned in
the proposed rule recognizes the
misalignment of measures that exists for
the patient population and cohort under
the model. However, there are limited
instruments available to measure patient
experience available at this time. We
have chosen to rely on these metrics to
assess patient satisfaction under the
model. The HCAHPS are a reliable set
of metrics widely accepted to
adequately measure patient experience.
Comment: Several commenters urged
CMS to use the CJR composite scoring
methodology.
Response: We appreciate the support
for utilizing the CJR composite scoring
methodology in the SHFFT model as
proposed. We believe the SHFFT model
composite scoring methodology
accurately reflects the quality measures
that will be assessed under the model.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal, without
modification.
f. EPM Pay-for-Performance
Methodologies to Link Quality and
Payment
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(1) Overview of Pay-for-Performance
Proposals Applicable to the EPMs
As in the CJR model, we proposed
that the maximum effective discount
factor for all EPM participants that
could be incorporated in qualityadjusted target prices would be 3.0
percent (80 FR 733760). We refer to
section III.D.4.b.(10) of this final rule for
further discussion of the application of
the effective discount factor to EPM-
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episode benchmark prices in calculating
quality-adjusted target prices. EPM
participants that provide high-quality
episode care would have the
opportunity to reduce the effective
discount factor used to calculate their
quality-adjusted prices at reconciliation.
The effective discount factors are
displayed in tables in the following
EPM-specific sections, based on the
EPM-specific composite quality score
that would place each EPM participant
into one of four quality categories,
specifically ‘‘Below Acceptable,’’
‘‘Acceptable,’’ ‘‘Good,’’ and ‘‘Excellent,’’
for each EPM performance year. Three
tables are required to display the
proposed effective discount factor and
applicable discount factor (the discount
factor that represents the phase-in of
repayment responsibility in
performance years 2 (DR) and 3) for
each quality category due to the phasein of EPM participant repayment
responsibility from no responsibility in
performance year 1 and performance
year 2 (NDR), to partial responsibility in
performance years 2 (DR) and 3, and
finally full responsibility in
performance years 4 and 5 as discussed
in section III.D.2.c. Note that the
applicable discount factor only applies
to EPM performance years 2 (DR) and 3.
The following is a summary of the
comments received and our responses.
Comment: A commenter suggests that
CMS heavily skew the point
distributions for the models so that the
majority of the hospitals fall into the
‘‘good’’ category of performance. There
is concern that the disparity between
excellent and good would be great
across the model using the proposed
methodology. Commenters believe the
bar for achieving ‘‘excellent’’ care is set
too high and strongly recommended that
threshold be lowered to allow for more
hospitals to be placed into the
‘‘excellent’’ category under the three
models. Lowering the ‘‘excellent’’
threshold would correctly recognize
additional institutions that are
achieving high levels of quality of care
for their patients.
Response: We disagree with the
commenters that the bar for achieving
excellent care is set too high. In
modeling the score ranges for the
different improvement categories, we
are assuming that the majority of model
participants will score within the ’good’
category. We have proposed to award up
to 10 percent of the maximum measure
points available and believe that the
standard for providing excellent quality
of care should be high.
Comment: A commenter supports
CMS’s stated belief that the EPM models
should use the pay for performance
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methodologies that simultaneously
reward improvement in patient
outcomes and lower health care
spending. The commenter supports the
proposal to pay on a quality first
principle: Only sharing saving with
hospitals that achieve quality scores
above the 30th percentile and weighting
the discount percentage based on
quality performance.
Response: We acknowledge and
appreciate your support for the payment
methodology and quality driven focus of
this model. CMS is committed to linking
payments to the quality of care
delivered across this model.
Comment: A commenter urged CMS
to explore a reward for higher quality,
and consider paying bonuses to
hospitals which improve quality while
keeping costs stable. Under the
proposed model there is no reward for
a hospital that achieves better outcomes
for its patients at the same cost. Under
the proposed model, quality
measurement only comes into play as a
punitive measure. If spending is the
same but quality is higher, there is no
bonus.
Response: The basic design of the
EPMs requires savings to Medicare first,
before any payment would be made to
EPM participants for future savings
Thus, the payments to EPM participants
are not ‘‘bonus’’ Payments to
participants may vary based on episode
quality. Quality is not used as a
‘‘punitive’’ measure but, rather,
improved quality allows EPM
participants to receive a higher amount
of their savings achieved. No payment is
made to any EPM participant under the
design when there are no measurable
savings to the Medicare program.
Rewarding hospitals who achieve higher
quality at the same cost is not within the
scope of this model or the intent.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal, without
modification.
(2) AMI and CABG Model Pay-forPerformance Methodologies
(a) AMI Model Pay-for-Performance
Methodology
We proposed to incorporate the AMI
model composite quality score in the
AMI model payment methodology by (1)
requiring a minimum AMI model
composite quality score for
reconciliation payment eligibility if the
AMI model participant’s actual episode
payments are less than the qualityadjusted target price and (2)
determining the effective discount factor
included in the quality-adjusted target
price experienced by the AMI model
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participant in the reconciliation process.
The payment policies we would apply
are displayed in Tables 31, 32, and 33
for the performance years of the AMI
model. Under the AMI model as
proposed, there is no AMI model
participant repayment responsibility in
performance year 1 and performance
year 2 (NDR) and this responsibility
begins to be phased-in in performance
year 2 (DR), with full implementation in
performance year 4. Because repayment
responsibility is phased-in, in
performance years 2 (DR) and 3,
repayment responsibility only applies to
a portion of the amount of excess AMI
model episode spending that results
from the quality-adjusted target prices
that include the AMI model
participant’s effective discount factor.
We, therefore, refer in the repayment
column to the applicable discount factor
for repayment amount in performance
years 2 (DR) and 3. The effective
discount factor applies to both the
reconciliation payment and the
repayment amount in performance years
4 and 5. We note that the average
Medicare payment for historical AMI
episodes beginning in CYs 2012 to 2014
was $24,200.91
TABLE 31—PERFORMANCE YEAR 1 (ALL PARTICIPANTS) AND PERFORMANCE YEAR 2 (FOR PARTICIPANTS WHO DO NOT
ELECT EARLY DOWNSIDE RISK): RELATIONSHIP OF AMI MODEL COMPOSITE QUALITY SCORE TO RECONCILIATION
PAYMENT ELIGIBILITY AND THE EFFECTIVE DISCOUNT FACTOR EXPERIENCED AT RECONCILIATION
AMI model composite quality score
(proposed)
AMI model composite quality score
(final)
Eligible for reconciliation payment
<3.6 .................................................................
>=3.6 and <6.9 ...............................................
>=6.9 and <=14.8 ...........................................
>14.8 ...............................................................
<3.8 ................................................................
>=3.8 and <6.3 ...............................................
>=6.3 and <=15.0 ...........................................
>15.0 ..............................................................
No ..................
Yes .................
Yes .................
Yes .................
Effective discount factor
for reconciliation
payment
(%)
3.0
3.0
2.0
1.5
Effective discount factor for
repayment
amount
Not
Not
Not
Not
applicable.
applicable.
applicable.
applicable.
TABLE 32—PERFORMANCE YEARS 2 (FOR PARTICIPANTS WHO ELECT EARLY DOWNSIDE RISK ONLY), 3 AND 4: RELATIONSHIP OF AMI MODEL COMPOSITE QUALITY SCORE TO RECONCILIATION PAYMENT ELIGIBILITY AND THE EFFECTIVE
DISCOUNT FACTOR EXPERIENCED AT RECONCILIATION
AMI model composite quality score
(propose)
AMI model composite quality score
(final)
Eligible for reconciliation payment
Effective discount factor
for reconciliation payment
(%)
Applicable discount factor
for repayment
amount *
(%)
<3.6 .................................................................
>=3.6 and <6.9 ...............................................
>=6.9 and <=14.8 ...........................................
>14.8 ...............................................................
<3.8 ................................................................
>=3.8 and <6.3 ...............................................
>=6.3 and <=15.0 ...........................................
>15.0 ..............................................................
No ..................
Yes .................
Yes .................
Yes .................
3.0
3.0
2.0
1.5
2.0
2.0
1.0
0.5
* The applicable discount factor for the repayment amount only applies in performance years 2 (for participants who choose early downside
risk) and 3 (for all other participants) when repayment responsibility is being phased-in.
TABLE 33—PERFORMANCE YEAR 5: RELATIONSHIP OF AMI MODEL COMPOSITE QUALITY SCORE TO RECONCILIATION
PAYMENT ELIGIBILITY AND THE EFFECTIVE DISCOUNT FACTOR EXPERIENCED AT RECONCILIATION
AMI model composite quality score
(final)
Eligible for reconciliation payment
Effective discount factor
for reconciliation payment
(%)
Applicable discount factor
for repayment
amount
(%)
<3.6 .................................................................
>=3.6 and <6.9 ...............................................
>=6.9 and <=14.8 ...........................................
>14.8 ...............................................................
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AMI model composite quality score
(proposed)
<=3.7 ..............................................................
>3.7 and <= 6.25 ...........................................
>6.25 and <=15.0 ...........................................
>15.0 ..............................................................
No ..................
Yes .................
Yes .................
Yes .................
3.0
3.0
2.0
1.5
3.0
3.0
2.0
1.5
Under this approach, the maximum
AMI model effective discount factor
included in the quality-adjusted target
price would be 3.0 percent, consistent
with the CJR model (80 FR 73365). We
believe that a maximum effective
discount factor of 3.0 percent is
reasonable as it is within the range of
discount percentages included in the
ACE demonstration and it is the Model
2 BPCI discount factor for 30- and 60day episodes, where BPCI participants
are testing AMI episodes subject to the
3.0 percent discount factor. AMI model
participants that provide high quality
episode care would have the
opportunity for a lower effective
discount factor to be included in their
quality-adjusted target prices at
reconciliation as displayed in Tables 31,
32, and 33.
Under this methodology, we proposed
to require AMI model participants to
achieve a minimum AMI model
91 Episodes for AMI beneficiaries initiated by all
U.S. IPPS hospitals and constructed using
standardized Medicare FFS Parts A and B claims,
as proposed in this rule that began in CYs 2012–
2014.
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composite quality score of >=3.6 to be
eligible for a reconciliation payment if
actual episode payments were less than
the quality-adjusted target price based
on the 3.0 percent maximum effective
discount factor. Participants with below
acceptable quality performance reflected
in an AMI model composite quality
score <3.6 would not be eligible for a
reconciliation payment if actual AMI
model episode payments were less than
the quality-adjusted target price. A level
of quality performance that is below
acceptable would not affect AMI model
participants’ repayment responsibility if
actual AMI model episode payments
exceed the quality-adjusted target price.
We believe that excessive reductions in
utilization that lead to low actual AMI
model episode payments and that could
result from the financial incentives of an
EPM would be limited by a requirement
that this minimum level of AMI model
episode quality be achieved for
reconciliation payments to be made.
This policy would encourage AMI
model participants to focus on
appropriate reductions or changes in
utilization to achieve high quality care
in a more efficient manner. Therefore,
these participants would be ineligible to
receive a reconciliation payment if
actual AMI model episode payments
were less than the quality-adjusted
target price.
We proposed that AMI model
participants with an acceptable AMI
model composite quality score of >=3.6
and <6.9 would be eligible for a
reconciliation payment if actual AMI
model episode payments were less than
the quality-adjusted target price based
on a 3.0 percent effective discount factor
because their quality performance was
at the acceptable level established for
the AMI model. Therefore, these AMI
model participants would be eligible to
receive a reconciliation payment if
actual AMI model episode payments
were less than the quality-adjusted
target price.
We proposed that AMI model
participants with a good AMI model
composite quality score of >=6.9 and
<=14.8 would be eligible for a
reconciliation payment if actual AMI
model episode payments were less than
the quality-adjusted target price based
on a 2.0 percent effective discount factor
that reflects their good quality
performance. Thus, participants
achieving this level of quality for AMI
episodes under the AMI model would
either have less repayment
responsibility (that is, the reduced
effective discount factor would offset a
portion of their repayment
responsibility) or receive a higher
reconciliation payment (that is, the
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reduced effective discount factor would
increase the reconciliation payment) at
reconciliation than they would have
otherwise based on a comparison of
actual AMI model episode payments to
quality-adjusted target prices that
include the maximum 3.0 percent
effective discount factor.
Finally, we proposed that AMI model
participants with an excellent AMI
model composite score quality score of
>14.8 would be eligible to receive a
reconciliation payment if actual AMI
model episode payments were less than
the quality-adjusted target price based
on a 1.5 percent effective discount factor
that reflects their excellent performance.
Thus, participants achieving this level
of quality for AMI episodes under the
AMI model would either have less
repayment responsibility (that is, the
reduced effective discount factor would
offset a portion of their repayment
responsibility) or receive a higher
reconciliation payment (that is, the
reduced effective discount factor would
increase the reconciliation payment) at
reconciliation than they would have
otherwise based on a comparison of
actual AMI model episode payments to
quality-adjusted target prices that
include the maximum 3.0 percent
effective discount factor.
Under this methodology, the
proposed stop-loss and stop-gain limits
discussed in section III.D.7.b. of this
final rule will not change. We believe
this approach to quality incentive
payments based on the AMI model
composite quality score could have the
effect of increasing the alignment of the
financial and quality performance
incentives under the AMI model to the
potential benefit of AMI model
participants and their collaborators as
well as CMS, and would be consistent
with the CJR model methodology
linking quality and payment.
The proposal to link quality to
payment in the AMI model pay-forperformance methodology is included
in § 512.315(b)(5). We sought comment
on our proposal to link quality to
payment in the AMI model pay-forperformance methodology.
We did not receive comments which
uniquely addressed the proposed AMI
model pay-for-performance
methodology.
Final Decision: Although we did not
receive comments on the proposed AMI
model pay-for-performance
methodology, adjustments to our
proposal are necessary due to the final
selection of actual EPM MSAs and our
policy for participants who elect early
downside risk as discussed in section
III.D.2.c. of this final rule. Specifically,
in our proposed rule we created
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composite quality score ranges for the
AMI measure based on historical
performance of a representative group of
hospitals within 98 potentially EPMeligible MSAs. However, for the final
rule we have randomly selected 98
MSAs in which to officially conduct the
EPM models. Therefore, the composite
quality score ranges associated with
each quality performance category we
are finalizing in this rule are based on
a model of historical performance in the
actual 98 MSAs selected for this model.
Final AMI model composite quality
score ranges, associated quality
performance categories and discounts
are reflected in tables 31, 32, and 33.
After consideration of the public
comments received, we are finalizing
the proposal, with modification to final
composite quality score ranges to reflect
selection of MSAs, as discussed here.
(b) CABG Model Pay-for-Performance
Methodology
We proposed to incorporate the CABG
model composite quality score in the
CABG model payment methodology
by—(1) requiring a minimum CABG
model composite quality score for
reconciliation payment eligibility if the
CABG model participant’s actual
episode payments are less than the
quality-adjusted target price; and (2)
determining the effective discount factor
included in the quality-adjusted target
price experienced by the CABG model
participant in the reconciliation process.
The payment policies we would apply
are displayed in Tables 34, D24, and
D25 for the performance years of the
CABG model. Under the CABG model as
proposed, there is no CABG model
participant repayment responsibility in
performance year 1 and performance
year 2 (NDR) and this responsibility
begins to be phased-in in performance
year 2 (DR), with full implementation in
performance year 4. Because repayment
responsibility is phased-in, in
performance years 2 (DR) and 3,
repayment responsibility only applies to
a portion of the amount of excess CABG
model episode spending that results
from the quality-adjusted target prices
that include the CABG model
participant’s effective discount factor.
We, therefore, refer in the repayment
column to the applicable discount factor
for repayment amount in performance
years 2 (DR) and 3. The effective
discount factor applies to both the
reconciliation payment and the
repayment amount in performance years
4 and 5. We note that the average
Medicare payment for historical CABG
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episodes beginning in CYs 2012 to 2014
was $47,000.92
TABLE 34—PERFORMANCE YEAR 1 (ALL PARTICIPANTS) AND PERFORMANCE YEAR 2 (FOR PARTICIPANTS WHO DO NOT
ELECT EARLY DOWNSIDE RISK): RELATIONSHIP OF CABG MODEL COMPOSITE QUALITY SCORE TO RECONCILIATION
PAYMENT ELIGIBILITY AND THE EFFECTIVE DISCOUNT FACTOR EXPERIENCED AT RECONCILIATION
CABG model composite quality score
(proposed)
CABG model composite quality score
(final)
Eligible for reconciliation payment
<2.8 .................................................................
>=2.8 and <4.8 ...............................................
>=4.8 and <=17.5 ...........................................
>17.5 ...............................................................
<=2.2 ..............................................................
>2.2 and <=3.4 ...............................................
>3.4 and <=16.2 .............................................
>16.2 ..............................................................
No ..................
Yes .................
Yes .................
Yes .................
Effective discount factor
for reconciliation
payment
(%)
3.0
3.0
2.0
1.5
Effective discount factor for
repayment
amount
Not
Not
Not
Not
applicable.
applicable.
applicable.
applicable.
TABLE 35—PERFORMANCE YEARS 2 (FOR PARTICIPANTS WHO ELECT EARLY DOWNSIDE RISK ONLY), 3 AND 4: RELATIONSHIP OF CABG MODEL COMPOSITE QUALITY SCORE TO RECONCILIATION PAYMENT ELIGIBILITY AND THE EFFECTIVE
DISCOUNT FACTOR EXPERIENCED AT RECONCILIATION
CABG model composite quality score
(proposed)
CABG model composite quality score
(final)
Eligible for reconciliation payment
Effective discount factor
for reconciliation payment
(%)
Applicable discount factor
for repayment
amount *
(%)
<2.8 .................................................................
>=2.8 and <4.8 ...............................................
>=4.8 and <=17.5 ...........................................
>17.5 ...............................................................
<2.5 ................................................................
>=2.5 and <3.5 ...............................................
>=3.5 and <=16.2 ...........................................
>16.2 ..............................................................
No ..................
Yes .................
Yes .................
Yes .................
3.0
3.0
2.0
1.5
2.0
2.0
1.0
0.5
* The applicable discount factor for the repayment amount only applies in performance years 2 (for participants who choose early downside
risk) and 3 (for all other participants) when repayment responsibility is being phased-in.
TABLE 36—PERFORMANCE YEAR 5: RELATIONSHIP OF CABG MODEL COMPOSITE QUALITY SCORE TO RECONCILIATION
PAYMENT ELIGIBILITY AND THE EFFECTIVE DISCOUNT FACTOR EXPERIENCED AT RECONCILIATION
CABG model composite quality score
(final)
Eligible for reconciliation payment
Effective discount factor
for reconciliation payment
(%)
Applicable discount factor
for repayment
amount
(%)
<2.8 .................................................................
>=2.8 and <4.8 ...............................................
>=4.8 and <=17.5 ...........................................
>17.5 ...............................................................
asabaliauskas on DSK3SPTVN1PROD with RULES
CABG model composite quality score
(proposed)
<2.5 ................................................................
>=2.5 and <3.5 ...............................................
>=3.5 and <=16.2 ...........................................
>16.2 ..............................................................
No ..................
Yes .................
Yes .................
Yes .................
3.0
3.0
2.0
1.5
3.0
3.0
2.0
1.5
Under this approach, the maximum
CABG model effective discount factor
included in the quality-adjusted target
price would be 3.0 percent, consistent
with the CJR model (80 FR 73365). We
believe that a maximum effective
discount factor of 3.0 percent is
reasonable as it is within the range of
discount percentages included in the
Medicare Acute Care Episode (ACE)
demonstration and it is the Model 2
BPCI discount factor for 30 and 60 day
episodes, where BPCI participants are
testing CABG episodes subject to the 3.0
percent discount factor. CABG model
participants that provide high quality
episode care would have the
opportunity for a lower effective
discount factor to be included in their
quality-adjusted target prices at
reconciliation as displayed in Tables 34,
35, and 36.
Under this methodology, we proposed
that we would require CABG model
participants to achieve a minimum
CABG model composite quality score of
>=2.8 to be eligible for a reconciliation
payment if actual episode payments
were less than the quality-adjusted
target price based on the 3.0 percent
maximum effective discount factor. We
proposed that participants with below
acceptable quality performance reflected
in an CABG model composite quality
score <2.8 would not be eligible for a
reconciliation payment if actual CABG
model episode payments were less than
the quality-adjusted target price. A level
of quality performance that is below
acceptable would not affect participants’
repayment responsibility if actual CABG
model episode payments exceed the
quality-adjusted target price. We believe
that excessive reductions in utilization
that lead to low actual CABG model
episode payments and that could result
from the financial incentives of an EPM
would be limited by a requirement that
this minimum level of CABG model
episode quality be achieved for
reconciliation payments to be made.
92 Episodes for CABG beneficiaries initiated by all
U.S. IPPS hospitals and constructed using
standardized Medicare FFS Parts A and B claims,
as proposed in this rule that began in CYs 2012–
2014.
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This policy would encourage CABG
model participants to focus on
appropriate reductions or changes in
utilization to achieve high quality care
in a more efficient manner. Therefore,
these participants would be ineligible to
receive a reconciliation payment if
actual CABG model episode payments
were less than the quality-adjusted
target price.
We proposed that CABG model
participants with an acceptable CABG
model composite quality score of >=2.8
and <4.8 would be eligible for a
reconciliation payment if actual CABG
model episode payments were less than
the quality-adjusted target price based
on a 3.0 percent effective discount factor
because their quality performance was
at the acceptable level established for
the CABG model. Therefore, these
CABG model participants would be
eligible to receive a reconciliation
payment if actual CABG model episode
payments were less than the qualityadjusted target price.
We proposed that CABG model
participants with a good CABG model
composite quality score >=4.8 and
<=17.5 would be eligible for a
reconciliation payment if actual CABG
model episode payments were less than
the quality-adjusted target price based
on a 2.0 percent effective discount factor
that reflects their good quality
performance. Thus, participants
achieving this level of quality for CABG
episodes under the CABG model would
either have less repayment
responsibility (that is, the reduced
effective discount factor would offset a
portion of their repayment
responsibility) or receive a higher
reconciliation payment (that is, the
reduced effective discount factor would
increase the reconciliation payment) at
reconciliation than they would have
otherwise based on a comparison of
actual CABG model episode payments
to quality-adjusted target prices that
include the maximum 3.0 percent
effective discount factor.
Finally, we proposed that CABG
model participants with an excellent
CABG model composite score quality
score of >17.5 would be eligible to
receive a reconciliation payment if
actual CABG model episode payments
were less than the quality-adjusted
target price based on a 1.5 percent
effective discount factor that reflects
their excellent performance. Thus,
participants achieving this level of
quality for CABG model episodes would
either have less repayment
responsibility (that is, the reduced
effective discount factor would offset a
portion of their repayment
responsibility) or receive a higher
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reconciliation payment (that is, the
reduced effective discount factor would
increase the reconciliation payment) at
reconciliation than they would have
otherwise based on a comparison of
actual CABG model episode payments
to quality-adjusted target prices that
include the maximum 3.0 percent
effective discount factor.
Under this methodology, the
proposed stop-loss and stop-gain limits
discussed in section III.D.7.b. of this
final rule will not change. We believe
this approach to quality incentive
payments based on the CABG model
composite quality score could have the
effect of increasing the alignment of the
financial and quality performance
incentives under the CABG model to the
potential benefit of CABG model
participants and their collaborators as
well as CMS, and would be consistent
with the CJR model methodology
linking quality and payment.
The proposal to link quality to
payment in the CABG model pay-forperformance methodology is included
in § 512.315(c)(5). We sought comment
on our proposal to link quality to
payment in the CABG model pay-forperformance methodology.
We did not receive comments which
uniquely addressed our proposed CABG
model pay-for-performance
methodology.
Final Decision: Although we did not
receive comments on the proposed
CABG model pay-for-performance
methodology, adjustments to our
proposal are necessary due to selection
of the EPM MSAs and our policy for
participants who elect early downside
risk as discussed in section III.D.2.c. of
this final rule. Specifically, in our
proposed rule we created composite
quality score ranges for the CABG
measure based on historical
performance of a representative group of
hospitals within 98 potentially EPMeligible MSAs. However, for the final
rule we have randomly selected 98
MSAs in which to officially conduct the
EPM models. Therefore, the composite
quality score ranges associated with
each quality performance category we
are finalizing in this rule are based on
a model of historical performance of in
the actual 98 MSAs selected for this
model. Final CABG model composite
quality score ranges, associated quality
performance categories and discounts
are reflected in tables 34, 35, and 36.
After consideration of the public
comments received, we are finalizing
the proposal, with modification to final
composite quality score ranges to reflect
selection of MSAs, as discussed here
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(c) Alignment Between the AMI and
CABG Model Methodologies
The AMI and CABG models are
closely related, given that they both are
based on a significant event or
procedure for a beneficiary with CAD.
As discussed in sections III.D.2.b. and
III.D.2.c. of the proposed rule (81 FR
50794), we proposed the use of a 30-day
mortality measure in both models,
specifically MORT–30–AMI (NQF
#0230) with a weight of 50 percent in
the AMI model composite quality score
and MORT–30–CABG (NQF #2558) with
a weight of 75 percent in the CABG
model quality score. The beneficiaries
included in the measure have some
overlap, because some beneficiaries
with AMI will have a CABG during their
hospitalization that begins an episode.
Analysis of both the MORT–30–AMI
(NQF #0230) and MORT–30–CABG
(NQF #2558) measure national
distributions suggests that improving
from the 25th percentile to 75th
percentile represents roughly a 1
percentage point decrease in mortality
rates for both measures.
In addition, we note that for historical
episodes beginning in 2012 to 2014, the
average Medicare spending for an AMI
episode that extends 90 days posthospital discharge was approximately
$24,200 and for a CABG episode was
approximately $47,000.93 However,
because we proposed the same 1.5
percent to 3.0 percent effective discount
factor range based on quality
performance and improvement for the
AMI and CABG models (and, to a lesser
degree, because of the modestly lower
weight assigned to the mortality
measure under the AMI model), the
absolute dollar amounts tied to changes
in AMI or CABG mortality rates are
different in the two models. A larger
absolute financial incentive is
associated with improvement in CABG
mortality than AMI mortality under our
proposal. We recognize that mortality is
a serious outcome for beneficiaries with
CAD who have a significant event or
procedure, and we considered setting a
wider effective discount factor range
based on quality in the AMI model than
the CABG model to align the absolute
financial incentives to improve
mortality under both models. For
example, to create a more similar
absolute financial incentive between the
lowest and highest effective discount
percentages in the AMI and CABG
models, we could set the effective
93 Episodes for AMI and CABG beneficiaries
initiated by all U.S. IPPS hospitals and constructed
using standardized Medicare FFS Parts A and B
claims, as proposed in this rule that began in CYs
2012–2014.
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discount factor range for the AMI model
at 0.75 percent to 3.75 percent and the
CABG model range at 1.5 percent to 3
percent. Alternatively, we could set the
AMI model effective discount factor
range at 1.5 percent to 3 percent and
compress the CABG effective discount
factor range. While we did not propose
different effective discount factor ranges
for the AMI and CABG models in order
to retain consistency with the CJR
model and the BPCI initiative, we
sought comments about the potential
benefits and drawbacks of establishing
the same absolute dollar incentive for
similar improvements in quality across
different models that have similar
measures but vary in average episode
cost. This feedback will be useful as we
consider future episode payment
models and candidate quality measures
for potential new and existing models,
as well as consider future refinements to
the pay-for-performance methodologies
under the models. Our goal in all of our
episode payment models is to create
strong financial incentives for quality
performance and improvement for
participants at all level of current
quality performance and to rationalize
the strength of the financial incentives
in the context of the specificity and
importance of the quality measures used
under the models.
Final Decision: No comments were
received on the proposed pay for
performance methodology. Therefore,
we are finalizing the proposal, without
modification.
(3) SHFFT Model Pay-for-Performance
Methodology
We proposed to incorporate the
SHFFT model composite quality score
in the SHFFT model payment
methodology by (1) requiring a
minimum SHFFT model composite
quality score for reconciliation payment
eligibility if the SHFFT model
participant’s actual episode payments
are less than the quality-adjusted target
price and (2) determining the effective
discount factor included in the qualityadjusted target price experienced by the
SHFFT model participant in the
reconciliation process. The payment
policies we would apply are displayed
in Tables 37, 38, and 28 for the
performance years of the SHFFT model.
Under the SHFFT model as proposed,
there is no SHFFT model participant
repayment responsibility in
performance year 1 and performance
year 2 (NDR) and this responsibility
begins to be phased-in in performance
year 2 (DR), with full implementation in
performance year 4. Because repayment
responsibility is phased-in, in
performance years 2 (DR) and 3,
repayment responsibility only applies to
a portion of the amount of excess
SHFFT model episode spending that
results from the quality-adjusted target
prices that include the SHFFT model
participant’s effective discount factor.
We, therefore, refer in the repayment
column to the applicable discount factor
for repayment amount in performance
years 2 (DR) and 3. The effective
discount factor applies to both the
reconciliation payment and the
repayment amount in performance years
4 and 5. We note that the average
Medicare payment for historical SHFFT
episodes beginning in CYs 2012 to 2014
was $43,000.94
We refer to section V.E. of this final
rule for discussion of the correction to
the composite quality score ranges for
the four quality categories from what
was presented in the CJR final rule (80
FR 73378). The SHFFT model
composite quality score ranges
displayed in Tables 37 through 39 are
the corrected ranges that also apply to
the CJR model.
TABLE 37—PERFORMANCE YEAR 1 (ALL PARTICIPANTS) AND PERFORMANCE YEAR 2 (FOR PARTICIPANTS WHO DO NOT
ELECT EARLY DOWNSIDE RISK): RELATIONSHIP OF SHFFT MODEL COMPOSITE QUALITY SCORE TO RECONCILIATION
PAYMENT ELIGIBILITY AND THE EFFECTIVE DISCOUNT FACTOR EXPERIENCED AT RECONCILIATION
SHFFT model composite quality score
(proposed)
SHFFT model composite quality score
(final)
Eligible for reconciliation payment
Effective discount factor
for reconciliation payment
(%)
<5.0 .................................................................
>=5.0 and <6.9 ...............................................
>=6.9 and <=15.0 ...........................................
>15.0 ...............................................................
<5.0 ................................................................
>=5.0 and <6.9 ...............................................
>=6.9 and <=15.0 ...........................................
>15.0 ..............................................................
No ..................
Yes .................
Yes .................
Yes .................
3.0
3.0
2.0
1.5
Effective discount factor for
repayment
amount
Not
Not
Not
Not
applicable.
applicable.
applicable.
applicable.
TABLE 38—PERFORMANCE YEARS 2 (FOR PARTICIPANTS WHO ELECT EARLY DOWNSIDE RISK ONLY), 3 AND 4: RELATIONSHIP OF SHFFT MODEL COMPOSITE QUALITY SCORE TO RECONCILIATION PAYMENT ELIGIBILITY AND THE EFFECTIVE DISCOUNT FACTOR EXPERIENCED AT RECONCILIATION
asabaliauskas on DSK3SPTVN1PROD with RULES
SHFFT model composite quality score
(proposed)
SHFFT model composite quality score
(final)
Eligible for reconciliation payment
Effective discount factor
for reconciliation payment
(%)
Applicable discount factor
for repayment
amount *
(%)
<5.0 .................................................................
>=5.0 and <6.9 ...............................................
>=6.9 and <=15.0 ...........................................
>15.0 ...............................................................
<5.0 ................................................................
>=5.0 and <6.9 ...............................................
>=6.9 and <=15.0 ...........................................
>15.0 ..............................................................
No ..................
Yes .................
Yes .................
Yes .................
3.0
3.0
2.0
1.5
2.0
2.0
1.0
0.5
* The applicable discount factor for the repayment amount only applies in performance years 2 (for participants who choose early downside
risk) and 3 (for all other participants) when repayment responsibility is being phased-in.
94 Episodes for SHFFT beneficiaries initiated by
all U.S. IPPS hospitals and constructed using
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standardized Medicare FFS Parts A and B claims,
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as proposed in this rule that began in CYs 2012–
2014.
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TABLE 39—PERFORMANCE YEAR 5: RELATIONSHIP OF SHFFT MODEL COMPOSITE QUALITY SCORE TO RECONCILIATION
PAYMENT ELIGIBILITY AND THE EFFECTIVE DISCOUNT FACTOR EXPERIENCED AT RECONCILIATION
SHFFT model composite quality score
(final)
Eligible for reconciliation payment
Effective discount factor
for reconciliation payment
(%)
Effective discount factor
for repayment
amount
(%)
<5.0 .................................................................
>=5.0 and <6.9 ...............................................
>=6.9 and <=15.0 ...........................................
>15.0 ...............................................................
asabaliauskas on DSK3SPTVN1PROD with RULES
SHFFT model composite quality score
(proposed)
<5.0 ................................................................
>=5.0 and <6.9 ...............................................
>=6.9 and <=15.0 ...........................................
>15.0 ..............................................................
No ..................
Yes .................
Yes .................
Yes .................
3.0
3.0
2.0
1.5
3.0
3.0
2.0
1.5
Under this methodology, we proposed
that we would require SHFFT model
participants to achieve a minimum
SHFFT model composite quality score
of >=5.0 to be eligible for a
reconciliation payment if actual episode
payments were less than the qualityadjusted target price based on the 3.0
percent maximum effective discount
factor. We proposed that participants
with below acceptable quality
performance reflected in a SHFFT
model composite quality score <5.0
would not be eligible for a
reconciliation payment if actual SHFFT
model episode payments were less than
the quality-adjusted target price. A level
of quality performance that is below
acceptable would not affect participants’
repayment responsibility if actual
SHFFT model episode payments exceed
the quality-adjusted target price. We
believe that excessive reductions in
utilization that lead to low actual
SHFFT model episode payments and
that could result from the financial
incentives of an EPM would be limited
by a requirement that this minimum
level of SHFFT model episode quality
be achieved for reconciliation payments
to be made. This policy would
encourage SHFFT model participants to
focus on appropriate reductions or
changes in utilization to achieve high
quality care in a more efficient manner.
Therefore, these participants would be
ineligible to receive a reconciliation
payment if actual SHFFT model episode
payments were less than the qualityadjusted target price.
We proposed that SHFFT model
participants with an acceptable SHFFT
model composite quality score of >=5.0
and <6.9 would be eligible for a
reconciliation payment if actual SHFFT
model episode payments were less than
the quality-adjusted target price based
on a 3.0 percent effective discount factor
because their quality performance was
at the acceptable level established for
the SHFFT model. Therefore, these
SHFFT model participants would be
eligible to receive a reconciliation
payment if actual SHFFT model episode
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payments were less than the qualityadjusted target price.
We proposed that SHFFT model
participants with a good SHFFT model
composite quality score of >=6.9 and
<=15.0 would be eligible for a
reconciliation payment if actual SHFFT
model episode payments were less than
the quality-adjusted target price based
on a 2.0 percent effective discount factor
that reflects their good quality
performance. Thus, participants
achieving this level of quality for
SHFFT model episodes under the
SHFFT model would either have less
repayment responsibility (that is, the
reduced effective discount factor would
offset a portion of their repayment
responsibility) or receive a higher
reconciliation payment (that is, the
reduced effective discount factor would
increase the reconciliation payment) at
reconciliation than they would have
otherwise based on a comparison of
actual SHFFT model episode payments
to quality-adjusted target prices that
include the maximum 3.0 percent
effective discount factor.
Finally, we proposed that SHFFT
model participants with an excellent
SHFFT model composite score quality
score of >15.0 would be eligible to
receive a reconciliation payment if
actual SHFFT model episode spending
was less than the quality-adjusted target
price based on a 1.5 percent effective
discount factor that reflects their
excellent performance. Thus,
participants achieving this level of
quality for SHFFT model episodes
would either have less repayment
responsibility (that is, the reduced
effective discount factor would offset a
portion of their repayment
responsibility) or receive a higher
reconciliation payment (that is, the
reduced effective discount factor would
increase the reconciliation payment) at
reconciliation than they would have
otherwise based on a comparison of
actual SHFFT model episode payments
to quality-adjusted target prices that
include the maximum 3.0 percent
effective discount factor.
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Under this methodology, the
proposed stop-loss and stop-gain limits
discussed in section III.D.7.b. of this
final rule will not change. We believe
this approach to quality incentive
payments based on the SHFFT model
composite quality score could have the
effect of increasing the alignment of the
financial and quality performance
incentives under the SHFFT model to
the potential benefit of SHFFT model
participants and their collaborators as
well as CMS, and would be consistent
with the CJR model methodology
linking quality and payment.
The proposal to link quality to
payment in the SHFFT model pay-forperformance methodology is included
in § 512.315(d)(5). We sought comment
on our proposal to link quality to
payment in the SHFFT model pay-forperformance methodology.
We did not receive comments on the
proposed SHFFT model pay-forperformance methodology.
Final Decision: We are finalizing
without modification our proposal for
SHFFT model pay-for-performance
methodology.
4. Details on Quality Measures for the
EPMs
a. AMI Model-Specific Measures
(1) Hospital 30-Day, All-Cause, RiskStandardized Mortality Rate Following
Acute Myocardial Infarction (AMI)
Hospitalization (NQF #0230)(MORT–
30–AMI)
(a) Background
AMI is one of the most common
principal hospital discharge diagnoses
among older adults and is associated
with high mortality. AMI was the tenth
most common principal discharge
diagnosis among patients with Medicare
in 2012.95 Each year, over 600,000
Americans will experience an AMI.
Despite improvements in treatments, 30day mortality rates following AMI
exceed 7 percent. CMS pays
95 Agency for Healthcare Research and Quality
(AHRQ). Healthcare Cost and Utilization Project
(HCUP) https://hcupnet.ahrq.gov/.
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asabaliauskas on DSK3SPTVN1PROD with RULES
approximately $11.7 billion annually for
in-hospital costs for Medicare
beneficiaries with coronary heart
disease, of which AMI is a major
contributor. The high prevalence and
considerable morbidity and mortality
associated with AMI create an economic
burden on the health care system.96
Hospital mortality is an outcome that
is likely attributable to care processes
and is an important outcome for
patients. Complex and critical aspects of
care, such as communication between
providers, prevention of and response to
complications, patient safety, and
coordinated transitions to the outpatient
environment, all contribute to patient
outcomes. Many current hospital
interventions are known to decrease the
risk of death within 30 days of hospital
admission.97 98 We believe it is
important to assess the quality of care
provided to Medicare beneficiaries who
are hospitalized for AMI.
The measure developed by CMS, and
currently implemented in the HIQR and
HVBP Programs, assesses a hospital’s
risk-standardized mortality rate, which
is the rate of death after admission to a
hospital with a principal diagnosis of
AMI. The measure outcome is the rate
of mortality occurring after admission
with a principal diagnosis of AMI for
patients 65 and older during a 30-day
period that begins with the date of the
index admission for the specific
hospital. An index admission is the
hospitalization which is included in the
measure cohort because it meets all
inclusion criteria and does not meet any
exclusion criteria. The index admission
is the hospitalization to which the
mortality outcome is attributed. The
median hospital-level risk-standardized
mortality rate for 2016 public reporting
on Hospital Compare was 14.2 percent,
with an interquartile range from 13.7
percent to 14.6 percent in hospitals. The
variation in mortality rates suggests that
important differences in the quality of
care delivered across hospitals exist,
and there is room for quality
improvement.
We developed the measure of
hospital-level risk-standardized
96 American Heart Association. Heart Disease and
Stroke Statistics—2010 Update. Dallas, Texas:
American Heart Association; 2010. c2010,
American Heart Association.
97 Jha AK, Orav EJ, Li Z, Epstein AM. The inverse
relationship between mortality rates and
performance in the Hospital Quality Alliance
measures. Health Aff (Millwood). 2007 Jul-Aug;
26(4):1104–10.
98 Rathore SS, Curtis JP, Chen J, Wang Y,
Nallamothu BK, Epstein AJ, Krumholz HM;
National Cardiovascular Data Registry. Association
of door-to-balloon time and mortality in patients
admitted to hospital with ST elevation myocardial
infarction: National cohort study. BMJ. 2009 May
19; 338:b1807.
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mortality rate (RSMR) following AMI
hospitalization, which is endorsed by
the NQF (NQF #0230). The measure has
been publicly reported on Hospital
Compare since FY 2007, and was
incorporated into what is now the HIQR
Program since FY 2008 (FY 2008 IPPS/
LTCH final rule 71 FR 67960), and the
HVBP Program since FY 2014 (FY 2011
IPPS/LTCH final rule 76 FR 26510).
(b) Data Sources
We proposed to use Medicare Part A
and Part B FFS claims submitted by the
AMI model participant as the data
source for calculation of the MORT–30–
AMI (NQF #0230) measure. Index
admission diagnoses and in-hospital
comorbidities are assessed using
Medicare Part A claims. Additional
comorbidities prior to the index
admission are assessed as Part A
inpatient, outpatient, and Part B office
visit Medicare claims in the 12 months
prior to the index (initial) admission.
Enrollment and post-discharge mortality
status are obtained from Medicare’s
enrollment database which contains
beneficiary demographics, benefits/
coverage, and vital status information.
(c) Cohort
The MORT–30–AMI (NQF #0230)
measure includes Medicare FFS
beneficiaries, aged 65 years or older,
discharged from non-federal acute care
hospitals with a principal discharge
diagnosis of AMI and with a complete
claims history for the 12 months prior
to admission. Eligible hospitalizations
are defined using the following ICD–10–
CM codes: I2109, I2119, I2111, I2119,
I2129, I214, and I213.
We proposed that the measure will
include index admissions to all nonfederal acute care hospitals, which
includes all AMI model participants.
Hospital performance will only be
publically reported for hospitals with 25
or more index admissions in the 3-year
measurement period. The AMI model
cohort would differ from the hospital
cohort that is currently captured in the
measure through the HIQR Program.
Although performance on the measure
will not be publically reported for
hospitals with fewer than 25 cases, they
will receive information about their
performance. We refer readers to section
III.B.5. of this final rule for participant
selection for the AMI model. For eligible
hospitalizations defined using ICD–9–
CM codes, we refer readers to the CMS
Web site at: https://cms.gov/Medicare/
Quality-Initiatives-Patient-AssessmentInstruments/HospitalQualityInits/
Measure-Methodology.html.
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373
(d) Inclusion and Exclusion Criteria
We proposed that an index admission
is the hospitalization to which the
mortality outcome is attributed. We note
that for purposes of the EPMs where we
need to identify episodes that are
included in the EPMs, we use the term
anchor hospitalization to identify
hospitalizations that initiate EPM
episodes for beneficiaries whose care is
included in the EPMs. In describing the
quality measures themselves in detail in
section III.E.4. of the proposed rule (81
FR 50794), we use the term index
hospitalization to identify
hospitalizations of beneficiaries whose
outcomes are included in the measures.
Thus, anchor hospitalizations and index
hospitalizations would have varying
degrees of overlap depending on the
specific quality measure. The measure
includes the following index admissions
for patients:
• Having a principal discharge
diagnosis of AMI.
• Enrolled in Medicare FFS.
• Aged 65 or over.
• Not transferred from another acute
care facility.
• Enrolled in Medicare Part A and
Part B for the 12 months prior to the
date of index admission, and enrolled in
Part A during the index admission.
This measure excludes the following
index admissions for patients:
• Discharged alive on the day of
admission or the following day who
were not transferred to another acute
care facility.
• With inconsistent or unknown vital
status or other unreliable demographic
(age and gender) data;
• Enrolled in the Medicare hospice
program any time in the 12 months
prior to the index admission, including
the first day of the index admission;
• Discharged against medical advice
American Medical Association (AMA);
or
• Without at least 30 days of postdischarge enrollment in FFS Medicare
as the 30-day mortality outcome cannot
be assessed for these patients.
Finally, for the purpose of this
measure, admissions within 30 days of
discharge from an index admission are
not eligible to also be index admissions.
Thus, only one index admission for AMI
per beneficiary is randomly selected for
inclusion in the cohort.
(e) Risk-Adjustment
We note that this measure is aligned
with the risk-adjustment methodologies
adopted for the MORT–30–AMI (NQF
#0230) measure under the HIQR
Program in accordance with section
1886(b)(3)(B)(viii)(VIII) of the Act, as
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finalized in FY 2008 IPPS/LTCH final
rule (2008 IPPS/LTCH final rule 71 FR
67960). We also note that the measure
risk adjustment takes into account
patient age, sex, and comorbidities to
allow a fair assessment of hospital
performance. The measure defines the
patient risk factors for mortality using
diagnosis codes collected from all
patient claims 1 year prior to patient
index hospitalization for AMI. As
previously noted in the MORT–30–AMI
measure (NQF #0230), ICD–10–CM
codes on Medicare Parts A and B
administrative claims are used to inform
the risk prediction for each patient;
diagnostic codes from post-acute care
settings are included in the measure, but
this information is only used to identify
a hospital’s patient case mix in order to
adequately adjust for differences in case
mix across hospitals. Use of Parts A and
B data does not mean the measure is
applicable to post-acute care settings,
only that it uses comprehensive data to
predict the risk of the outcome and
adjust for hospital patient case mix. We
note that the patient diagnosis codes are
grouped using Hierarchical Condition
Categories (HCCs), which are clinically
relevant diagnostic groups of codes. The
CCs used in the risk-adjustment model
for this measure are provided on the
CMS QualityNet Web site at: https://
www.qualitynet.org/dcs/
ContentServer?c=Page&pagename=
QnetPublic%2FPage%2F
QnetTier4&cid=1219069856694.
In summary, age, sex, and
comorbidities present at the time of
admission are adjusted for differences in
hospital case mix (patient risk factors).
The measure uses the hierarchical
logistic regression model (HLM)
statistical methodology for risk
adjustment.
asabaliauskas on DSK3SPTVN1PROD with RULES
(f) Calculating the Risk-Standardized
Mortality Ratio (RSMR) and
Performance Period
We proposed to calculate hospital 30day, all-cause, risk-standardized
mortality rates consistent with the
methodology used to risk standardize all
readmission and mortality measures
used in CMS hospital quality programs.
Using HLM, we calculate the hospitallevel risk-standardized mortality rate
following AMI hospitalization by
producing a ratio of the number of
‘‘predicted’’ deaths (that is, the adjusted
number of deaths at a specific hospital)
to the number of ‘‘expected’’ deaths
(that is, the number of deaths if an
average quality hospital treated the
same patients) for each hospital and
then multiplying the ratio by the
national raw mortality rate.
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A 3-year rolling period for calculating
measure results would be consistent
with the time frame used for the HIQR
Program (FY 2008 IPPS/LTCH final rule
71 FR 67960). Section III.E.5. of the
proposed rule (81 FR 50794), Form,
Manner, and Timing of Quality Measure
Submission, summarizes the proposed
measure performance periods for AMI
model performance years 1 through 5.
We note that, for each performance year,
improvement on the MORT–30–AMI
(NQF #0230) measure would be
determined by comparing measure
results from that performance year to
results in the 3-year rolling
measurement period immediately
preceding each AMI model performance
year to results from the 3-year period
from July 1, 2014 through June 30, 2017,
for performance year 2 by comparing
measure results in this year to results
from the 3-year period from July 1, 2015
through June 30, 2018, in performance
year 3 by comparing measure results in
this year to results from the 3-year
period from July 1, 2016 and June 30,
2019, in performance year 4 by
comparing measure results in this year
to results from the 3-year period from
July 1, 2017 and June 30, 2020, and in
performance year 5 by comparing
measure results in this year to results
from the 3-year period from July 1, 2018
and June 30, 2021.
The proposal to include Hospitallevel 30-Day, All-Cause, RiskStandardized Mortality Rate (RSMR)
following AMI hospitalization (NQF
#0230) measure in the AMI model is
included in § 512.411(a)(1). We sought
comment on this proposal to include
Hospital-level 30-Day, All-Cause, RiskStandardized Mortality Rate (RSMR)
following AMI hospitalization (NQF
#0230) measure in the AMI model to
assess quality performance.
The following is a summary of the
comments received and our responses.
Comment: One commenter supported
the proposal to use mortality rates as the
principal outcome measure for the
cardiac EPMs. The commenter agreed
that mortality is an extremely serious
outcome for these episodes, and it has
the added benefit of not requiring
adjustment for SES, demographic, or
environmental risk factors.
Response: We thank the commenter
for their support.
Comment: Several commenters
expressed concern about the proposed
weighting of the 30-day riskstandardized mortality rate (RSMR) at
50 percent of the composite quality
score because the high weight assigned
to the risk-standardized 30-day
mortality rate could encourage
inappropriate treatment such as total
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revascularization even when not
clinically indicated at the time of the
acute event. One commenter was also
concerned that with this weighting
proposal, hospitals with fewer AMI
cases would be further disadvantaged
since there will be less data used to
calculate the hospital’s quality score.
Response: To ensure hospitals have
enough cases to produce a valid quality
score, the AMI mortality measure uses
3 years of claims data to calculate the
measure. Hospitals must have at least 25
qualifying index admissions within the
3-year measurement period to calculate
and publically report a measure result.
We do not believe these measures
disadvantage smaller volume hospitals.
We have found hospitals with fewer
cases tend to have measure results that
are close to the national average,
hospital rate and are therefore rarely
identified as poor performing outliers.
Comment: One commenter
recommended excluding cardiogenic
shock and sepsis patients because
patients with either of these conditions
and AMI have a higher mortality rate
than those who do not.
Response: In order to account for
differences in patient mix among
hospitals, the measures adjust for
variables (for example, age, comorbid
diseases, and indicators of patient
frailty) that are clinically relevant and
have relationships with the outcome. In
the case of the AMI measure, we risk
adjust for cardio-respiratory failure or
shock. However the measure’s risk
model does not include a risk variable
for sepsis.
Comment: Several commenters
requested clarification or expressed
concern about attribution of the measure
outcome to hospitals when patients are
transferred among acute-care hospitals.
One commenter suggested that
hospitalizations that include transfers
among institutions be excluded or that
the AMI mortality measure not be used
in cases where there was a transfer.
Another commenter suggested that the
current method within the AMI
mortality measure of attributing the
outcome to the transferring hospital,
rather than the receiving hospital
should be changed.
Response: In the AMI mortality
measures, for patients transferred from
one short-term acute care hospital to
another, only the first admission in the
transfer chain is eligible for inclusion in
the cohort. The subsequent admissions
are not included. The measures assign a
death that occurs within 30 days to the
hospital that initially admitted the
patient as an inpatient. For example, if
a patient is admitted to Hospital A for
AMI and then transfers to Hospital B,
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only the Hospital A admission (the
index admission) would be included in
the cohort, and death within 30 days of
the Hospital A admission would be
captured in Hospital A’s AMI mortality
outcome. The rationale for this
approach is that the initial admitting
hospital makes diagnostic and treatment
decisions which exert great influence on
a patient’s risk of mortality in AMI cases
even when patient transfers are
warranted, for example, for
interventions that cannot be provided at
the initial admitting institution, such as
cardiac catheterization.
Comment: One commenter expressed
concern that having 50 percent of an
EPM participant’s quality score for AMI
and 75 percent of a participant’s quality
score for CABG based upon 30-day
hospital mortality places a heavy
reliance on only a few quality measures.
Furthermore, the commenter believed
that the heavy emphasis on 30-day
mortality could disadvantage smaller
hospitals with relatively low AMI/
CABG admissions, such that a few
adverse outcomes could
disproportionately impact the hospital’s
quality score.
Response: To ensure hospitals have
enough cases to produce a valid quality
score, the AMI mortality measure uses
3 years of claims data to calculate the
measure. Hospitals must have at least 25
qualifying index admissions within the
3-year measurement period to calculate
and publically report a measure result.
We do not believe these measures
disadvantage smaller volume hospitals.
We have found hospitals with few cases
tend to have measure results that are
close to the average hospital rate and are
therefore rarely identified as poor
performing outliers.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal, without
modification, to include Hospital-level
30-Day, All-Cause, Risk-Standardized
Mortality Rate (RSMR) following AMI
hospitalization (NQF #0230) measure in
the AMI model to assess quality
performance.
(2) Excess Days in Acute Care After
Hospitalization for Acute Myocardial
Infarction (AMI Excess Days)
asabaliauskas on DSK3SPTVN1PROD with RULES
(a) Background
The Excess Days in Acute Care after
Hospitalization for Acute Myocardial
Infarction (AMI) measure (AMI Excess
Days) is a risk-standardized outcome
measure that compares the number of
days that patients are predicted to spend
in acute care across the full spectrum of
possible acute care events (hospital
readmissions, observation stays, and ED
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visits) after discharge from a hospital for
AMI, to the days patients are expected
to spend in acute care based on their
degree of illness.
Some of the costs for AMI can be
attributed to high acute care utilization
for post-discharge AMI patients in the
form of readmissions, observation stays,
and emergency department (ED) visits.
We note that patients admitted for AMI
have disproportionately high
readmission rates, and that readmission
rates following discharge for AMI are
highly variable across hospitals in the
United States.99 100
For the previously adopted HIQR
Program measure, Hospital 30-Day, AllCause Risk-Standardized Readmission
Rate (RSRR) following Acute
Myocardial Infarction (AMI)
Hospitalization (NQF #0505) (CY 2009
OPPS/ASC final rule with comment
period; 73 FR 68780 through 68781),
publicly reported 30-day riskstandardized readmission rates for AMI
ranged from 17.5 percent to 30.3 percent
for the time period between July 2011
and June 2012.101 However, in addition
to an increased risk of requiring
readmission in the post-discharge
period, patients are also at risk of
returning to the hospital for both
observation stays and ED visits which
also characterize potentially preventable
acute care. ED visits represent a
significant proportion of post-discharge
acute care utilization for all conditions,
including patients with AMI. Two
recent studies conducted in patients of
all ages showed that 9.5 percent of
patients return to the ED within 30 days
of hospital discharge; additionally,
about 12 percent of these patients are
initially discharged from the ED and are
not captured by the previously adopted
HIQR Program readmission
measures.102 103 The rising use of
99 Krumholz HM, Merrill AR, Schone EM, et al.:
Patterns of hospital performance in acute
myocardial infarction and heart failure 30-day
mortality and readmission. Circulation.
Cardiovascular Quality & Outcomes. Sep
2009;2(5):407–413.
100 Bernheim SM, Grady JN, Lin Z, et al.: National
patterns of risk-standardized mortality and
readmission for acute myocardial infarction and
heart failure. Update on publicly reported outcomes
measures based on the 2010 release. Circulation.
Cardiovascular Quality & Outcomes. Sep
2010;3(5):459–46
101 Centers for Medicare and Medicaid Services.
Medicare Hospital Quality Chartbook Performance
Report on Outcome Measures September 2013.
September 2013; Available at: https://www.cms.gov/
Medicare/Quality-Initiatives-Patient-AssessmentInstruments/HospitalQualityInits/Downloads/Medicare-Hospital-Quality-Chartbook-2013.pdf.
102 Rathore SS, Curtis JP, Chen J, Wang Y,
Nallamothu BK, Epstein AJ, Krumholz HM;
National Cardiovascular Data Registry. Association
of door-to-balloon time and mortality in patients
admitted to hospital with ST elevation myocardial
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375
observation stays among Medicare
beneficiaries between 2001 and 2008
sparked concern among patients,
providers, and policymakers that the
AMI 30-day Readmission (NQF #0505)
measure does not capture the full range
of unplanned acute care events that
occur in the post-discharge period. In
order to address the rising use of
observation stays amongst Medicare
beneficiaries CMS proposed the Excess
Days in Acute Care after Hospitalization
for AMI (AMI Excess Days) measure for
use in the AMI model. The AMI Excess
Days measure comprehensively captures
all post-discharge, unplanned acute care
events as a count of the excess days a
hospital’s patients spent as inpatients,
in observation, or in the ED over a 3year measurement period.
In 2014, we developed the proposed
measure of excess days in acute care
following AMI hospitalization,
supported for use in the Hospital
Quality Reporting Program by the MAP
and submitted to the NQF for
endorsement. We note that this measure
was submitted for endorsement to the
NQF All-Cause Admissions and
Readmissions Committee in January
2016 with appropriate consideration for
sociodemographic status. The measure
was finalized for the HIQR Program FY
2018 payment determination (FY 2016
IPPS/LTCH final rule 80 FR 49690).
(b) Data Sources
We proposed to use Medicare Part A
and Part B FFS claims submitted by the
AMI model participant as the data
source for calculation of the AMI Excess
Days measure as harmonized with the
MORT–30–AMI(NQF #0230) and
READM–30–AMI(NQF #0505)
measures. Index admission diagnoses
and in-hospital comorbidities are
assessed using Medicare Part A claims.
Additional comorbidities prior to the
index admission are assessed as Part A
inpatient, outpatient, and Part B office
visit Medicare claims in the 12 months
prior to the index (initial) admission.
Enrollment and post-discharge mortality
status are obtained from Medicare’s
enrollment database which contains
beneficiary demographic, benefits/
coverage, and vital status information.
infarction: national cohort study. BMJ. 2009 May
19; 338:b1807. Krumholz HM, Merrill AR, Schone
EM, et al.: Patterns of hospital performance in acute
myocardial infarction and heart failure 30-day
mortality and readmission. Circulation.
Cardiovascular Quality & Outcomes. Sep
2009;2(5):407–413.
103 Krumholz HM, Merrill AR, Schone EM, et al.:
Patterns of hospital performance in acute
myocardial infarction and heart failure 30-day
mortality and readmission. Circulation.
Cardiovascular Quality & Outcomes. Sep
2009;2(5):407–413.
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asabaliauskas on DSK3SPTVN1PROD with RULES
(c) Cohort
The AMI Excess Days measure
includes Medicare FFS beneficiaries,
aged 65 years or older, discharged from
non-federal acute care hospitals with a
principal discharge diagnosis of AMI
and with a complete claims history for
the 12 months prior to index admission.
Eligible hospitalizations are defined
using the following ICD–10–CM codes:
I2109, I2111, I2119, I2129, I214, and
I213.
We proposed that the measure will
include index admissions to all nonfederal acute care hospitals, which
includes all participants in the AMI
model. Hospital performance will only
be publically reported for hospitals with
25 or more index admissions in the 3year measurement period. The AMI
model cohort would differ from the
hospital cohort that is currently
captured in the measure through the
HIQR Program. Although performance
on the measure will not be publically
reported for hospitals with fewer than
25 cases, such hospitals will receive
information about their performance on
the measure. We refer readers to section
III.B.5. of this final rule for a discussion
of AMI model participant selection.
(d) Inclusion and Exclusion Criteria
We proposed that an index admission
is the hospitalization to which the
excess days in acute care outcome is
attributed. We note that for purposes of
the EPMs where we need to identify
episodes that are included in the EPMs,
we use the term anchor hospitalization
to identify hospitalizations that initiate
EPM episodes for beneficiaries whose
care is included in the EPMs. In
describing the quality measures
themselves in detail in section III.E.4. of
the proposed rule (81 FR 50794), we use
the term index hospitalization to
identify hospitalizations of beneficiaries
whose outcomes are included in the
measures. Thus, anchor hospitalizations
and index hospitalizations would have
varying degrees of overlap depending on
the specific quality measure. The
measure includes the following index
admissions for patients:
• Having a principal discharge
diagnosis of AMI.
• Enrolled in Medicare FFS.
• Aged 65 or over.
• Not transferred from another acute
care facility.
• Enrolled in Medicare Part A and
Part B for the 12 months prior to the
date of index admission, and enrolled in
Part A during the index admission.
The measure excludes the following
index admissions for patients:
• Discharged alive on the day of
index admission or the following day
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who were not transferred to another
acute care facility.
• With inconsistent or unknown vital
status or other unreliable demographic
(age & gender) data.
• Enrolled in the Medicare hospice
program any time in the 12 months
prior to the index admission, including
the first day of the index admission.
• Discharged AMA.
• Without at least 30 days of postdischarge enrollment in FFS Medicare
as the 30-day excess days outcome
cannot be assessed for these patients.
Finally, for the purpose of this
measure, hospitalizations that occur
within 30 days of discharge from an
index admission are not eligible to also
be index admission. Thus, only one
index admission for AMI per beneficiary
is randomly selected for inclusion in the
cohort.
(e) Risk-Adjustment
We proposed for the AMI model to
align this measure with the riskadjustment methodologies adopted for
the AMI Excess Days measure under the
HIQR Program in accordance with
section 1886(b)(3)(B)(viii)(VIII) of the
Act, as finalized in the FY 2016 IPPS/
LTCH final rule (80 FR 49682). We also
note that the measure risk adjustment
takes into account patient age, sex, and
comorbidities to allow a fair assessment
of hospital performance. The measure
defines the patient risk factors for excess
days using diagnosis codes collected
from all patient claims 1 year prior to
a patient’s index hospitalization for
AMI. Accordingly, only comorbidities
that convey information about the
patient at the time of index admission
or in the 12 months prior, and not
complications that arise during the
course of the index hospitalization, are
included in the risk-adjustment model.
The measure does not adjust for
patients’ index admission source or
their discharge disposition (for example,
SNF) because these factors are
associated with the structure of the
health care system, not solely patients’
clinical comorbidities. Regional
differences in the availability of postacute care providers and practice
patterns might also exert undue
influence on measure results. In
addition, data fields that capture
discharge disposition, for example to
post-acute care settings, on inpatient
claims are not audited and are not as
reliable as diagnosis codes.
As previously noted in the AMI
Excess Days measure, ICD–10–CM
diagnosis codes present on Parts A and
B administrative claims are used to
inform the risk prediction for each
patient. Diagnostic codes from post-
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acute care settings are utilized in the
measure calculation, but this
information is only used to identify a
hospital’s patient case mix in order to
adequately adjust for differences in case
mix across hospitals. We note that the
patient diagnosis codes are grouped
using HCCs, which are clinically
relevant diagnostic groups of codes. The
CCs used in the risk-adjustment model
for this measure are provided on the
CMS QualityNet Web site: https://
www.qualitynet.org/dcs/
ContentServer?c=Page&pagename=
QnetPublic%2FPage%2FQnet
Tier4&cid=1219069856694.
In summary, age, sex, and
comorbidities present at the time of
index admission are adjusted for
differences in hospital case mix (patient
risk factors). The measure uses the HLM
statistical methodology for risk
adjustment.
(f) Calculating the Rate and Performance
Period
We proposed to calculate hospital 30day excess days in acute care with the
methodology used to risk standardize all
excess days measures used in CMS
hospital quality programs. The outcome
of the measure is a count of the number
of days the patient spends in acute care
within 30 days of discharge. We define
days in acute care as days spent in an
ED, admitted to an observation unit, or
admitted as an unplanned readmission
for any cause within 30 days from the
date of discharge from the index AMI
hospitalization. Each ED treat-andrelease visit is counted as 1 half-day (0.5
days). Observation stays are recorded in
terms of hours and are rounded up to
the nearest half-day. Each readmission
day is counted as 1 full day (1 day). We
count all eligible outcomes occurring in
the 30-day period, even if they are
repeat occurrences. The measure
incorporates ‘‘exposure time’’ (the
number of days each patient survives
after discharge, up to 30). This exposure
time is included to account for
differential risk for excess days in acute
care after discharge among those
patients who do not survive the full
post-discharge period. If a readmission
or observation stay extends beyond the
30-day window, only those days within
the 30-day window are counted.
Using a two-part random effects
model, or ‘‘hurdle’’ model, we account
for the structure of the data (patients
clustered within hospitals) and the
observed distribution of the outcome.
Specifically, we model the number of
acute care days for each patient as: (a)
The probability that the patient will
have a non-zero number of days in postdischarge acute care; and (b) the number
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of days the patient is predicted to spend
given that this number is non-zero. The
first part is specified as a legit model,
and the second part is specified as a
Poisson model, with both parts having
the same risk-adjustment variables and
each part having a random effect. This
model is used to calculate the predicted
(including random effects) and expected
(assuming random effects are zero)
number of days in post-discharge acute
care for each patient. The average
difference between patients’ predicted
and expected estimates for each hospital
is used to construct the riskstandardized excess days outcome. The
excess days outcome is reported at the
hospital-level per 100 discharges.
We define the time period for the
measure as within 30 days of the date
of discharge of the index AMI
hospitalization. The 30-day postdischarge window for assessing the
outcome is consistent with the claimsbased MORT–30–AMI (NQF #0230) and
Hybrid AMI Mortality (NQF #2473)
measures as noted in this final rule.
A 3-year rolling performance period
would be consistent with that used for
the HIQR Program (FY 2016 IPPS/LTCH
final rule 80 FR 49681). Section III.E.5.,
Form, Manner, and Timing of Quality
Measure Data Submission, of this final
rule summarizes the proposed measure
performance periods for AMI model
performance years 1 through 5. We note
that improvement on the AMI Excess
Days measure would be determined
from the immediate 3-year rolling
performance period available for the
year preceding the AMI model
performance year as explained in Table
41.
The proposal to include the Excess
Days in Acute Care after Hospitalization
for AMI measure in the AMI model is
included in § 512.411(a)(2). We sought
comment on this proposal to include the
Excess Days in Acute Care after
Hospitalization for AMI measure in the
AMI model to assess quality
performance.
The following is a summary of the
comments received and our responses.
Comment: Several commenters stated
that certain characteristics of the patient
population, such as patient
expectations, health literacy, inadequate
transportation, lack of caregiver support,
and socioeconomic status, contribute to
the rate of post-discharge
hospitalizations and disadvantage
hospitals serving poorer populations.
Response: We appreciate the
commenters’ concerns that
socioeconomic factors influence
patient’s risk of post-discharge returns
to the hospital for acute care. The AMI
EDAC measure currently does not
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include socioeconomic factors in the
risk-adjustment model. We routinely
monitor the impact of SDS on providers’
differential performance on our outcome
and payment measure.
The NQF is currently conducting a 2year trial, in which new measures and
measures undergoing maintenance
review will be assessed to determine if
risk-adjusting for sociodemographic
factors is appropriate. This trial entails
temporarily allowing inclusion of
sociodemographic factors in the riskadjustment approach for some
performance measures. At the
conclusion of the trial, NQF is expected
to issue recommendations on future
permanent inclusion of
sociodemographic factors. During the
trial, measure developers are
encouraged to submit information such
as analyses and interpretations as well
as performance scores with and without
sociodemographic factors in the risk
adjustment model. Several measures
developed by CMS have been brought to
NQF since the beginning of the trial,
including the AMI EDAC measure
which was submitted to NQF in January
2016 and is a part of the trial. Under the
guidance of NQF, we are making every
effort to be proactive in examining SDS
factors in quality measures by testing
SDS factors in the measures’ risk models
and making recommendations about
whether or not to include these factors
in the endorsed measure. We are still
awaiting final recommendations from
the NQF and intend to continue
engaging in the NQF process as we
consider the appropriateness of
adjusting for SDS factors in our outcome
measures. For more detailed
information about measures in the NQF
SDS trial period, we refer commenters
to: https://www.qualityforum.org/SES_
Trial_Period.aspx. Furthermore, we are
awaiting the findings of an ASPE report
on SDS factors in risk-adjustment.
Therefore, we are not currently
changing our risk-adjustment
methodology with respect to SDS factors
at this time. We will continue to
consider such factors in our ongoing
measure development and maintenance
activities.
Comment: Two commenters opposed
the AMI EDAC measure because it
measures quality based partly on care
provided in settings and facilities other
than those of the initial discharging
hospital.
Response: We believe these measures
reflect the actions of hospitals and the
care their patients receive postdischarge. Hospitals providing quality
inpatient care, conducting appropriate
discharge planning, and working with
providers and suppliers on appropriate
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377
follow-up care will likely perform well,
because the Medicare beneficiaries they
serve will have a reduced need for
excessive post-discharge services. The
risk adjustment methodology used for
these measures acknowledge the
differences in a given hospital’s patient
case mix, so that their performance can
be compared to a national average. We
recognize that the structure of health
care markets and practice patterns vary
geographically, beyond the variation in
patient case mix. However, as
previously mentioned, we believe that
the aforementioned opportunities for
hospitals to exert control over postdischarge services exist, regardless of
the degree of integration of a health
system. In cases where systems are not
well-integrated, there may be an even
greater opportunity for redesign of care
processes to achieve high performance
on these measures. We are collaborating
with our postacute care quality
programs and we will take the
commenters’ suggestions that similar
measures should be incorporated into
those programs under consideration.
However, we do not believe that it
would be appropriate to delay adoption
of this measure and the public reporting
of this valuable and actionable payment
information until such time as any
similar, postacute care measures are
implemented.
Comment: Several commenters
expressed concern with the outcome of
the AMI EDAC measures, questioning
whether excess days in acute care
provides a signal of quality. One
commenter opposed the AMI EDAC
measure because high readmission rates
could stem from the need to care for
chronically ill patients. The commenter
stated that hospitals should not be
punished for high readmission rates
when they are associated with lower
mortality rates and good access to
inpatient hospital care.
Response: We disagree that excess
days in acute care does not provide a
signal of quality. Our discussions with
patients and the TEP, as well as
published literature, indicate that acute
care utilization after discharge (that is,
return to the ED, observation stay, and
readmission), for any reason, is
disruptive to patients and caregivers,
costly to the health care system, and
puts patients at additional risk of
hospital-acquired infections and
complications. These measures are
meant to provide patients with a more
complete picture of potential postdischarge acute care use as they make
choices for their care. We are confident
that for most patients, remaining home
or remaining in a non-acute setting
rather than returning to the hospital
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indicates a better outcome. Although
some hospital returns are unavoidable,
others may result from poor quality of
care, overutilization of care or
inadequate transitional care.
Transitional care includes effective
discharge planning, transfer of
information at the time of discharge,
patient assessment and education, and
coordination-of-care and monitoring in
the post-discharge period. When
appropriate care transition processes are
in place (for example, a patient is
discharged to a suitable location,
communication occurs between
clinicians, medications are correctly
reconciled, timely follow-up is
arranged), fewer patients return to an
acute care setting, either for an ED visit,
observation stay, or hospital
readmission during the 30 days postdischarge. Numerous studies have
found an association between quality of
inpatient or transitional care and early
(typically 30-day) readmission rates 104
and ED visits 105 or a wide range of
conditions including AMI.
With respect to the commenter’s
concern that some hospitals care for a
greater number of chronically ill
patients, although the measures cannot
capture all reasons for variability among
hospitals, the EDAC measures
incorporate risk adjustment using
claims data to account for patient factors
that could account for the observed
variability. The measures use claims
based risk adjusters that are clinically
relevant and have strong relationships
with the outcome as has been done in
other claims-based outcome measures in
the Hospital IQR Program. This
approach was supported by the TEP. We
understand that hospitals have complex
patients with varying comorbidities.
104 Dean NC, Bateman KA, Donnelly SM, Silver
MP, Snow GL, Hale D. Improved clinical outcomes
with utilization of a community-acquired
pneumonia guideline. Chest. 2006;130(3):794–799.
Coleman EA, Parry C, Chalmers S, et al. 2006.
The care transitions intervention: Results of a
randomized controlled trial. Arch Intern Med
166:1822–1828.
Coleman EA, Smith JD, Frank JC, Min SJ, Parry
C, Kramer AM. Preparing patients and caregivers to
participate in care delivered across settings: The
Care Transitions Intervention. J Am Geriatr Soc
2004;52(11):1817–25.
Hansen LO, Young RS, Hinami K, et al.
Interventions to reduce 30-day rehospitalization: A
systematic review. 2011; 155(8):520–8.
Leppin AL, Gionfriddo MR, Kessler M, et al.
Preventing 30-day hospital readmissions: A
systematic review and meta-analysis of randomized
trials. JAMA Internal Med. 2014; 174(7):1095–107.
Hansen LO, Young RS, Hinami K, et al.
Interventions to reduce 30-day rehospitalization: A
systematic review. 2011; 155(8):520–8.
105 Mistiaen P, Francke AL, Poot E. Interventions
aimed at reducing problems in adult patients
discharged from hospital to home: A systematic
metareview. BMC Health Serv Res 2007;7:47.
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Although the cohort may contain
patients with different disease severity,
and therefore, different levels of risk,
the measure accounts for this range of
severity and risk because it is riskadjusted for 65 factors that are clinically
relevant and have strong relationships
with the outcome of acute care
utilization.
With respect to the comment that
hospitals not be punished for
readmission if they reduce patient
mortality, the goal of these measures is
not to punish hospitals for appropriate
readmissions; it is to help patients and
providers understand variation among
hospitals in the days that are spent by
patients in acute care settings following
a discharge for AMI. The measures
provide a broader perspective on postdischarge events than the current
readmission measures and are intended
to incentivize improvements in care
transitions from the hospital so that
patients are less likely to return to the
acute setting.
Comment: One commenter
recommended the AMI EDAC measure
be removed from the model to create a
better balance of provider risk and
reward. One commenter noted that costs
of a hospital emergency department or
observation visit following an index
admission is already captured and will
impact a hospital’s reimbursement in
this EPM. The commenter stated that
hospitals should not be further
penalized by including this measure in
the quality component. The commenter
also opposed the AMI EDAC measure
because it was not included in the list
of recommended quality measures in
the HCP LAN ‘‘Accelerating and
Aligning Clinical Episode Payment
Models: Coronary Artery Disease’’ draft
whitepaper released in May, 2016.
Response: We interpreted this
commenter’s concern to be that because
visits to the emergency department and
observation stays are less costly than
readmissions, by combining all of these
types of visits into a single outcome,
providers are not incentivized to use the
lower cost settings to deliver care
whenever appropriate. We agree that all
acute care utilization is not equal in its
disruption, cost, or risk to patients. In
the AMI EDAC measure, the weight of
events (such as observation or ED care)
is determined by the intensity of care
delivered to patients. Prolonged acute
care is more costly and worse from a
patient perspective than a brief ED visit.
That is why we elected to report the
AMI EDAC measure as a count of days:
Events lasting longer with more cost and
disruption (such as readmissions),
therefore, naturally weigh more than
brief events (such as ED visits) in the
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overall day count. This approach is
based on the believe that, from a patient
perspective, it is the count of total days
spent in acute care settings that is most
meaningful and representative of the
disruption, which is why we combine
day counts for each type of event and
do not separately report rates of each
type of event. This day count is also
valuable for hospitals, because a
hospital with a high number of ED visits
may still be able to achieve a low
number of total days in acute care by
actively coordinating care from the ED
and avoiding re-hospitalizations.
Because the EDAC measure had not
previously been publically reported at
the time of the HCP LAN report in May
2016, they did not consider it for
inclusion on the list of potential
measures to be used in cardiovascular
episode of payment models. However,
the AMI and CABG readmission
measures were recommended suggesting
that the HCP LAN did consider the
prevention or reduction of postdischarge acute care use as an important
quality metric to include in
cardiovascular episode payment
models.
Comment: One commenter supported
inclusion of the AMI EDAC measure in
the AMI EPM bundle and recommended
CMS include a measure of excess days
in acute care for the CABG and surgical
hip and femur fracture treatment EPM
bundles.
Response: We thank the commenters
for their support and will consider
additional measure development as was
suggested.
Comment: One commenter stated that
the AMI EDAC measure will not be
helpful to beneficiaries in navigating
their care nor will the measure be
actionable for hospitals given that
physicians dictate the discharge date.
Response: We disagree that the AMI
EDAC measure will not be helpful to
beneficiaries. We have developed the
AMI EDAC measure to try to provide
important patient-centered information
to providers. The measure supports
existing hospital incentives to further
invest in interventions and tools to
improve hospital care, better respond to
individual patient preferences, better
assess patient readiness for discharge,
and facilitate transitions to outpatient
status. Such interventions and tools will
reduce the likelihood of patients having
any return to the hospital and make it
more likely that patients who do return
have less severe illnesses which may
require fewer days of care. We disagree
that providers do not have the ability to
take meaningful actions that would have
an impact on patient outcomes as a
result of adopting the AMI EDAC
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measure. The measure spotlights the
excess number of days patients spend in
acute care (hospital readmissions,
observation stays, and ED visits) per 100
discharges during the first 30 days after
discharge from the hospital, relative to
the number spent by the same patients
discharged from an average hospital. We
believe the information provided to
hospitals through this measure will help
inpatient and outpatient providers
better understand the trajectory of care
for patients that have been discharged
from their facility. Specifically,
hospitals will be able to assess whether
patients discharged from their facility
have readmissions, observation stays,
and/or ED visits during the first 30 days
after discharge from the hospital.
Because the measure provides more
granular information regarding patient
discharge outcomes, this will assist
hospitals in developing targeted quality
improvement activities aimed at
improving transitions of care. We
believe that the measure will reduce
readmissions, observation stays, and/or
ED visits by encouraging hospitals to
further invest in interventions to
improve hospital care by better
assessing the readiness of patients for
discharge and facilitating quality
transitions to outpatient status.
Comment: One commenter requested
that CMS not include outpatient care
that is beneficial to patients as part of
the AMI EDAC measure.
Response: We do not dismiss the
importance of hospital-level care in
outpatient settings, such as the
Emergency Department, and support
hospitals using the level of care most
appropriate for each particular patient’s
condition. We agree with the
commenter that some returns to the
acute care setting are necessary and
beneficial to patients. The goal is not to
avoid all post-discharge acute care
service utilization, but to identify excess
use of acute care post-discharge. Acute
care utilization after discharge (that is,
return to the ED, observation stay, and
readmission), for any reason, is
disruptive to patients and caregivers,
costly to the health care system, and
puts patients at additional risk of
hospital-acquired infections and
complications. Although some factors
are outside hospitals’ control, when
appropriate care transition processes are
in place (for example, a patient is
discharged to a suitable location,
communication occurs between
clinicians, medications are correctly
reconciled, timely follow-up is
arranged), fewer patients return to an
acute care setting, whether for an ED
visit, observation stay, or hospital
readmission during the 30 days post-
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discharge period. Numerous studies
have found an association between
quality of inpatient or transitional care
and early (typically 30-day) readmission
rates and ED visits for a wide range of
conditions including AMI.
Comment: Several commenters
opposed the inclusion of the AMI EDAC
measure because it is not NQF endorsed
and wasn’t reviewed by the MAP for
inclusion in this EPM.
Response: Section
1886(b)(3)(B)(IX)(bb) of the Act provides
that in the case of a specified area or
medical topic determined appropriate
by the Secretary for which a feasible and
practical measure has not been endorsed
by the entity with a contract under
section 1890(a) of the Act, the Secretary
may specify a measure that is not so
endorsed as long as due consideration is
given to measures that have been
endorsed or adopted by a consensus
organization identified by the Secretary.
While we considered other existing
measures related to care transitions and
post-discharge acute care utilization that
have been endorsed by NQF or other
consensus organizations, we were
unable to identify any NQF-endorsed (or
other consensus organization endorsed)
measures that assess the full range of
post-discharge acute care use that
patients may experience.
Existing process measures capture
many important domains of care
transitions such as education,
medication reconciliation, and follow
up, but all require chart review and
manual abstraction. Existing outcome
measures are focused entirely on
readmissions or complications and do
not include observation stays or ED
visits. We are not aware of any other
measures that assess the quality of
transitional care by measuring 30-day
risk-standardized days in acute care
(hospital readmissions, observation
stays, and ED visits) following
hospitalization for AMI that have been
endorsed or adopted by a consensus
organization, and we have not found
any other feasible and practical
measures on this topic. However, we
note that this measure has been
submitted to NQF for endorsement
proceedings and received a
recommendation for endorsement from
the Admissions and Readmissions
Standing Committee as part of the AllCause Admissions and Readmissions
project in January 2016.
Furthermore, the AMI EDAC measure
was reviewed by clinical experts and a
TEP and was subject to separate public
input prior to being proposed for the
Hospital IQR Program. This measure
was also included on a publicly
available document entitled ‘‘List of
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379
Measures under Consideration for
December 1, 2014’’ (available at: https://
www.qualityforum.org/
ProjectMaterials.aspx?projectID=75367)
and has been reviewed by the NQF MAP
Hospital Workgroup. The measure was
conditionally supported pending the
examination of SDS factors and NQF
review and endorsement of the measure
update, as referenced in the MAP 2015
Final Recommendations Spreadsheet
(available at: https://
www.qualityforum.org/
ProjectMaterials.aspx?projectID=75367).
We will continue to work
collaboratively with stakeholders in
soliciting input on ways to refine this
measure in the future.
Comment: Several commenters
opposed the inclusion of the AMI EDAC
measure because it is not publicly
reported.
Response: CMS understands the
commenters concern that the measure
has not been publicly reported as of yet.
We held a dry run to educate hospitals
on the AMI and HF EDAC measures in
September 2015 and we reported
updated results to hospitals in the IQR
Preview Period in April 2016. Hospitals
results on the measures will be updated
with more recent data and reported to
hospitals in Spring 2017 as part of the
IQR Preview Period for the public
reporting release of the measures in July
2017.
Comment: One commenter opposed
inclusion of the AMI EDAC measure
because it overlaps with the AMI
readmission measure.
Response: In response to the
commenter’s concern about overlap of
the AMI EDAC and the current
readmission measure, we interpret the
commenter to be referring to the 30-day
AMI readmission measure. That
measure and the AMI EDAC measure
assess different outcomes. Although
both measures count readmission, the
30-day AMI readmission measure only
informs a hospital if a patient had a
readmission, and does not include all
postdischarge outcomes that matter to
patients, such as having to return to the
ED or spending time in the hospital
under observation, like the AMI EDAC
measure does. The AMI EDAC measure
provides patients a more comprehensive
and patient-centered perspective on the
30-day postdischarge experience
because it includes not only
readmissions, but also ED visits and
observation stays and captures the
numbers of days in these settings.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal, without
modification, to include the Excess Days
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in Acute Care after Hospitalization for
AMI measure in the AMI model.
(3) Hybrid Hospital 30-Day, All-Cause,
Risk-Standardized Mortality Rate
Following Acute Myocardial Infarction
(AMI) Hospitalization (NQF #2473)
(Hybrid AMI Mortality)
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(a) Background
In keeping with our goal to move
toward the use of EHRs, and in response
to stakeholder feedback to include
clinical data in outcome measures, we
have developed the hospital 30-day riskstandardized acute myocardial
infarction (AMI) mortality eMeasure
(NQF #2473) (herein after referred to as
Hybrid AMI Mortality measure). This
measure will incorporate a combination
of claims data and EHR data submitted
by hospitals, and because of these
combined data sources, it is referred to
as a hybrid measure. The Hybrid AMI
Mortality (NQF #2473) measure cohort
and outcome are identical to those in
the hospital 30-day, all-cause, riskstandardized mortality rate (RSMR)
following acute myocardial infarction
(AMI) (NQF #0230), measure which is
also being proposed in the AMI model.
In contrast to the claims-only MORT–
30–AMI (NQF #0230) measure, the
proposed Hybrid AMI Mortality (NQF
#2473) measure utilizes five core
clinical data elements (age; heart rate;
systolic blood pressure; troponin;
creatinine) in the risk-adjustment
methodology that are obtainable through
EHR data. These five core clinical data
elements are intended to reflect
patients’ clinical status when they first
present to an acute care hospital for
treatment of AMI. The clinical data
elements include age at the time of
admission, first-captured vital signs
(heart rate, systolic blood pressure)
collected within 2 hours of the patient
first presenting to the hospital, and the
first captured laboratory values
(troponin, creatinine) collected within
24 hours of the patient first presenting
to the hospital to which they are
subsequently admitted. We note that
these five data elements are routinely
collected on hospitalized adults with
AMI upon presentation to the hospital,
consistently captured in medical
records under current clinical practice,
and can be feasibly electronically
extracted from hospital EHRs.
In order to prepare for future
reporting of the Hybrid AMI Mortality
(NQF #2473) measure, we proposed to
seek and reward voluntary data
submission of the five core clinical data
elements included in the risk model for
the Hybrid AMI mortality (NQF #2473)
measure. We also proposed to require
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submission of six additional linking
variables (CCN, HIC Number, date of
birth, sex, admission date, and
discharge date) to ensure that the
datasets containing administrative
claims data are correctly linked with
EHR datasets containing the core
clinical data elements for proper risk
adjustment. The voluntary data
submission initiative will allow AMI
model participants to build processes to
extract and report the EHR data
elements, as well as support CMS
testing of systems required for Hybrid
AMI Mortality measure (NQF #2473)
production including data receiving and
auditing, the merging EHR and claims
data, calculation and production of
measure results.
Finally, we are considering using the
Hybrid AMI Mortality (NQF #2473)
measure as a replacement for the current
publicly reported MORT–30–AMI (NQF
#0230) measure in CMS models or
programs when appropriate. In future
years CMS may implement the Hybrid
AMI Mortality (NQF #2473) measure in
models and/or programs, such as in the
AMI model or HIQR Program. In that
event, we would propose to adopt the
measure through notice and comment
rulemaking. We refer readers to more
detailed information on the measure
specifications in this final rule and to
the CMS Web site at: https://cms.gov/
Medicare/Quality-Initiatives-PatientAssessment-Instruments/
HospitalQualityInits/MeasureMethodology.html.
(b) Data Sources
We proposed to use two sources of
data submitted by AMI model
participants to calculate the Hybrid AMI
Mortality (NQF #2473) measure:
Medicare Part A and Part B (FFS claims
to identify index admission diagnoses;
and EHR-captured clinical information
collected at presentation for riskadjustment of patients’ severity of
illness. Deaths are identified using the
Medicare Enrollment Database which
contains beneficiary demographic,
benefits/coverage, and vital status
information.
For the voluntary data submission
initiative, EHR data submission will
align with existing Electronic Clinical
Quality Measure (eCQM) standards and
data reporting procedures for hospitals.
In alignment with these standards, we
are posting the electronic specifications
for the Hybrid AMI Mortality (NQF
#2473) measure, which include the
Measure Authoring Tool (MAT) output
and value sets for all included data
elements, on the CMS Web site at:
https://cms.gov/Medicare/QualityInitiatives-Patient-Assessment-
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Instruments/HospitalQualityInits/
Measure-Methodology.html.
The Office of the National
Coordinator for Health Information
Technology (ONC) adopted quality
reporting document architecture
(QRDA) as the standard to support both
QRDA Category I (individual patient)
and QRDA Category III (aggregate) data
submission approaches for Meaningful
Use Stage 2 in the Health Information
Technology: Standards, Implementation
Specifications, and Certification Criteria
for Electronic Health Record
Technology, 2014 Edition; Revisions to
the Permanent Certification Program for
Health Information Technology rule (77
FR 54163 through 54292). We intend to
provide AMI model participants with
information about how many qualifying
admissions are submitted successfully.
We refer readers to the definition of
‘‘successful data submission’’ in section
III. E.4.a.(3)(vii) of this final rule.
We sought comment on our proposal
to use the following reporting
mechanisms in performance year 1:
QRDA, a simpler mechanism such as a
spreadsheet, or both. We proposed using
QRDA in AMI model performance years
2 through 5. The purpose of the use of
a simpler reporting format in the first
performance year reporting format in
the first performance year would be to
allow hospitals to perfect data
extraction with the 2017 data and
postpone mastery of reporting in the
QRDA format to the following year.
The following is a summary of the
comments received and our responses.
Comment: Several commenters had
concerns or provided suggestions about
the reporting standard for voluntary
reporting of EHR data elements. One
commenter recommended that CMS
require QRDA I file format for every
year of data submission, as it is already
required for the Inpatient Quality
Reporting and Meaningful Use
programs. Another commenter
recommended that CMS not allow data
to be submitted for performance year
(PY) 1 in a different file format than the
other years to avoid confusion. Several
commenters agreed with CMS in being
flexible in the voluntary reporting of the
clinical data elements by allowing
multiple reporting formats. One
commenter specifically appreciated the
flexible approach, as it created a better
balance of provider risk and reward.
Another commenter suggested that CMS
allow both QRDA and Excel reporting in
performance years 2 and 3.
Response: We thank commenters for
their suggestion to align standards
across our programs. We agree that it is
important to align these data collection
requirements to reduce burden on
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hospitals and improve interoperability.
We will take this feedback into
consideration as we shape future
proposals for hybrid measures. One of
the main tenets of the 2015 Edition
Health IT Certification Criteria final rule
(80 FR 62601) is to facilitate greater
interoperability for several clinical
health information purposes and enable
health information exchange through
new and enhanced certification criteria,
standards, and implementation
specifications. We note that we have
worked closely with ONC to enhance
testing and validation of certified
technology’s ability to capture,
exchange, and report electronic patient
data, such as improved testing and
certification through the Cypress CQM
testing and certification tool. As another
example, we note that ONC proposed a
2015 Edition ‘‘CQM—report’’
certification criterion in the FY 2016
IPPS/LTCH PPS proposed rule (80 FR
24613 through 24614). After
consideration of stakeholder input on
the standards for representing and
reporting CQM data in certified health
IT to improve the reliability and
consistency of such data reporting, we
finalized that hospitals can report using
either the 2014 or 2015 edition of
CEHRT (80 FR 49708). Furthermore, the
2015 Edition certification criteria
related to eCQMs offer increased data
portability and user access using the
established QRDA standards. Because of
the support for testing and certification
offered by ONC and their certification
tools and programs, the widespread
deployment of the QRDA standard and
CMS’ own recent experience that QRDA
can provide superior clinical data for
assessing quality and performance, we
will finalize our selection of QRDA–I as
the primary reporting standard for the
EPM Model Rule for program years 1–
3. If QRDA–I cannot be available to all
participants for year 1, we will make a
transitional submission format available
to systems using a spreadsheet-based
approach that will allow these sites
additional time to meet the QRDA-based
reporting requirements. We thank
commenters for their continued support
of improving the electronic reporting
process and plan to continue to make
improvements as standards evolve.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal, without
modification, to use the following
reporting mechanisms in performance
year 1: QRDA, a simpler mechanism
such as a spreadsheet, or both. We
proposed using QRDA in AMI model
performance years 2 through 5.
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(c) Cohort
The Hybrid AMI Mortality (NQF
#2473) measure includes Medicare FFS
beneficiaries, aged 65 years or older,
discharged from non-federal acute care
hospitals with a principal discharge
diagnosis of AMI. Eligible
hospitalizations are defined using the
following ICD–10–CM codes: I2109,
I2111, I2119, I2129, I214, and I213.
Hospital performance for the Hybrid
AMI Mortality (NQF #2473) measure
will not be publicly reported. However,
AMI model participants will receive
hospital-specific reports for each
performance year with information
about the success of their voluntary
submission of EHR data.
(d) Inclusion and Exclusion Criteria
We proposed that an index admission
is the hospitalization to which the
mortality outcome is attributed. The
Hybrid AMI mortality (NQF #2473)
measure includes the following index
admissions for patients:
• Having a principal discharge
diagnosis of AMI.
• Enrolled in Medicare FFS.
• Aged 65 or over.
• Not transferred from another acute
care facility.
• Enrolled in Medicare Part A and
Part B for the 12 months prior to the
date of index admission, and enrolled in
Part A during the index admission.
This measure excludes the following
index admissions for patients:
• Discharged alive on the day of
admission or the following day who
were not transferred to another acute
care facility.
• With inconsistent or unknown vital
status or other unreliable demographic
(age & gender) data.
• Enrolled in the Medicare hospice
program any time in the 12 months
prior to the index admission, including
the first day of the index admission.
• Discharged AMA.
• Without at least 30 days of postdischarge enrollment in FFS Medicare
as the 30-day mortality outcome cannot
be assessed for these patients.
Finally, for the purpose of this
measure, only one index admission per
patient for AMI is randomly selected for
inclusion in the cohort.
(e) Risk-Adjustment
We note that this measure is aligned
with the methodology approach adopted
for the MORT–30–AMI (NQF #0230)
measure under the HIQR Program in
accordance with section
1886(b)(3)(B)(viii)(VIII) of the Act, as
finalized in FY 2008 IPPS/LTCH final
rule (2008 IPPS/LTCH final rule 71 FR
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381
67960). The Hybrid AMI Mortality (NQF
#2473) measure uses EHR data and not
administrative claims data to adjust for
differences across hospitals in how atrisk their patients are for death, relative
to patients cared for by other hospitals.
The risk model was developed with
input from the literature, clinical and
EHR experts, and health IT vendors. In
order to be included as risk variables,
clinical data elements had to be—(1)
consistently obtained in the target
population (Medicare FFS AMI patients)
based on current clinical practice; (2)
captured with a standard definition and
recorded in a standard format within the
EHR; and (3) entered in structured fields
that are feasibly retrieved from current
EHR systems. The final measure
includes five variables that meet these
feasibility criteria, are present for most
patients at the time of clinical
presentation to the hospital, are
clinically relevant to patients with AMI,
and demonstrate a strong statistical
association with 30-day mortality.
Hospitals will submit the first-captured
data values of each of the five core
clinical data elements upon patient
presentation to the hospital. They are:
Age; the first-captured heart rate and
systolic blood pressure measured within
2 hours of a patient presenting to the
hospital; and the first captured troponin
and creatinine values within 24 hours of
a patient presenting to the hospital.
Although EHRs likely will ultimately
link across clinical episodes of care and
contain historical patient data, given the
EHR environment at the time of measure
development and inability to reliably
obtain data from the outpatient setting
prior to admission, we only considered
for inclusion those measure variables
that would be available and consistently
collected at first presentation to the
hospital.
The overall performance of the model
was comparable with or better than that
of current publicly reported outcome
measures.106 We tested measure score
validity by correlating the RSMR with
that of the previously validated,
publicly reported, administrative
claims-based MORT–30–AMI (NQF
#0230) measure. For more detailed
information on the model performance,
we refer readers to the CMS Web site at:
https://cms.gov/Medicare/QualityInitiatives-Patient-AssessmentInstruments/HospitalQualityInits/
Measure-Methodology.html.
106 AMI Mortality Hybrid Measure methodology
report. https://cms.gov/Medicare/Quality-InitiativesPatient-Assessment-Instruments/
HospitalQualityInits/Measure-Methodology.html.
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(f) Calculating the Risk-Standardized
Mortality Ratio (RSMR) and
Performance Period
We calculate hospital 30-day, allcause, risk-standardized mortality rates
consistent with the methodology used to
risk standardize all readmission and
mortality measures used in CMS
hospital quality programs. Using an
HLM statistical methodology for risk
adjustment, we calculate the hospitallevel risk-standardized mortality rate
following AMI hospitalizations by
producing a ratio of the number of
‘‘predicted’’ deaths (that is, the adjusted
number of deaths at a specific hospital)
to the number of ‘‘expected’’ deaths
(that is, the number of deaths if an
average quality hospital treated the
same patients) for each hospital and
then multiplying the ratio by the
national observed mortality rate.
We proposed defining AMI model
performance years as outlined in section
III.E.5. of the proposed rule (81 FR
50794). A performance period for the
voluntary data submission are those
timeframes in which a hospital
discharge occurs for an eligible AMI
index hospitalization. For performance
year 1 of the AMI model, participants
voluntarily submitting data will only be
requested to submit data for a 2-month
period. The 2-month period for AMI
voluntary data reporting was identified
due to data processing and coordination
with other proposed timelines for this
model. Data submitted for the first year
would be for cases that fulfill the
measure specifications described in
section III.E.4.a.(3) of this final rule, and
would be restricted to the data elements
from eligible AMI index hospitalizations
with discharges occurring between July
1, 2017 and August 31, 2017.
For performance year 2 of the AMI
model, AMI voluntary data reporting
would be 10 months of data for
discharges from eligible AMI
hospitalizations occurring between
September 1, 2017 and June 30, 2018.
For subsequent years of the model, the
performance periods for submission of
voluntary data will consist of discharges
within calendar-year 12-month time
periods from July 1 through June 30.
The proposed performance periods
would enable AMI model participants to
receive points toward the AMI model
composite quality score for data
submission starting in performance year
1. We sought comment on our proposal
for defining the data reporting period for
performance year 1 episodes for an AMI
model participant as eligible AMI index
hospitalizations with discharges
occurring between July 1, 2017 and
August 31, 2017, and for performance
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year 2 as eligible AMI hospitalizations
with discharges occurring between
September 1, 2017 and June 30, 2018,
with subsequent performance year data
reporting periods each being calendaryear 12 month periods and starting
every July 1st. Refer to Table 41 for
summary of performance periods.
The following is a summary of the
comments received and our responses.
Comment: Several commenters were
supportive of including a voluntary
hybrid AMI mortality measure in the
AMI episode payment model, but were
concerned about the timeline to report
clinical data. Commenters remarked that
hospitals need to redesign their EHRs to
collect and validate this data, and
recommended delaying the
implementation of this measure until
2018. One commenter recommended
that CMS delay the start date of the
hybrid AMI mortality measure to PY 2
because the proposed rule indicates that
data collection will start on July 1, 2017,
likely 6 months after release of the final
rule, which is not enough time for
vendors to consume the final rule and
specifications, as well as develop,
package, and release the required
updates to clients.
Response: We are aware of the burden
to hospitals associated with extraction,
validation, and submission of EHR data.
However, data submission for EHR data
elements used in the Hybrid AMI
Mortality Measure is voluntary, with an
incentive for hospitals that chose to
submit clinical data. Hospitals that are
unable to consume the specifications,
develop, package, and submit the EHR
data elements will not be penalized
under this payment program. Hospitals
that do not submit data in program year
one, will have the opportunity to submit
data and receive the incentive in
program years two through five.
Comment: One commenter noted that,
according to CMS’s Conditions of
Participation (CoPs), hospitals have
thirty days following discharge to
complete the medical records with final
diagnosis. Since CMS is proposing a
submission period for the AMI EHR data
60 days following the end of the
measurement period, this would only
allow thirty days following final
diagnosis to compile, validate, and
submit data. The commenter
recommended that CMS allow a 120 day
submission period after the end of the
measurement period.
Response: We will use a 30-day
claims maturity period to identify the
index admissions for the voluntary
reporting of EHR data for the AMI EPM
in program year 1. This will allow
hospitals 30 days to extract data on the
appropriate patients and submit the data
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to CMS. In program years 2 through 5
CMS will use the customary 90-day
claims maturity period to identify the
index admissions for the voluntary
reporting of EHR data for the AMI EPM.
This is the same 90-day claims maturity
period currently used in the claimsbased AMI 30-day mortality measure.
Hospitals will have 60 days to complete
EHR data extraction and submission to
CMS.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal, without
modification to define the data reporting
period for performance year 1 episodes
for an AMI model participant as eligible
AMI index hospitalizations with
discharges occurring between July 1,
2017 and August 31, 2017, and for
performance year 2 as eligible AMI
hospitalizations with discharges
occurring between September 1, 2017
and June 30, 2018, with subsequent
performance year data reporting periods
each being calendar-year 12 month
periods and starting every July 1st.
(g) Requirements for Successful
Submission of AMI Voluntary Data
In order for CMS to assess if AMI
model participants that submit the AMI
voluntary data are eligible for points
toward the hospital’s AMI model
composite quality score, we proposed to
use the following criteria to determine
if a participant has successfully
submitted AMI voluntary data:
Submission of the first-captured data
values for the five core clinical data
elements (age; first-captured heart rate
and systolic blood pressure measured
within 2 hours of a patient presenting to
the hospital; and first-captured troponin
and creatinine values measured within
24 hours of a patient presenting to the
hospitals), and six linking variables
required to merge with the CMS claims
data CCN, HIC Number, date of birth,
sex, admission date, and discharge
date).
All of these data elements must be
submitted for each qualifying AMI
hospitalization as described in section
III.E.5. of the proposed rule (81 FR
50794). If troponin was not measured in
the patient within 24 hours of
presentation to the hospital, the hospital
will still receive credit for successful
data submission if all other clinical data
elements (age, heart rate, systolic blood
pressure, and creatinine) as well as the
six linking variables are all reported in
the submission. We recognize that some
patients may have clinical signs or
symptoms that require emergent
treatment; and that in such cases
treatment might proceed without first
obtaining a troponin level. However
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hospitals are required to report troponin
values on all patients in whom a
troponin test was performed within the
first 24 hours of presenting to the
hospital and to indicate in their data
submission each instance in which a
troponin value was not measured and
therefore not available for a patient.
AMI voluntary data submission must
occur within 60 days of the end of the
most recent data collection period as
described in the listing of reporting
periods for all 5 model performance
years in section III.E.5. of the proposed
rule (81 FR 50794).
To fulfill AMI voluntary data
collection criteria for model
performance year 1, hospitals must
submit valid data on 50 percent of
qualifying AMI hospitalizations
(identified by the denominator in the
measure authorizing tool (MAT)
output). To successfully submit AMI
voluntary data for performance years 2
through 5, hospitals must submit valid
data for all five core clinical data
elements on over 90 percent of
qualifying AMI patients (with the
exception for troponin values described
in this section). Further details on
scoring of the voluntary data submission
are discussed in section III.E.3.e.(1) of
the proposed rule (81 FR 50794).
Each year, AMI model participants
voluntarily submitting data for this
measure will receive hospital-specific
reports that detail submission results
from the most recent performance
period. The reports will include the
match rate between the hospital’s
submitted EHR data and corresponding
claims data, as well as the proportion of
patient data submitted relative to all
qualifying AMI admissions with all five
core clinical data elements. As the
initiative sought to test and reward
hospitals’ ability to submit data,
hospitals will not be penalized for
missing troponin values for patients in
whom these values were not measured
at the time clinical treatment was
provided. If hospitals successfully
submit the remaining four clinical data
elements and all of the linking variables,
a missing troponin value which is due
to troponin having not been measured
in that patient will not result in an
unsuccessful submission as long as
hospitals indicate that the troponin
value was not measured and therefore
not available for that patient. Hospitals
will still be rewarded for successfully
submitting data in these cases.
We previously described a qualifying
AMI patient in section III.E.4.a.(3)(iii) of
the proposed rule (81 FR 50794). This
description is important, as these
patients are those for whom we seek
submission of voluntary data from AMI
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model participants. We selected the
requirement of submitting 90 percent of
qualifying AMI patients’ data for
performance years 2 through 5 because
this volume of cases will result in a high
probability that we will have a national
sample of AMI patient data
representative of each hospital’s patient
case mix. Having 90 percent of the data
for qualifying AMI patients in
performance years 2 through 5 will
enable an accurate and reliable
assessment of the potential
implementation of a Hybrid AMI
mortality (NQF# 2473) measure that
utilizes EHR data. In addition, the
testing we have performed in hospitals’
EHR data indicate that these data
elements are captured in over 90
percent of Medicare FFS patients who
are 65 years or older and admitted to
acute care hospitals for treatment of
AMI.
We sought public comment on the
proposed requirements to determine
successful voluntary submission of AMI
data, including the proposal to give
hospitals credit for data submission if
they submit all troponin values that
were actually measured, each of the
other four data elements, and all of the
linking variables; to not penalize
hospitals for failure to submit a troponin
value if it was not measured during the
admission; and the proposal on the
specific minimum percentage
requirements for data on the qualifying
AMI patients.
The following is a summary of the
comments received and our responses.
Comment: Several commenters agreed
with the potential value of hybrid
measures, but expressed concern about
the ability of hospitals to submit
accurate and reliable data. Several
commenters urged CMS not to finalize
any data submission requirements
beyond the first reporting period until
hospitals and the agency have gained
experience with measure submission.
Two commenters specifically
recommended the percent of data
submitted be gradually increased over
time, instead of 50 percent in
performance year 1, to 90 percent in
performance year 2. One commenter
expressed concern that hospitals that
did not participate in the Meaningful
Use Program that utilized QRDA
technology would be disadvantaged by
being required to submit clinical data in
this format. One commenter noted that
while CMS continues to conduct testing
of the electronic specifications in a few
hospitals, the QRDA format has not
demonstrated competency, and should
therefore not be included in the AMI
episode payment model.
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383
Response: We are sensitive to the
potential burden on hospitals of
mapping, extracting, and reporting data
elements from their EHRs. However, we
have tested the accuracy of mapping,
extracting, and reporting compiled data
from the EHRs of four separate health
systems, although we have not tested
data reporting in QRDA format. These
tests showed that, once instructed on
the Measure Authoring Tool output,
hospitals are able to submit accurate
EHR data on nearly all of their admitted
patients. We validated the electronically
extracted data by comparing values
identified through manual chart review.
This suggests that hospitals will be able
to extract and submit data on the subset
of their patients admitted with AMI. We
intend to require the QRDA format
beginning in program year two in order
to maintain alignment with
requirements for electronic clinical
quality measures. We will continue to
coordinate with ONC to maintain
alignment with standards and
requirements.
Comment: Several commenters
supported the proposal to include a
voluntary hybrid AMI mortality
measure in the AMI episode payment
model.
Response: We thank the commenters
for their support.
Comment: One commenter supported
the inclusion of clinical data into the
risk adjustment model for the Hybrid
AMI mortality measure. They suggested
hospitals submit additional standard
laboratory data, including white blood
cell count and albumin levels, to
support this measure and the
development of other quality measures.
Response: We thank the commenter
for their support. We sought to develop
a model that included key variables that
are clinically relevant, demonstrate a
strong statistical association with 30-day
mortality, and are feasible for use in a
hybrid measure. We developed the
following criteria to assess feasibility of
candidate variables: 1. Data that are
consistently obtained in the target
population based on current clinical
practice; 2. Data that are captured with
a standard definition and recorded in a
standard format; 3. Data that are entered
in structured fields that are feasibly
retrieved from current EHR systems.
During measure development the
members of the expert working group
reviewed the entire list of variables in
the National Cardiovascular Data
Registry ACTION Registry—Get With
The Guidelines database and selected
variables that met these criteria. We
then tested all candidate variables in
multivariate regression models with 30day mortality as the outcome. CMS did
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evaluate white blood cell count as one
of the candidate variables. However it
was not consistently predictive of
mortality in the risk model and
therefore was not included in the final
measure. Albumin was not considered.
We have developed two other hybrid
outcome measures which use additional
clinical data including the Hybrid
Hospital-Wide Readmission Measure
with Claims and Electronic Health
Record Data (NQF #2879), and the
Hybrid Hospital 30-day, All-cause, Riskstandardized Mortality Rate (RSMR)
Following Acute Ischemic Stroke with
Risk Adjustment for Stroke Severity
(NQF #2877). For descriptions of these
measures we refer readers to the FY
2016 IPPS/LTCH final rule 80 49698,
and the FY 2017 IPPS/LTCH final rule
81 57161, respectively.
Comment: Several commenters
referred to the hybrid AMI mortality
measure as a ‘‘hybrid eCQM’’.
Response: We wanted to clarify the
hybrid AMI mortality measure is a
claims-based measure, and not an
electronic clinically quality measure
(eCQM). The cohort and outcome for the
hybrid AMI mortality measure is
derived from claims and not the EHR.
Comment: One commenter
recommended that CMS release the final
specifications for the hybrid AMI
mortality measure as soon as possible
following the release of the final EPM
rule. The commenter further
recommended that CMS align the
specifications of the hybrid AMI
mortality measure as closely as possible
with other electronically submitted
CQMs available through the IQR
program.
Response: The measure specifications
have been published along with this
final rule. We refer readers to ‘‘Core
Clinical Data Elements and Hybrid
Measures’’ folder on our Web site at:
https://www.cms.gov/Medicare/QualityInitiatives-Patient-AssessmentInstruments/HospitalQualityInits/
Measure-Methodology.html.
We closely aligned our development
process for the hybrid AMI mortality
measure electronic specifications with
the electronic clinical quality measures
(eCQM) development process, according
to the MMS Blueprint. This process
included a stakeholder public comment
on the measure specifications, input
from experts in the field, Bonnie testing,
Mitre review, and VSAC review of the
value sets. Additionally, we tested the
electronic specifications in several
different health systems, which utilized
different EHRs. We aligned the
electronic specifications with eCQMs in
use by IQR and MU programs. Where
appropriate, we harmonized the use of
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the value sets and logic that are
currently used in these program
measures to ease the implementation of
the CCDE. We plan to continue these
harmonization efforts with each annual
update cycle.
Comment: One commenter requested
clarification how the hybrid AMI
mortality measure would be validated
using EHR and claims data.
Response: The hybrid AMI mortality
measures has been fully tested and
validated in merged Medicare claims
and registry data from the National
Cardiovascular Data Registry (NCDR)
ACTION Registry-Get With The
Guidelines. The measure was endorsed
by the NQF in 2014. However, we plan
to perform additional testing as a part of
measure reevaluation. We have not yet
determined when this testing will take
place.
Comment: One commenter believed
that CMS did not account for a small but
important population of patients that
arrive at a participating hospital in an
unstable, critical condition by not
excluding cardiogenic shock. The
commenter noted that this population is
at a higher risk of mortality, and thus
should have separate quality measures
that take into account the severity and
complexity of their medical conditions.
Response: In order to account for
differences in patient mix among
hospitals, the measures adjust for
variables (for example, age, comorbid
diseases, and indicators of patient
frailty) that are clinically relevant and
have relationships with the outcome. In
the case of the AMI measure, we risk
adjust for cardio-respiratory failure or
shock. However, the measure’s risk
model does not include a risk variable
for sepsis. A diagnosis of sepsis that
occurred during the index AMI
admission would not be used as a risk
variable because we cannot know
whether sepsis was present at the time
a patient first presented for care or was
a consequence of poor care received
during the hospitalization. During
measure development we did consider
including sepsis as a risk variable only
if it occurred in the 12 months prior to
the index admission. This variable was
not consistently found to predict
mortality in the measure cohort and,
therefore, was not included in the final
risk model.
Comment: One commenter was
supportive of using clinical data and
claims data to create a hybrid measure,
but noted combining these data is a
laudable endeavor. They noted that
determining the measure population
using administrative data would
increase the reporting burden on
hospitals.
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Response: We acknowledge that the
need to identify patients with a
principal discharge diagnosis of AMI
will be required to successfully map,
extract, and report data for the hybrid
AMI mortality measure. However, we
believe that the added benefit of
including clinical data in the measure’s
risk model outweighs the additional
burden of EHR data extraction and
reporting. Many commenters in this and
previous public comment periods have
expressed support for this approach.
Additionally, we note that reporting of
the EHR data elements is voluntary and
that hospitals will not be penalized if
they cannot or choose not to submit
these data.
Comment: One commenter requested
CMS explore the use of
sociodemographic factors in improving
the risk adjustment for the hybrid AMI
mortality measure.
Response: We appreciate the
commenters’ concerns that
socioeconomic factors influence
patient’s risk of post-discharge returns
to the hospital for acute care. The
hybrid AMI mortality measure currently
does not include socioeconomic factors
in the risk-adjustment model. We
routinely monitor the impact of SDS on
providers’ differential performance on
our outcome and payment measure.
The NQF is currently conducting a 2year trial, in which new measures and
measures undergoing maintenance
review will be assessed to determine if
risk-adjusting for sociodemographic
factors is appropriate. This trial entails
temporarily allowing inclusion of
sociodemographic factors in the riskadjustment approach for some
performance measures. At the
conclusion of the trial, NQF is expected
to issue recommendations on future
permanent inclusion of
sociodemographic factors. During the
trial, measure developers are
encouraged to submit information such
as analyses and interpretations as well
as performance scores with and without
sociodemographic factors in the risk
adjustment model. Several measures
developed by CMS have been brought to
NQF since the beginning of the trial,
including the AMI EDAC measure
which was submitted to NQF in January
2016. Under the guidance of NQF, we
are making every effort to be proactive
in examining SDS factors in quality
measures by testing SDS factors in the
measures’ risk models and making
recommendations about whether or not
to include these factors in the endorsed
measure. We are still awaiting final
recommendations from the NQF and
intend to continue engaging in the NQF
process as we consider the
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appropriateness of adjusting for SDS
factors in our outcome measures. For
more detailed information about
measures in the NQF SDS trial period,
we refer commenters to: https://
www.qualityforum.org/SES_Trial_
Period.aspx. Furthermore, we are
awaiting the findings of an ASPE report
on SDS factors in risk-adjustment.
Therefore, we are not currently
changing our risk-adjustment
methodology with respect to SDS
factors. We will continue to consider
such factors in our ongoing measure
development and maintenance
activities.
Comment: One commenter requested
CMS clarify when they would replace
the current publically reported AMI
mortality measure (NQF #0230) with the
hybrid AMI mortality measure (NQF
#2473).
Response: We have not yet
determined and timeline for replacing
the claims-only AMI mortality measure
(NQF #0230) with the hybrid AMI
mortality measure (NQF #2473).
However, we will make any changes to
the measures used in payment programs
through the notice of proposed
rulemaking. We point out that the
hybrid AMI mortality measure, similar
to other CMS condition-specific
outcome measures, requires a 3-year
measurement period in order for a
sufficient number of hospitals to meet
the threshold of having discharged at
least 25 patients with a principal
diagnosis of AMI to be included in the
measure cohort. Therefore, reporting
measure results would require a
minimum of 3 years of EHR data
collection.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal, without
modification, to give hospitals credit for
data submission if they submit all
troponin values that were actually
measured, each of the other four data
elements, and all of the linking
variables; to not penalize hospitals for
failure to submit a troponin value if it
was not measured during the admission;
and the proposal on the specific
minimum percentage requirements for
data on the qualifying AMI patients.
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b. CABG Model-Specific Measure
(1) Hospital 30-Day, All-Cause, RiskStandardized Mortality Rate (RSMR)
Following Coronary Artery Bypass Graft
(CABG) Surgery (NQF# 2558)(MORT–
30–CABG)
(a) Background
CABG is a common procedure
associated with considerable morbidity,
mortality, and health care spending. In
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2010, the National Hospital Discharge
Survey (NHDS) estimated that 219,000
patients underwent a total of 397,000
CABG procedures. Among Medicare
FFS beneficiaries, there were 139,133
hospitalizations for isolated CABG
surgery between July 2012 and June
2015. CABG surgeries are costly
procedures that account for the majority
of major cardiac surgeries performed
nationally. In FY 2009, isolated CABG
surgeries accounted for almost half (47.6
percent) of all cardiac surgery hospital
admissions in Massachusetts. This
provides an example of the frequency in
which a CABG is performed for a
patient admitted for cardiac surgery. In
2008, the average Medicare IPPS
payment was $30,546 for CABG without
valve replacement and $47,669 for
CABG with valve replacement surgeries.
The proposed Hospital-level 30-Day
Risk-Standardized Mortality Rate
(RSMR) following Coronary Artery
Bypass Graft (CABG) Surgery (MORT–
30–CABG) (NQF# 2558) measure
developed by CMS and currently
implemented in the HIQR program,
assesses hospitals’ 30-day, all-cause
risk-standardized rate of mortality,
which is rate of death after admission
for a CABG procedure for patients 65
and older during a 30-day period that
begins with the date of the index
admission for the specific hospital; an
index admission is the hospitalization
to which the mortality outcome is
attributed. The data indicate that the
median hospital-level risk-standardized
mortality rate for 2016 public reporting
on Hospital Compare was 3.2 percent,
with a range of 1.4 percent to 8.3
percent among hospitals. The variation
in these rates suggests that important
differences in the quality of care
delivered across hospitals exist, and that
there is room for improvement.
More details about the measure can be
found in the 2016 Annual Updates and
Specifications Report for CABG
Mortality posted on the CMS Web site
at: https://www.cms.gov/Medicare/
Quality-Initiatives-Patient-AssessmentInstruments/HospitalQualityInits/
Measure-Methodology.html.
The proposed MORT–30–CABG
(NQF# 2558) measure was endorsed by
the NQF in November 2014. This
measure has been publicly reported on
Hospital Compare since FY 2015 and
was incorporated into the HIQR
Program for FY 2017 (FY 2015 IPPS/
LTCH final rule 79 FR 50227).
(b) Data Source
Measure results for CABG model
participants are calculated using
Medicare Part A and Part B FFS claims
submitted by all non-federal short-term
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385
acute care hospitals for the MORT–30–
CABG (NQF# 2558) measure. Index
admission diagnoses and in-hospital
comorbidities are assessed using
Medicare Part A claims. Additional
comorbidities prior to the index
admission are assessed as Part A
inpatient, outpatient, and Part B office
visit Medicare claims in the 12 months
prior to the index (initial) admission.
Enrollment and post-discharge mortality
status are obtained from Medicare’s
enrollment database which contains
beneficiary demographic, benefits/
coverage, and vital status information.
(c) Cohort
The MORT–30–CABG (NQF# 2558)
measure includes Medicare FFS
beneficiaries, aged 65 years and older,
discharged from a non-federal shortterm acute care hospitals, Indian Health
Services hospitals, and critical access
hospitals, who received a qualifying
CABG procedure, and with a complete
claims history for the 12 months prior
to admission and through 30 days postprocedure.
We propose that the measure will
include index admissions to all nonfederal acute care hospitals, which
includes all hospitals in the CABG
model. Hospital performance will only
be publically reported for hospitals with
25 or more index admissions in the 3year measurement period. The CABG
model cohort would differ from the
hospital cohort that is currently
captured in the measure through the
HIQR Program. Although performance
on the measure will not be publicly
reported for hospitals with fewer than
25 cases, such hospitals will receive
information about their performance.
We refer readers to section III.B.5. of
this final rule for a discussion of CABG
model participant selection. For eligible
hospitalizations defined using ICD–9–
CM codes, we refer readers to the CMS
Web site at: https://cms.gov/Medicare/
Quality-Initiatives-Patient-AssessmentInstruments/HospitalQualityInits/
Measure-Methodology.html.
In order to include a clinically
coherent set of patients in the measure,
we sought input from clinical experts
regarding the inclusion of other
concomitant cardiac and non-cardiac
procedures, such as valve replacement
and carotid endarterectomy. Adverse
clinical outcomes following such
procedures are higher than those
following ‘‘isolated’’ CABG procedures,
that is, CABG procedures performed
without concomitant high-risk cardiac
and non-cardiac procedures. Limiting
the measure cohort to ‘‘isolated’’ CABG
patients is consistent with published
reports of CABG outcomes; therefore,
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the measure cohort considers only
patients undergoing isolated CABG as
eligible for inclusion in the measure. We
defined isolated CABG patients as those
undergoing CABG procedures without
concomitant valve or other major
cardiac, vascular or thoracic procedures.
In addition, our clinical experts,
consultants, and Technical Expert Panel
(TEP) members agreed that an isolated
CABG cohort is a clinically coherent
cohort for quality measurement. For
detailed information on the cohort
definition, we refer readers to the 2016
Annual Updates and Specifications
Report for CABG Mortality on the CMS
Web site at: https://www.cms.gov/
Medicare/Quality-Initiatives-PatientAssessment-Instruments/
HospitalQualityInits/MeasureMethodology.html.
(d) Inclusion and Exclusion Criteria
We proposed that an index admission
is the hospitalization to which the
mortality outcome is attributed. The
measure includes the following index
admissions for patients:
• Having a qualifying isolated CABG
surgery during the index admission;
• Enrolled in Medicare FFS Part A
and Part B for the 12 months prior to the
date of the index admission, and
enrolled in Part A during the index
admission; and,
• Aged 65 or over.
Isolated CABG surgeries are defined
as those CABG procedures performed
without the following concomitant
valve or other major cardiac, vascular,
or thoracic procedures:
• Valve procedures.
• Atrial and/or ventricular septal
defects.
• Congenital anomalies.
• Other open cardiac procedures.
• Heart transplants.
• Aorta or other non-cardiac arterial
bypass procedures.
• Head, neck, intracranial vascular
procedures.
• Other chest and thoracic
procedures.
This measure excludes the following
index admissions for patients:
• With inconsistent or unknown vital
status or other unreliable demographic
(age and gender) data.
• Discharged AMA.
• For patients with more than one
qualifying CABG surgery admission in
the measurement period, the first CABG
admission is selected for inclusion in
the measure and the subsequent CABG
admission(s) are excluded from the
cohort.
(e) Risk-Adjustment
We note that this measure is aligned
with the risk-adjustment methodologies
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adopted for the other mortality
measures developed by CMS and
implemented under the HIQR Program
in accordance with section
1886(b)(3)(B)(viii)(VIII) of the Act, as
finalized in FY 2008 IPPS/LTCH final
rule (2008 IPPS/LTCH final rule 71 FR
67960). We also note that the measure
risk adjustment takes into account
patient age, sex, and comorbidities to
allow a fair assessment of hospital
performance. The measure defines the
patient risk factors for mortality using
diagnosis codes collected from all
patient claims 1 year prior to patient
index hospitalization for CABG surgery.
ICD–10–CM diagnosis codes on Parts A
and B administrative claims are used to
inform the risk prediction for each
patient; diagnostic codes from postacute care settings are included in the
measure, but this information is only
used to identify a hospital’s patient case
mix in order to adequately adjust for
differences in case mix across hospitals.
Use of Parts A and B data does not mean
the measure is applicable to post-acute
care settings, only that it uses
comprehensive data to predict the risk
of the outcome and adjust for hospital
patient case mix. We note that the
patient diagnosis codes are grouped
using HCCs. The CCs used in the riskadjustment model for this measure are
provided on the CMS QualityNet Web
site: https://www.qualitynet.org/dcs/
ContentServer?c=Page&pagename=
QnetPublic%2FPage%2FQnet
Tier4&cid=1219069856694.
In summary, age, sex, and
comorbidities present at the time of
admission are adjusted for differences in
hospital case mix (patient risk factors).
The measure uses the HLM statistical
methodology for risk adjustment.
(f) Calculating the Risk-Standardized
Mortality Ratio (RSMR) and
Performance Period
We proposed to calculate hospital 30day, all-cause, risk-standardized
mortality rates (RSMR) consistent with
the methodology used to risk
standardize all readmission and
mortality measures used in CMS
hospital quality programs. Using HLM,
we calculate the hospital-level riskstandardized mortality rate following
AMI hospitalization by producing a
ratio of the number of ‘‘predicted’’
deaths (that is, the adjusted number of
deaths at a specific hospital) to the
number of ‘‘expected’’ deaths (that is,
the number of deaths if an average
quality hospital treated the same
patients) for each hospital and then
multiplying the ratio by the national
raw mortality rate. The RSMR is a point
estimate—the best estimate of a
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hospital’s mortality rate based on the
hospital’s case mix. For more detailed
information on the calculation
methodology we refer readers to the
CMS Web site at: https://www.cms.gov/
Medicare/Quality-Initiatives-PatientAssessment-Instruments/
HospitalQualityInits/MeasureMethodology.html.
A 3-year rolling performance period
would be consistent with that used for
the HIQR Program (FY 2015 IPPS/LTCH
final rule 79 FR 50227). Section III.E.5.
of the proposed rule (81 FR 50794),
Form, Manner, and Timing of Quality
Measure Data Submission, summarizes
the proposed measure performance
periods for CABG model performance
years 1 through 5. We note that
improvement on the MORT–CABG–30
(NQF #2558) measure would be
determined from the 3-year rolling
performance period available for the
year preceding the CABG model
performance year as explained in Table
41.
We sought comment on this proposal
to include Hospital-level 30-Day,AllCause, Risk-Standardized Mortality Rate
(RSMR) following CABG Surgery (NQF
#0230) measure in the CABG model to
assess quality performance.
The EPM episodes are structured as
90-day periods with the hospital as the
primary accountable entity, because we
believe 90 days is a period over which
hospitals have substantial ability to
influence the quality and efficiency of
the care that patients receive. We
believe that there could be significant
benefits for the quality of patient care
from using quality measures that
examine patient outcomes over a period
that extends at least as long as the EPM
episode (that is., 90 days after
discharge). In particular, we believe that
this approach could help ensure that
hospitals are held fully accountable for
the quality of the care they deliver
during the period covered by the
bundle.
However, as discussed in section III.E.
of the proposed rule (81 FR 50794),
several of the outcome measures we
proposed for these EPMs (MORT–30–
AMI (NQF #0230), AMI excess days,
and MORT–30–CABG (NQF #2558)
assess outcomes over a 30-day period
following discharge. We proposed the
use of these existing 30-day measures, at
least initially, because they are in wide
use and have gained acceptance among
hospitals and because the mortality
measures have been reviewed and
endorsed by the National Quality
Forum.
Nevertheless, we believe that it is
appropriate to seek to adapt these
measures or to develop new related
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measures to assess outcomes over a
longer timeframe, including timeframes
at least as long as the EPM episodes. In
developing measures that use a longer
timeframe, CMS would perform
empirical analyses to ensure that such
measures are scientifically robust and to
identify appropriate risk-adjustment
approaches. Once such measures were
available, CMS would consider when
and how to incorporate these measures
into the EPM quality payment
methodology. We invite public
comment on refining the existing 30-day
measures to extend the period of
outcome assessment following
admission for AMI or CABG surgery,
including the length of the period that
should be examined by an extended
measure, any important considerations
in developing the refined measures, and
any factors CMS should consider in
incorporating these measures into the
EPM quality payment methodologies.
The following is a summary of the
comments received and our responses.
Comment: One commenter suggested
that the CABG mortality measure not be
used in the EPM until it had been
reviewed by the NQF in the context of
the ongoing SDS trial period. The
commenter supported the use of the
CABG mortality measure if CMS
includes SDS factors in the riskadjustment because mortality is tied to
community factors that are typically
outside of the direct control of health
care providers.
Response: We appreciate the
commenters’ concerns that
socioeconomic factors influence
patient’s risk of post-discharge returns
to the hospital for acute care. The CABG
mortality measure currently does not
include socioeconomic factors in the
risk-adjustment model. We routinely
monitor the impact of SDS on providers’
differential performance on our outcome
and payment measure.
The NQF is currently conducting a 2year trial, in which new measures and
measures undergoing maintenance
review will be assessed to determine if
risk-adjusting for sociodemographic
factors is appropriate. This trial entails
temporarily allowing inclusion of
sociodemographic factors in the riskadjustment approach for some
performance measures. At the
conclusion of the trial, NQF is expected
to issue recommendations on future
permanent inclusion of
sociodemographic factors. During the
trial, measure developers are
encouraged to submit information such
as analyses and interpretations as well
as performance scores with and without
sociodemographic factors in the risk
adjustment model. Although the CABG
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mortality measure was not included in
the SDS trial period, several measures
developed by CMS have been brought to
NQF since the beginning of the trial,
including several mortality. Under the
guidance of NQF, we are making every
effort to be proactive in examining SDS
factors in quality measures by testing
SDS factors in the measures’ risk models
and making recommendations about
whether or not to include these factors
in the endorsed measure. We are still
awaiting final recommendations from
the NQF and intend to continue
engaging in the NQF process as we
consider the appropriateness of
adjusting for SDS factors in our outcome
measures. For more detailed
information about measures in the NQF
SDS trial period, we refer commenters
to: https://www.qualityforum.org/SES_
Trial_Period.aspx. Furthermore, we are
awaiting the findings of an ASPE report
on SDS factors in risk-adjustment.
Therefore, we are not currently
changing our risk-adjustment
methodology with respect to SDS
factors. We will continue to consider
such factors in our ongoing measure
development and maintenance
activities.
Comment: Once commenter expressed
agreement with the decision not to
include the CABG readmission measure
in this EPM stating that incentives are
already in place for hospitals to lower
excess readmission rates and it would
be duplicative to hold hospitals
accountable to these measures.
Response: We thank the commenter
for their support.
Comment: Several commenters
suggested alternative measures be used
in the CABG EPM. One commenter
suggested that CMS use the CABG
Composite Score suggesting that it is
more comprehensive because it is based
on several outcomes, not solely
mortality and is used by most
cardiothoracic surgery programs. They
also note that there is more variation
among hospitals in the Composite Score
compared with a mortality measure.
Another commenter suggested that CMS
use measures developed by the Society
of Thoracic Surgeon (STS) for
benchmarking instead of the CMS
measure.
Response: We agree with commenters
that this is a comprehensive NQFendorsed composite measure with
strong potential to meaningfully
improve quality. The STS CABG
Composite Score measures surgical
performance based on a combination of
11 NQF-endorsed process and outcomes
measures, grouped into four domains.
We are incorporating the use of the
CABG Composite Score performance
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387
measure (NQF #0696) as a voluntary
option weighted at 10 percent. By
including this measure in the CABG
EPM, we are reducing proposed
HCAHPS and mortality weights by 5
percent each for those hospitals
choosing to voluntary submit this data.
We intend to address the weighting and
the use of the actual measure score in
the next EPM rulemaking cycle. For
more information about the STS
Composite Score, we refer readers here:
https://www.sts.org/sts-public-reportingonline/cabg-composite-score.
Comment: One commenter expressed
concern 75 percent of a hospital’s
quality score for CABG based upon 30day hospital mortality places a heavy
reliance on only this quality measure.
This commenter was also concerned
that with this weighing propose,
hospitals with few CABG cases would
be further disadvantaged since there
will be less data used to calculate the
hospital’s quality score.
Response: To ensure hospitals have
enough cases to produce a valid quality
score, the CABG mortality measure uses
3 years of claims data to calculate the
measure. Hospitals must have at least 25
qualifying index admissions within the
3-year measurement period to calculate
and publically report a measure result.
We do not believe these measures
disadvantage smaller volume hospitals.
We have found that hospitals with few
cases tend to have measure results that
are close to the national average hospital
rate and are therefore rarely identified
as poor performing outliers.
Comment: One commenter disagreed
with the proposal to use the CABG
mortality measure in the CABG EPM
because this measure is used in the
Hospital Inpatient Quality Reporting
program (‘‘HIQR’’). The commenter
suggested that the CABG mortality
measure would do little to characterize
the quality performance beyond what is
already reported through existing CMS
programs. The commenter suggested
that CMS develop a new measure of
complications following CABG surgery.
Response: We disagree with the
suggestion that including the CABG
mortality measure would do little to
characterize the quality performance
beyond what is already reported
through the existing CMS programs.
Mortality is a very serious outcome for
AMI and CABG care and is one that
EPM model participants should manage
to avoid under the AMI and CABG
models.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal, with
modification, to incorporate the STS
CABG Composite Score measure (NQF
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#0696) from the STS Data Registry as a
voluntary option weighted at 10
percent. The measures that were
proposed, along with these STS CABG
measures are highly relevant to the
clinical conditions that are the focus of
the model. To use other measures would
increase administrative burden on
participant hospitals which we do not
believe would be appropriate for this
model. Even though the measures are
used in other CMS programs, we do not
believe their use in this model leads to
inappropriate financial risk because
they are relevant measures of patient
experience and outcomes.
c. SHFFT Model-Specific Measures
(1) Hospital-Level Risk-Standardized
Complication Rate (RSCR) Following
Elective Primary Total Hip Arthroplasty
(THA) and/or Total Knee Arthroplasty
(TKA) (NQF #1550) (Hip/Knee
Complications)
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(a) Background
THA and TKA are commonly
performed procedures for the Medicare
population that improve quality of life.
Between 2009 and 2012, there were
337,419 total hip arthroplasty (THA)
procedures and 750,569 total knee
arthroplasty (TKA) procedures for
Medicare FFS patients 65 years and
older.107 The post-operation
complications of these procedures are
high considering these are elective
procedures, and usually, the
complications are devastating to
patients. For example, rates for
periprosthetic joint infection, a rare but
devastating complication, have been
reported at 2.3 percent for THA/TKA
patients with rheumatoid arthritis after
1 year of follow-up 108 and 1.6 percent
in Medicare patients undergoing TKA
after 2 years of follow up.109 Two
studies reported 90-day death rates
following THA at 0.7 percent 110 and 2.7
107 Suter L, Grady JL, Lin Z et al.: 2013 Measure
Updates and Specifications: Elective Primary Total
Hip Arthroplasty (THA) And/Or Total Knee
Arthroplasty (TKA) All-Cause Unplanned 30-Day
Risk-Standardized Readmission Measure (Version
2.0). 2013. https://www.cms.gov/Medicare/QualityInitiatives-Patient-Assessment-Instruments/
HospitalQualityInits/Measure-Methodology.html.
108 Bongartz, T, Halligan CS, Osmon D, et al.
Incidence and risk factors of prosthetic joint
infection after total hip or knee replacement in
patients with rheumatoid arthritis. Arthritis Rheum.
2008; 59(12): 1713–1720.
109 Kurtz S, Ong K, Lau E, Bozic K, Berry D,
Parvizi J. Prosthetic joint infection risk after TKA
in the Medicare population. Clin Orthop Relat Res.
2010;468:5.
110 Cram P, Vaughan-Sarrazin MS, Wolf B, Katz
JN, Rosenthal GE. A comparison of total hip and
knee replacement in specialty and general
hospitals. J Bone Joint Surg Am. Aug
2007;89(8):1675–1684. Soohoo NF, Farng E,
Lieberman JR, Chambers L, Zingmond, DS. Factors
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percent, respectively.111 Reported rates
for pulmonary embolism following TKA
range from 0.5 percent to 0.9
percent.112 113 114 Reported rates for
septicemia range from 0.1 percent,
during the index admission 115 to 0.3
percent, 90-days following discharge for
primary TKA.116 Rates for bleeding and
hematoma following TKA have been
reported at 0.94 percent 117 to 1.7
percent.118 Combined, THA and TKA
procedures account for the largest
payments for procedures under
Medicare.119 Both hip and knee
arthroplasty procedures improve the
function and quality of life of patients
with disabling arthritis, and the volume
and cost associated with these
procedures are very high. We believe it
is important to assess the quality of care
provided to Medicare beneficiaries who
undergo one or both of these
procedures.
The proposed measure developed by
CMS, and currently implemented in the
HIQR and HVBP Programs and the CJR
model, assesses a hospital’s risk
standardized complication rate, which
is the rate of complications occurring
That Predict Short-term Complication Rates After
Total Hip Arthroplasty. Clin Orthop Relat Res. Sep
2010;468(9):2363–2371.
111 Soohoo NF, Farng E, Lieberman JR, Chambers
L, Zingmond, DS. Factors That Predict Short-term
Complication Rates After Total Hip Arthroplasty.
Clin Orthop Relat Res. Sep 2010;468(9):2363–2371.
Cram P, Vaughan-Sarrazin MS, Wolf B, Katz JN,
Rosenthal GE. A comparison of total hip and knee
replacement in specialty and general hospitals. J
Bone Joint Surg Am. Aug 2007;89(8):1675–1684.
112 Mahomed NN, Barrett JA, Katz JN, et al. Rates
and outcomes of primary and revision total hip
replacement in the United States medicare
population. J Bone Joint Surg Am. Jan 2003;85–
A(1):27–32.
113 Khatod M, Inacio M, Paxton EW, et al. Knee
replacement: epidemiology, outcomes, and trends
in Southern California: 17,080 replacements from
1995 through 2004. Acta Orthop. Dec
2008;79(6):812–819.
114 Solomon DH, Chibnik LB, Losina E, et al.
Development of a preliminary index that predicts
adverse events after total knee replacement.
Arthritis & Rheumatism. 2006;54(5):1536–1542.
115 Browne, JA, Cook C, Hofmann A, Bolognesi
MP. Postoperative morbidity and mortality
following total knee arthroplasty with computer
navigation. Knee. 2010;17(2): 152–156.
116 Cram P, Vaughan-Sarrazin MS, Wolf B, Katz
JN, Rosenthal GE. A comparison of total hip and
knee replacement in specialty and general
hospitals. J Bone Joint Surg Am. Aug
2007;89(8):1675–1684.
117 Browne, JA, Cook C, Hofmann A, Bolognesi
MP. Postoperative morbidity and mortality
following total knee arthroplasty with computer
navigation. Knee. 2010;17(2): 152–156.
118 Huddleston JI, Maloney WJ, Wang Y, Verzier
N, Hunt DR, Herndon JH. Adverse Events After
Total Knee Arthroplasty: A National Medicare
Study. The Journal of Arthroplasty. 2009;24(6,
Supplement 1): 95–100.
119 Bozic KJ, Rubash HE, Sculco TP, Berry DJ., An
analysis of Medicare payment policy for total joint
arthroplasty. J Arthroplasty. Sep 2008; 23(6 Suppl
1):133–138.
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after elective primary THA and TKA
surgery. The measure outcome is the
rate of complications occurring after
THA and TKA during a 90-day period
that begins with the date of the index
admission for a specific hospital; an
index admission is the hospitalization
to which the complications outcome is
attributed. The following outcomes
(either one or more) are considered
complications in this measure: Acute
myocardial infarction, pneumonia, or
sepsis/septicemia within 7 days of
admission; surgical site bleeding,
pulmonary embolism or death within 30
days of admission; or mechanical
complications, periprosthetic joint
infection or wound infection within 90
days of admission. The data indicated
that the median hospital-level riskstandardized complication rate for 2008
was 4.2 percent, with a range from 2.2
percent to 8.9 percent in hospitals. The
variation in complication rates suggests
that there are important differences in
the quality of care delivered across
hospitals, and that there is room for
quality improvement.
In 2010, we developed the proposed
measure of hospital-level riskstandardized complication rate (RSCR)
following elective primary THA and
TKA surgery, which was later endorsed
by the NQF (NQF #1550). In its PreRulemaking Report for 2012,120 the
Measure Application Partnership (MAP)
also recommended the inclusion of this
measure in the HIQR Program; we have
not submitted this measure for use in
post-acute care settings as the measure
was developed for the acute care
hospital setting. This measure has been
publicly reported on Hospital Compare
since FY 2014 and in the HIQR Program
since FY 2015 (FY 2015 IPPS/LTCH
final rule 79 FR 50062). Finally, we note
a comparison of the median hospitallevel risk-standardized complication
rates for hospitals between April 1, 2011
and March 31, 2014 illustrates a
performance gap (median RSCR of 3.1
percent with a range from 1.4 percent to
6.9 percent) indicating there is still
room for quality improvement.121
(b) Data Sources
Measure results are calculated using
Medicare Part A and Part B FFS claims
120 National Quality Forum. MAP Final Reports.
Available at: https://www.qualityforum.org/
Publications/2012/02/MAP_Pre-Rulemaking_
Report__Input_on_Measures_Under_Consideration_
by_HHS_for_2012_Rulemaking.aspx. Accessed on
April 16, 2015, page 78.
121 Suter L, Zang W, Parzynski C, et al. 2015
Procedure-Specific Complication Measures Update
and Specifications: Elective Primary Total Hip
Arthroplasty (THA) and/or Total Knee Arthroplasty
(TKA) Risk-Standardized Complication Measure
(Version 4.0). 2015.
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submitted by all non-federal acute care
hospitals. Index admission diagnoses
and in-hospital comorbidities are
assessed using Medicare Part A claims.
Additional comorbidities prior to the
index admission are assessed using Part
A inpatient, outpatient, and Part B office
visit Medicare claims in the 1 to 2
months prior to the index (initial)
admission. Enrollment and postdischarge mortality status are obtained
from Medicare’s enrollment database
which contains beneficiary
demographic, benefits/coverage, and
vital status information.
(c) Cohort
The Hip/Knee Complications (NQF
#1550) measure includes Medicare FFS
beneficiaries, aged 65 years or older,
admitted to non-federal acute care
hospitals for elective primary THA or
TKA. THA and TKA procedures eligible
for inclusion are defined using ICD–9–
CM codes 81.51 and 81.54, respectively.
The following 24 codes in ICD–10
correspond to these two ICD–9–CM
codes.
• ICD–9 code 81.51 (Total Hip
Replacement) = ICD–10 codes 0SR90J9,
0SR90JA, 0SR90JZ, 0SRB0J9, 0SRB0JA,
0SRB0JZ.
• ICD–9 code 81.54 (Total Knee
Replacement) = ICD–10 codes 0SRC07Z,
0SRC0JZ, 0SRC0KZ, 0SRD07Z,
0SRD0JZ, 0SRD0KZ, 0SRT07Z,
0SRT0JZ, 0SRT0KZ, 0SRU07Z,
0SRU0JZ, 0SRU0KZ, 0SRV07Z,
0SRV0JZ, 0SRV0KZ, 0SRW07Z,
0SRW0JZ, 0SRW0KZ.
We proposed that the measure will
include index admissions to all nonfederal acute care hospitals, which
includes all hospitals included in the
SHFFT model. Hospital performance
will only be publicly reported for
hospitals with 25 or more index
admissions in the 3-year measurement
period. The SHFFT model participant
hospital cohort would differ from the
hospital cohort that is currently
captured in the measure through the
HIQR Program. Although performance
on the measure will not be publicly
reported for hospitals with fewer than
25 cases, such hospital will receive
information about their performance.
We refer readers to section III.B.5. of
this final rule for discussion of the
selection of participants for the SHFFT
model.
(d) Inclusion and Exclusion Criteria
An index admission is the
hospitalization to which the
complication outcome is attributed. We
note that for purposes of the EPMs
where we need to identify episodes that
are included in the EPMs, we use the
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term anchor hospitalization to identify
hospitalizations that initiate EPM
episodes for beneficiaries whose care is
included in the EPMs. In describing the
quality measures themselves in detail in
section III.E.4. of the proposed rule (81
FR 50794), we use the term index
hospitalization to identify
hospitalizations of beneficiaries whose
outcomes are included in the measures.
Thus, anchor hospitalizations and index
hospitalizations would have varying
degrees of overlap depending on the
specific quality measure. The MS–DRGs
for the anchor or chained
hospitalizations included in the SHFFT
model will identify beneficiaries that do
not overlap with the index
hospitalizations used in the SHFFT
model measures, since the SHFFT
model measures use the elective THA/
TKA cases as proxies for hip or femur
fracture cases. The measure includes the
following index admissions for patients:
• Enrolled in Medicare FFS.
• Aged 65 or over.
• Enrolled in Part A and Part B
Medicare for the 12 months prior to the
date of index admission and during the
index admission.
• Have a qualifying elective primary
THA/TKA procedure; elective primary
THA/TKA procedures are defined as
those procedures without any of the
following:
++ Femur, hip, or pelvic fractures
coded in principal or secondary
discharge diagnosis fields of the index
admission.
++ Partial hip arthroplasty (PHA)
procedures with a concurrent THA/
TKA.
++ Revision procedures with a
concurrent THA/TKA.
++ Resurfacing procedures with a
concurrent THA/TKA.
++ Mechanical complication coded
in the principal discharge diagnosis
field.
++ Malignant neoplasm of the pelvis,
sacrum, coccyx, lower limbs, or bone/
bone marrow or a disseminated
malignant neoplasm coded in the
principal discharge diagnosis field.
++ Removal of implanted devices/
prostheses.
++ Transfer from another acute care
facility for the THA/TKA.
The following admissions would be
excluded from the measure:
• Admissions for patients discharged
AMA.
• Admissions for patients with more
than two THA/TKA procedure codes
during the index hospitalization.
• Consistent with the FY 2016 IPPS/
LTCH proposed rule, admissions for
patients without at least 90 days postdischarge enrollment in FFS Medicare;
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389
this exclusion is an update to the
measure signaled in the HIQR Program
section of the FY2016 IPPS/LTCH
proposed rule (80 FR 24572 through
24574) to ensure that disproportionate
Medicare FFS disenrollment does not
bias the measure results.
After applying these exclusion
criteria, we randomly select one index
admission for patients with multiple
index admissions in a calendar year.
Therefore, we exclude the other eligible
index admissions in that year.
Identification and use of a single index
admission in a calendar year is done
because this measure includes mortality
as an outcome and the probability of
death increases with each subsequent
admission, preventing each admission
from being mutually independent.
Therefore only one index admission is
selected to maintain measure integrity.
We note that the Hip/Knee
Complications (NQF #1550) measure
does not capture patients undergoing
partial hip arthroplasty procedures. We
excluded partial hip arthroplasty
procedures primarily because partial
hip arthroplasty procedures are done for
hip fractures. Therefore, they are not
elective procedures. Also, partial hip
arthroplasty procedures are typically
performed on patients who are older,
frailer, and have more comorbid
conditions. Although this exclusion is
not fully harmonized with MS–DRGs
469 and 470, which includes partial hip
arthroplasty procedures, use of this
measure will still provide strong
incentives for improving and
maintaining care quality across joint
replacement patients as hospitals
typically develop protocols for lower
extremity joint arthroplasty that will
address peri-operative and postoperative care for both total and partial
hip arthroplasty procedures. Fiscal year
2014 claims data indicate that among
inpatient claims with MS–DRG 469 or
470, partial hip arthroplasty (ICD–9–CM
procedure code: 81.52) accounted for 12
percent, while Total Hip Replacement
(ICD–9 code: 81.51) and total knee
replacement (ICD–9 code: 81.54)
accounted for 87 percent (80 FR 73300
and 73474). We also note that the same
surgeons and care teams frequently
perform both procedures. Therefore,
quality improvement efforts initiated in
response to the Hip/Knee Complications
(NQF #1550) measure are likely to
benefit patients undergoing similar
elective procedures, such as partial hip
arthroplasty and revision THA/TKA
procedures, and possibly even nonelective lower extremity hip fracture
surgery as described in section III.E.2.d.
of the proposed rule (81 FR 50794).
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(e) Risk-Adjustment
We note that this measure is aligned
with the risk-adjustment methodologies
adopted for the HIQR Program and
HRRP in accordance with section
1886(b)(3)(B)(viii)(VIII) of the Act (FY
2013 IPPS/LTCH final rule 77 FR 53516
through- 53518 and FY 2015 IPPS/LTCH
final rule; 79 FR 50024, 50031, and
50202). We note that the risk-adjustment
takes into account the patient case-mix
to assess hospital performance. The
patient risk factors are defined using the
HCCs.122 The HCCs used in the risk
adjustment model for this measure are
provided on the CMS QualityNet Web
site: (https://www.qualitynet.org/dcs/
ContentServer?c=Page&pagename=
QnetPublic%2FPage%2FQnet
Tier4&cid=1228772782693). We note
that the measure uses ICD–9–CM
diagnosis codes on Parts A and B
administrative claims for the year prior
to and including the index admission.
The ICD–9–CM codes are used to inform
the risk prediction for each patient.
Diagnostic codes from post-acute care
settings are utilized for the measure
calculation, but this information is only
used to identify a hospital’s patient case
mix in order to adequately adjust for
differences in case mix across hospitals.
Use of the administrative claims data
does not mean the measures are
applicable to post-acute care settings,
only that they use comprehensive data
to predict the risk of the outcome and
adjust for hospital patient case mix. The
measure methodology defines
’’complications’’ as acute myocardial
infarction (AMI); pneumonia; sepsis/
septicemia; pulmonary embolism;
surgical site bleeding; death; wound
infection; periprosthetic joint infection;
and mechanical complication within 0
to 90-days post the index date of
admission, depending on the
complication. The decision on the
appropriate follow-up period of 0 to 90
days was based on our analysis of 90day trends in complication rates using
the 2008 Medicare FFS Part A Inpatient
Data. We found that rates for
mechanical complications are elevated
until 90 days post the date of index
admission. We found that the rates for
four other complications—death,
surgical site bleeding, wound infection,
and pulmonary embolism—are elevated
for 30 days, and that rates for AMI,
pneumonia, and sepsis/septicemia level
off 7 days after the date of index
admission.
122 Pope G, Ellis R, Ash A, et al., Principal
Inpatient Diagnostic Cost Group Models for
Medicare Risk Adjustment. Health Care Financing
Review. 2000;21(3):26.
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(f) Calculating the Risk-Standardized
Complication Rate and Performance
Period
Analogous to how we calculate
hospital risk-standardized readmission
rates with all readmission measures and
risk-standardized mortality rates with
the mortality measures used in CMS
hospital quality programs, we calculate
the hospital risk-standardized
complication rate by producing a ratio
of the number of ‘‘predicted’’
complications (that is, the adjusted
number of complications at a specific
hospital based on its patient population)
to the number of ‘‘expected’’
complications (that is, the number of
complications if an average quality
hospital treated the same patients) for
each hospital and then multiplying the
ratio by the national raw complication
rate. The 3-year rolling performance
period would be consistent with that
used for HIQR Program (FY 2015 IPPS/
LTCH final rule 79 FR 50208 and
50209). Section III.E.5. of this final rule
summarizes measure performance
periods for SHFFT model years 1
through 5. We note that improvement
on the Hip/Knee Complications (NQF
#1550) measure would be determined
from the immediate 3-year rolling
performance period available for the
year preceding the SHFFT model
performance year as explained in Table
44.
We sought comment on this proposal
to assess quality performance for SHFFT
model participants through
implementation of the Hospital-level
risk-standardized complication rate
(RSCR) following elective primary total
hip arthroplasty (THA) and/or total knee
arthroplasty (TKA) (NQF #1550)
measure.
The following is a summary of the
comments received and our responses.
Comment: Several commenters
opposed the elective THA/TKA
complications measure because the
measure’s cohort does not align with the
SHFFT model cohort. Commenters
noted that the measure’s cohorts do not
include the patients in the SHFFT
model population. Commenters
requested that CMS provide more
justification for including the measures
in the SHFFT model. Commenters
suggested that because the measures
exclude hip fracture patients, they
would provide limited insight on the
quality of care provided to the patients
included in the SHFFT model.
Commenters raised specific concerns
about a lack of testing of the measures
in non-elective procedures and the
potential for the rates and types of
complications to differ between elective
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and non-elective procedure groups.
Commenters noted that patients with
hip fractures have higher mortality,
complication, and readmission rates and
are generally sicker with multiple
comorbidities. As a result, patient
recovery and rehabilitation pathways
may be different for hip fracture as
compared to patients who have elective
procedures. Additionally, commenters
noted that a hospital’s volume of hip
fracture patients is often much smaller
than the volume of elective surgery
patients causing concern that the use of
the measures will unfairly assess quality
at those hospitals with less arthroplasty
experience.
Response: While we recognize that
none of the proposed measures
specifically target the care of SHFFT
model beneficiaries, we provided the
following rationale in the proposed rule.
The proposed measures are the same as
those used for the CJR model because
SHFFT model episodes will be tested
along with the LEJR episodes in the CJR
model (80 FR 73501 and 73507) at
mostly the same hospitals. These
measures exclude patients with hip and
pelvic fractures. However, we expect
that many of the physicians and other
providers collaborating with participant
hospitals in the SHFFT and CJR models
will be the same, such that certain care
pathways and episode efficiencies may
be coordinated for SHFFT and CJR
model beneficiaries regardless of the
model, potentially resulting in quality
improvement for beneficiaries in both
models. Therefore, while the quality
measures do not specifically assess care
for hip fracture patients, they will
incentivize quality improvements that
also improve care for hip fracture
patients. In addition, as discussed
further in III.E.3.e.(3) of this final rule,
we propose to calculate a hospital-level
composite quality score that would
apply to episode payment for both the
CJR and SHFFT models, consistent with
our proposal of the same measures for
the two models. We believe that due to
the inclusion of beneficiaries with hip
fracture in both the CJR and SHFFT
models and our desire to streamline
EPM participant measure reporting, as
well as the focus of both models on
major lower extremity orthopedic
surgery, the same set of quality
measures can be used for both models
to incentivize quality improvement in
lower extremity orthopedic surgery care
and episode efficiency. We are also
considering future measure
development focused specifically on hip
and femur fracture patients.
We considered an alternative
approach to the required quality
measures for the SHFFT model given
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that the proposed measures do not
specifically target the SHFFT model
beneficiaries. This alternative approach
would not account for any hip-specific
measures (such as, Hospital-level RSCR
following elective primary THA and/or
TKA (NQF #1550) (Hip/Knee
Complications) and would instead only
measure patient experience through the
HCAHPS Survey (NQF #0166).
Although there may be some rationale
for excluding measures that do not
specifically target SHFFT model
beneficiaries, we do not propose this
approach to SHFFT model quality
measures because we believe that it is
critical to include a measure of both
clinical and patient experience
outcomes in the setting of lower
extremity orthopedic surgery episodes.
Additionally, we believe that using
quality measures for SHFFT model
episodes that do not align with those in
the CJR model could generate confusion
at CJR model participant hospitals
where we propose that the SHFFT
model be tested as discussed in III.B.4.
of this final rule.
Comment: One commenter expressed
support for our proposed approach of
using the same measures in the CJR and
SHFFT models given the lack of
measures specific to the hip fracture
population.
Response: We thank the commenter
for their support.
Comment: Several commenters
suggested that we develop measures that
are specific to the SHFFT model
population.
Response: We thank the commenter
for this suggestion and are considering
future measure development focused
specifically on hip and femur fracture
patients.
Comment: One commenter suggested
that the measures proposed do not
assess what matters most to patients,
such as whether patient’s or providers’
goals were met by the surgery
performed.
Response: We have incorporated the
THA/TKA patient-reported outcomebased data submission (henceforth
referred to as ‘‘THA/TKA voluntary
data’’) into the SHFFT model. The THA/
TKA voluntary data would provide
participant hospitals with valuable
information on functional outcomes that
would assist them in assessing an
important patient-centered outcome,
engaging other providers and suppliers
in care redesign for joint replacement
episodes, as well as provide them with
the potential for greater financial benefit
from improved episode efficiencies.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal, without
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modification, to assess quality
performance for SHFFT model
participants through implementation of
the Hospital-level risk-standardized
complication rate (RSCR) following
elective primary total hip arthroplasty
(THA) and/or total knee arthroplasty
(TKA) (NQF #1550) measure.
(2) Hospital-Level Performance
Measure(s) of Patient-Reported
Outcomes Following Elective Primary
Total Hip and/or Total Knee
Arthroplasty
III. (a) Background
As part of our goal to move towards
outcome measures that assess patientreported outcomes, we have begun
development on a measure to assess
improvement in patient-reported
outcomes following THA/TKA
procedures. The Hospital-Level
Performance Measure(s) of PatientReported Outcomes Following Elective
Primary Total Hip and/or Total Knee
Arthroplasty (hereinafter referred to as
‘‘THA/TKA patient-reported outcomebased measure’’) is currently under
development. We specifically chose to
focus on THA/TKA procedures since
THA/TKAs are important, effective
procedures performed on a broad
population, and the patient outcomes
for these procedures (for example, pain,
mobility, and quality of life) can be
measured in a scientifically sound way
and are also influenced by a range of
improvements in care.123 124 125 We also
note that THA/TKA procedures are
specifically intended to improve
function and reduce pain, making
patient-reported outcomes the most
meaningful outcome metric to assess for
these common, costly procedures.
Patient-reported outcomes would be
assessed separately for THA and TKA
procedures, though these results may be
combined into a single composite
measure for reporting. Therefore, we
will refer to a single measure, but
acknowledge the possibility of two
123 Monticone M, Ferrante S, Rocca B, et al.
Home-based functional exercises aimed at
managing kinesiophobia contribute to improving
disability and quality of life of patients undergoing
total knee arthroplasty: a randomized controlled
trial. Archives of physical medicine and
rehabilitation. Feb 2013;94(2):231–239.
124 Galea MP, Levinger P, Lythgo N, et al. A
targeted home- and center-based exercise program
for people after total hip replacement: a randomized
clinical trial. Archives of physical medicine and
rehabilitation. Aug 2008;89(8):1442–1447.
125 Moffet H, Collet JP, Shapiro SH, Paradis G,
Marquis F, Roy L. Effectiveness of intensive
rehabilitation on functional ability and quality of
life after first total knee arthroplasty: A single blind
randomized controlled trial. Archives of physical
medicine and rehabilitation. Apr 2004;85(4):546–
556.
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391
measures, one for THA patients and one
for TKA patients.
During measure development, we
discovered that in order to complete
measure development, we would need
access to a nationally representative
sample of THA and TKA inpatient
surgical procedure patient-reported
outcome data set that is also
consistently collected at the hospitallevel and contains risk variables
identified by orthopedists. The rationale
for requesting access to a national THA
and TKA inpatient surgical procedures
patient-reported data source are
twofold—(1) a national data source
would provide us with hospital-level
data representative of the total number
of THA and TKA procedures performed
in hospitals, as well as representative
data on hospital-level case-mix; and (2)
access to a national THA and TKA
inpatient surgical procedures patientreported data source would allow us to
assess and identify a set of
parsimonious data elements that will
minimize the data collection burden by
patients, physicians and hospitals. We
believe access to such data would allow
for completion and testing of the current
measure under development that can be
appropriately used for nationwide
hospital performance evaluation. We
implemented the initial data collection
for this measure initially in the CJR
model in order to test and resolve these
measurement development issues
through the collection of THA and TKA
patient-reported outcome data. We
proposed to test SHFFT model episodes
in mainly the same hospitals as the CJR
model as discussed in sectionIII.B.4. of
the proposed rule (81 FR 50794). We
note that approximately 50 hospitals
currently excluded from CJR model
participation because they are testing
BPCI LEJR episodes would be included
in the SHFFT model. Access to this data
through the SHFFT and CJR models
would address the following:
• Current data sources are not
consistently collected nor collected in a
uniform process and in a standardized
format (that is, data elements are not
consistently defined across different
data sources). We note that currently
available data sources tend to be limited
to single hospitals or regional registries
which are associated with complex data
access sharing requirements.
• Current lack of uniform hospitallevel data that can be used in measure
development.
• Lack of incentive for physicians and
hospitals to collect patient-reported
outcome data such as that through the
model’s financial incentives associated
with voluntary data submission.
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• Current lack of a technically simple
and feasible mechanism for hospitals to
submit patient-reported data to CMS.
This model would help create and
optimize such a mechanism, potentially
enabling future measure
implementation.
In summary, the voluntary data
collection that is already underway in
most SHFFT model participants who are
also participants in the CJR model
would provide data from the patient’s
perspective that is necessary to finalize
and test the measure specifications,
including the risk model. Access to this
nationally representative voluntarily
submitted data would enable us to do
the following:
• Determine a parsimonious set of
risk factors that are statistically
adequate for risk adjustment for patientreported outcome.
• Examine the differences in hospital
performance related to different
components in the patient-reported
outcome (such as functional status,
pain, etc.) to finalize the statistical
modeling methodology for risk
adjustment.
• Evaluate the reliability of the
patient-reported outcome measure.
• Examine validity of the patientreported outcome measure upon
finalization of the risk adjustment
model via potential testing methods
such as face validity testing with
national experts, comparing the measure
results to similar results based on other
data sources if feasible, etc.
In order to encourage participation
with voluntary data submission of
patient-reported outcome data, we are
proposed to seek and reward voluntary
participation in submission of THA/
TKA patient-reported outcome-based
measure data as outlined in section
III.E.4.c.(2)(viii) of the proposed rule (81
FR 50794). We note that we would not
publicly report the THA/TKA voluntary
data.
Finally, we intend to use a fully tested
and completed THA/TKA patientreported outcome-based measure in
CMS models or programs when
appropriate. If there is a decision to
implement the fully developed THA/
TKA patient-reported outcome-based
measure, we would propose to adopt the
measure through notice and comment
rulemaking. We refer reviewers to draft
measure specifications in the
downloads section of the Measure
Methodology Web page at https://
www.cms.gov/Medicare/QualityInitiatives-Patient-AssessmentInstruments/HospitalQualityInits/
Measure-Methodology.html.
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(b) Data Sources
As previously discussed, this measure
is under development, and we proposed
to reward SHFFT model participants
that volunteer to submit provider- and
patient-level data elements. We note
that there is currently little uniformity
across hospitals regarding collection of
specific provider- and patient- level data
elements that are used to assess patient
outcomes after THA and TKA inpatient
procedures. In the voluntary data
submission for the THA/TKA patientreported outcome-based measure, we
are trying to identify a uniform set of
provider- and patient-level data
elements that are accurate, valid, and
reliable pieces of information that can
be used in the determination of
improvement in various patient
characteristics like those previously
listed (that is, pain, mobility, and
quality of life). Furthermore, in order to
minimize provider and hospital burden
associated with data collection and
submission of provider- and hospitallevel data elements, we proposed using
a variety of data sources for measure
development. We anticipate using the
following data sources are:
• Patient-reported data.
• Administrative claims-based data.
• One or both physician-reported and
electronic health record data.
Through this voluntary data
submission proposal, we hope to
identify a uniform set of provider- and
patient-level data elements while also
identifying data sources that are the
least burdensome for the patients,
providers, and hospitals. We proposed
to request that SHFFT model
participants provide administrative
claims-based data whenever possible, in
order to minimize burden on patients,
providers, and hospitals. Additionally,
we proposed to request that SHFFT
model participants submit either
hospital documentation, chart
abstraction, or abstraction from the
electronic health records. We proposed
to request submission of the following
data elements as finalized in the CJR
model final rule (80 FR 73494 through
73495):
• Pre-operative Assessments (to be
collected between 90 and 0 days prior
to THA/TKA procedure):
++ Date of Birth.
++ Race and Ethnicity.
++ Date of admission to anchor
hospitalization.
++ Date of eligible THA/TKA
procedure.
++ Unique Identifier (Medicare
Health Insurance Claim Number).
++ Hip-specific PROM Instrument for
THA Procedures.
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Either VR–12 or PROMIS-Global
[collected pre-operatively (90 to 0 days
prior to the THA procedure)], the
revised list of risk variables [Table 39,
collected only pre-operatively (90 to 0
days prior to the THA procedure)], AND
either (A) the HOOS Jr. (6 items total)
[collected pre-operatively (90 to 0 days
prior to the THA procedure)] or (B) the
original HOOS Pain Subscale (10 items),
AND the original HOOS Function, Daily
Living Subscale (17 items, for a total of
27 items) [collected pre-operatively (90
to 0 days prior to the THA procedure).
++ Knee-specific PROM instrument
for TKA procedures.
Either (A) the HOOS Jr. (6 items total)
[collected both pre-operatively (90 to 0
days prior to the THA procedure) and
post-operatively (270 to 365 days after
the THA procedure] or (B) the original
HOOS Pain Subscale (10 items), AND
the original HOOS Function, Daily
Living Subscale (17 items, for a total of
27 items) [collected both pre-operatively
(90 to 0 days prior to the THA
procedure) and post-operatively (270 to
365 days after the THA procedure].
++ Body Mass Index (or height in cm
and weight in kg).
++ Pre-operative use of narcotics.
++ Patient-Reported Pain in Nonoperative Lower Extremity Joint.
++ Patient-Reported Back Pain
(Oswestry Index question).
++ Patient-Reported Health Literacy
• Post-operative Assessments (To be
collected between 270 and 365 days
following THA/TKA procedure):
++ Date of admission to anchor
hospitalization.
++ Date of eligible THA/TKA
procedure.
++ Medicare Health Insurance Claim
Number (Unique Identifier).
++ Generic PROM Instrument for
THA and TKA Procedures.
++ Knee-Specific PROM Instrument
for TKA Procedures.
Either VR–12 or PROMIS-Global
[collected post-operatively (270 to 365
days after the TKA procedure)], AND
either (A) the KOOS Jr. (7 items total)
[collected post-operatively (270 to 365
days after the TKA procedure)] OR (B)
the original KOOS Stiffness Subscale (2
items), AND the original KOOS Pain
Subscale (9 items) AND the original
KOOS Function, Daily Living Subscale
(17 items, for a total of 28 items)
collected post-operatively (270 to 365
days after the TKA procedure)].
++ Hip-Specific PROM Instrument
for THA Procedures.
Either VR–12 or PROMIS-Global
[collected post-operatively (270 to 365
days after the THA procedure], the
revised list of risk variables [Table 39,
collected only pre-operatively (90 to 0
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days prior to the THA procedure)], AND
either (A) the HOOS Jr. (6 items total)
[collected post-operatively (270 to 365
days after the THA procedure] or (B) the
original HOOS Pain Subscale (10 items),
AND the original HOOS Function, Daily
Living Subscale (17 items, for a total of
27 items) [collected post-operatively
(270 to 365 days after the THA
procedure)].
Finally, we note that as the measure
continues to undergo development that
the list of data elements may be
simplified. As stated earlier in this
section, we intend to identify a uniform
set of provider- and patient-level data
elements that are accurate, valid and
reliable pieces of information that can
be used in the determination of
improvement in various patientreported outcomes like those previously
listed (that is, pain, mobility, and
quality of life).
In accordance with, and to the extent
permitted by, the HIPAA Privacy Rule
and other applicable law, we proposed
to request that participants submit the
data specified in the request, which we
would limit to the minimum data
necessary for us to conduct quality
assessment and improvement activities.
Regarding the process for data
collection, we proposed the THA/TKA
voluntary data will be submitted to and
collected by a CMS contractor in a
manner and format similar to existing
CMS data submission processes. For
example, CMS would supply applicable
hospitals with a file template and
instructions for populating the file
template with data and submitting the
data; the hospitals will populate the
template, log in to a secure portal, and
transmit the file to the appropriate CMS
contractor; the CMS contractor would
also match the submitted data to
Medicare administrative claims-based
data and calculate successful
submission determination for use in
assigning the SHFFT composite quality
score as described in section III.E.3.e.(3).
of this final rule(or validated subscales
or abbreviated versions of these
instruments). We believe that voluntary
participation in the submission of THA/
TKA patient-reported outcome-based
measure data will provide the minimum
information we would need that would
inform us on how to continuously
improve the currently specified measure
in development.
We note that some of these data
elements are closely aligned with data
elements in e-clinical measures
submitted by eligible professionals for
the Medicare EHR Incentives Program
for Eligible Professionals. Specifically
these EHR Incentives Program measures
for eligible professionals are—1)
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Functional Status Assessment for Knee
replacement (CMS 66); and 2)
Functional Status Assessment for Hip
replacement (CMS 56). We refer
reviewers to CMS.gov EHR Incentives
Program 2014 Eligible Professional June
2015 zip file update at https://cms.gov/
Regulations-and-Guidance/Legislation/
EHRIncentivePrograms/Downloads/
eCQM_2014_EP_June2015.zip for full
measure specifications. We believe it is
possible that many health IT vendors
are already certified to capture,
calculate and report these provider-level
measures of functional status on total
knee and total hip arthroplasty, and
therefore we anticipate that the
provider-level data elements that are
identical to the THA/TKA patientreported outcome voluntary data
elements previously listed may not be as
burdensome for the SHFFT model
participants to voluntarily submit.
(c) Cohort
The measure cohort(s) includes
Medicare FFS beneficiaries, aged 65
years or older, admitted to non-federal
acute care hospitals for elective primary
THA or TKA. We would exclude from
the cohort patients with fractures and
mechanical complications or those
undergoing revision procedures. The
THA/TKA patient-reported outcomebased measure cohort is harmonized
with the Hip/Knee Complications (NQF
#1550) measure and with the cohort
definition in the CJR model final rule
(80 FR 73477). THA and TKA patientreported outcomes will be assessed
separately but may be combined into a
single composite measure for reporting.
(d) Inclusion and Exclusion Criteria
The measure cohort inclusion criteria
are all patients undergoing elective
primary THA/TKA procedures.
Exclusion criteria will consist of
patients undergoing non-elective
procedures (that is, patients with
fractures resulting in THA/TKA), as it is
infeasible to routinely capture preoperative patient-reported assessments
in these patients; patients with
mechanical complications of prior hip
and knee joint procedures and those
undergoing revision THA/TKA will also
be excluded, as their patient-reported
outcomes may be influenced by prior
care experiences and therefore may not
adequately represent care quality of the
hospital performing the revision
procedure.
(e) Outcome
The measure will assess change
between pre- and post-operative patientreported outcomes for THA and TKA
separately or as a composite measure for
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393
both procedures. The measure will use
one or more of the following patientreported outcome instruments (or
validated subscales or abbreviated
versions of these instruments) to
calculate the measure score: The Patient
Reported Outcomes Measurement
Information Systems (PROMIS)-Global
or the Veterans Rand 12 Item Health
Survey (VR–12), and the Hip
dysfunction and Osteoarthritis Outcome
Score/Knee injury and Osteoarthritis
Outcome Score (HOOS/KOOS)
instruments to measure pre- and
postoperative improvement or both.
These candidate instruments were
selected by a TEP based upon their
meaningfulness to patients and
clinicians, performance characteristics
such as reliability, responsiveness and
validity, and their perceived burden to
both patients and providers. The preoperative data collection timeframe will
be 90 to 0 days before surgery, and the
post-operative data collection timeframe
will be 270 to 365 days following
surgery. The approach to calculating the
improvement or worsening of patient
outcomes represented by the pre- and
postoperative patient-reported survey
results has not yet been determined, but
will use one or more surveys to define
the improvement or worsening of
patient-reported outcomes to reliably
identify differences between hospitals of
varying performance.
(f) Risk-Adjustment (if applicable)
We note that the measure’s risk model
has yet to be developed. In order to
develop the risk model, final risk
variable selection for the risk model will
involve empirical testing of candidate
risk variables as well as consideration of
the feasibility and reliability of each
variable. The risk model will account
for the hospital level response rate as
well as measureable patient-level factors
relevant to patient-reported outcomes
following elective THA/TKA
procedures. To the extent feasible, the
risk model methodology will adhere to
established statistical
recommendations.126
(g) Calculating the Risk-Standardized
Rate
We note that the approach to
reporting this measure(s) has yet to be
126 Ash AS, Fiengerg SE., Louis TA, Normand ST,
Stukel TA, Utts J. STATISTICAL ISSUES IN
ASSESSING HOSPITAL PERFORMANCE,
Commissioned by the Committee of Presidents of
Statistical Societies. Original report submitted to
CMS on November 28, 2011, Revised on January 27,
2012. Available at:https://www.cms.gov/Medicare/
Quality-Initiatives-Patient-Assessment-Instruments/
HospitalQualityInits/Downloads/Statistical-Issuesin-Assessing-Hospital-Performance.pdf. Accessed
on April 15, 2015.
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developed. The measure will assess
change in patient-reported outcomes
between the pre-operative (90 to 0 days
prior to the elective primary THA/TKA
procedure) and post-operative (270–365
days following the elective primary
THA/TKA procedure) periods.
(h) Performance Period for Successful
Submission of THA/TKA PatientReported-Outcome-Based Voluntary
Data
We proposed defining data reporting
performance periods for each
performance year of the SHFFT model
as outlined in Table 40. Performance
periods for voluntary reporting of THA/
TKA patient-reported outcome-based
measure data are those timeframes in
which a hospital admission occurs for
an eligible THA/TKA voluntary data
submission procedure. Data submitted
for the first SHFFT model performance
year would be for cases that fulfill the
measure specifications described in
section III.E.4.c.(2)(i) of the proposed
rule (81 FR 50794), and would be
restricted to the pre-operative data
elements on cases performed between
September 1, 2016 and June 30, 2017.
We note that SHFFT model participants
generally would have the opportunity
for voluntary data submission on cases
performed in this timeframe through the
hospitals’ participation in the CJR
model, which uses the same timeframe
for voluntary submission of preoperative data elements on cases. The
proposed timing allows matching of the
patient-reported data with relevant
administrative claims-based data in
order to accurately calculate the percent
of eligible elective primary THA/TKA
patients for which THA/TKA voluntary
data was successfully submitted. For
SHFFT model performance year 2,
THA/TKA voluntary data reporting
would be 10 months of post-operative
data for cases performed between
September 1, 2016 and June 30, 2017,
and 12 months of pre-operative data for
cases performed between July 1, 2017
and June 30, 2018. For SHFFT model
performance year 3 and subsequent
years of the model, the performance
periods for submission of voluntary data
will consist of 12-month time periods.
TABLE 40—DURATION OF PERFORMANCE PERIODS FOR PRE- AND POST-OPERATIVE THA/TKA VOLUNTARY DATA
SUBMISSION
Duration of
performance
period
Patient population eligible for THA/TKA
voluntary data submission
Requirements for successful THA/TKA
voluntary data submission *
2017 Performance
Year 1.
10 months ..................
All patients undergoing elective primary THA/
TKA procedures performed between September 1, 2016 and June 30, 2017.
2018 Performance
Year 2.
22 months ..................
All patients undergoing elective primary THA/
TKA procedures performed between September 1, 2016 and June 30, 2018.
2019 Performance
Year 3.
24 months ..................
All patients undergoing elective primary THA/
TKA procedures performed between July 1,
2017 and June 30, 2019.
2020 Performance
Year 4.
24 months ..................
All patients undergoing elective primary THA/
TKA procedures performed between July 1,
2018 and June 30, 2020.
2021 Performance
Year 5.
24 months ..................
All patients undergoing elective primary THA/
TKA procedures performed between July 1,
2019 and June 30, 2021.
• Submit PRE-operative data on primary
elective THA/TKA procedures for ≥60% or
≥75 procedures performed between September 1, 2016 and June 30, 2017.
• Submit POST-operative data on primary
elective THA/TKA procedures for ≥60% or
≥75 procedures performed between September 1, 2016 and June 30, 2017.
• Submit PRE-operative data on primary
elective THA/TKA procedures for ≥70% or
≥100 procedures performed between July
1, 2017 and June 30, 2018.
• Submit POST-operative data on primary
elective THA/TKA procedures for ≥70% or
≥100 procedures performed between July
1, 2017 and June 30, 2018.
• Submit PRE-operative data on primary
elective THA/TKA procedures for ≥80% or
≥200 procedures performed between July
1, 2018 and June 30, 2019.
• Submit POST-operative data on primary
elective THA/TKA procedures for ≥80% or
≥200 procedures performed between July
1, 2018 and June 30, 2019.
• Submit PRE-operative data on primary
elective THA/TKA procedures for ≥80% or
≥200 procedures performed between July
1, 2019 and June 30, 2020.
• Submit POST-operative data on primary
elective THA/TKA procedures for ≥80% or
≥200 procedures performed between July
1, 2019 and June 30, 2020.
• Submit PRE-operative data on primary
elective THA/TKA procedures for ≥80% or
≥200 procedures performed between July
1, 2020 and June 30, 2021.
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SHFFT model
performance year
The proposed performance periods
would enable SHFFT model
participants to receive points toward the
SHFFT model composite quality score
starting in performance year 1, even
though complete pre-operative and postoperative data collection requires a
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minimum 9- through 12-month time
period. This 9- through 12-month time
period, between the procedure and postoperative data collection, was defined
through clinician and stakeholder input
and provides for both sufficient elapsed
time for maximum clinical benefit of
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THA/TKA procedures on patientreported outcomes and accommodates
common clinical care patterns in which
THA/TKA patients return to their
surgeon 1 year after surgery. We
emphasize that SHFFT model
participants that are also participating
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in the CJR model do not need to submit
data twice to satisfy the successful
submission requirements of both
models. If those hospitals successfully
submit voluntary data for the CJR model
they will be credited with successful
submission under the SHFFT model.
We sought comment on our proposed
measure reporting periods for the
performance years of the SHFFT model.
The following is a summary of the
comments received and our responses.
Comment: One commenter expressed
support for our proposal to assess
patient-reported functional status before
surgery and again one year after surgery
as a mechanism to provide insight into
the effectiveness of these procedures.
Response: We thank the commenter
for their support.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal, without
modification, to the measure reporting
periods for the performance years of the
SHFFT model. The performance periods
will enable SHFFT model participants
to receive points toward the SHFFT
model composite quality score starting
in performance year 1, even though
complete pre-operative and postoperative data collection requires a
minimum 9- through 12-month time
period. This 9- through 12-month time
period, between the procedure and postoperative data collection, was defined
through clinician and stakeholder input
and provides for both sufficient elapsed
time for maximum clinical benefit of
THA/TKA procedures on patientreported outcomes and accommodates
common clinical care patterns in which
THA/TKA patients return to their
surgeon 1 year after surgery.
(i) Requirements for Successful
Submission of THA/TKA PatientReported-Outcome-Based Voluntary
Data
In order for CMS to assign points in
the SHFFT model composite quality
score for successful participant
submission of THA/TKA voluntary data,
requirements to determine if the
submitted data will inform measure
development have been identified.
We believe that the following criteria
should be used to determine if a
participant has successfully submitted
THA/TKA voluntary data. We note that
successful THA/TKA voluntary data
submission requires completion of all of
the following:
• Submission of the data elements
listed in section III.E.4.c.(2)(ii) of the
proposed rule (81 FR 50794).
• Data elements listed in section
III.E.4.c.(2)(ii) of this final rule must be
submitted on at least 80 percent of their
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eligible elective primary THA/TKA
patients.
• THA/TKA voluntary data
submission must occur within 60 days
of the end of the most recent data
collection period.
To successfully submit THA/TKA
voluntary data for performance years 1
through 5, SHFFT model hospitals must
submit both pre-operative and postoperative patient reported outcome data
on an increasing proportion of eligible
elective primary THA/TKA patients
over the performance years as described
in Table 29 of the proposed rule (81 FR
50794). Performance periods for which
we proposed to have THA/TKA
voluntary data submitted are displayed
in Table 29 of the proposed rule (81 FR
50794). Table 29 also summarizes the
performance periods for pre-operative
and post-operative THA/TKA voluntary
data. Finally, SHFFT model hospitals
volunteering to submit THA/TKA data
would be required to submit preoperative data on all eligible patients
and post-operative data elements only
on those patients at least 366 days out
from surgery. Therefore, hospitals are
not expected to collect and submit postoperative THA/TKA voluntary data on
patients who are fewer than 366 days
from the date of surgery.
We previously described a THA/TKA
eligible patient in section III.E.4.c.(2)(iii)
of the proposed rule (81 FR 50794). This
description is important as these
patients are those in which we sought
submission of voluntary data. We also
selected the requirement of submitting
an increasing percent of eligible elective
primary THA/TKA patients’ data
starting at 60 percent in performance
year 1 and reaching 80 percent by
performance years 4 and 5 because this
volume of cases would result in a high
probability that we will have a have a
national sample of THA/TKA patient
data representative of each hospital’s
patient case mix. Having at least 80
percent of the eligible elective primary
THA/TKA patients would enable an
accurate and reliable assessment of
patient-reported outcomes for use in
measure development. We note that
data used for outcome measure
development must adequately represent
the population that is anticipated to be
measured and in this case that
population would be those experiencing
elective primary THA/TKA inpatient
surgical procedures. Furthermore, we
considered setting the requirement at
100 percent of the eligible elective
primary THA/TKA patients, but
concluded that a requirement of 100
percent data collection may not be
feasible for all hospitals or may be
excessively burdensome to achieve.
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395
Therefore we set the requirement in
SHFFT model performance year 4 and
beyond at 80 percent of the eligible
elective primary THA/TKA patients. We
believe acquisition of 80 percent of the
eligible elective primary THA/TKA
patients will provide representative data
for measure development while
decreasing patient, provider and
hospital burden.
The proposal for voluntary
submission of THA/TKA data is
included in § 512.413(b). We sought
public comment of these requirements
to determine successful voluntary
submission of THA/TKA data. We also
sought comment specifically on the
requirement for data collection on an
increasing percentage of eligible
patients starting with at least 60 percent
in SHFFT model performance year 1
and increasing to 80 percent of the
eligible elective primary THA/TKA
patients by SHFFT model performance
year 4.
The following is a summary of the
comments received and our responses.
Comment: One commenter expressed
support of our proposal to incentivize
SHFFT model participants who submit
PRO data.
Response: We thank the commenter
for their support.
Comment: Several commenters
expressed concern that the instruments
used for the proposed Total Hip
Arthroplasty (THA)/Total Knee
Arthroplasty (TKA) voluntary patientreported outcome (PRO) measure had
not been validated in hip fracture
patients, specifically the Hip disability
and Osteoarthritis Outcome Score
(HOOS), JR.
Response: The purpose of the
voluntary PRO data collection is to
collect the data required to develop a
future PRO-based performance measure
that will assess hospital quality of care
for patients undergoing elective primary
THA/TKA procedures. Because only
patients with elective primary THA/
TKA procedures will complete these
survey instruments, there is no need to
assess their validity in hip fracture
patients. Although we plan to develop
a PRO-based measure that excludes
patients with fracture-related THA/
TKA, we believe quality improvement
efforts initiated in response to the future
measure are likely to benefit patients
undergoing similar elective procedures,
such as partial hip arthroplasty and
revision THA/TKA procedures, and
possibly even non-elective THA/TKA
procedures, such as fracture-related
THA.
Comment: Several commenters
suggested that hospitals will not be able
collect PRO data on hip fracture patients
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prior to the procedure because hip
fractures are acute and unanticipated
events.
Response: The PRO data will be
collected only for patients undergoing
elective THA/TKA procedures within
hospitals participating in the SHFFT
model and not for hip fracture patients.
Comment: One commenter expressed
concern that the proposal that hospitals
seeking credit for voluntary submission
of PRO data need only submit data on
80 percent of eligible elective primary
THA/TKA patients could cause
hospitals to report data only on those
patients who had positive outcomes.
The commenter requested that CMS
raise the threshold.
Response: We appreciate the
commenter’s suggestion to increase the
successful criterion based upon the
concern that lowering the successful
criterion (that is, the patient-reported
outcome instrument response and risk
variable submission rates required for
successful participation) may produce
biased data that are not generalizable to
all patients undergoing elective primary
THA/TKA procedures at a given
hospital. We refer the commenter to our
response to this concern in the CJR
model final rule (80 FR 73499–73500).
Comment: One commenter suggested
that we consider removing the Oswestry
Index from the list of required variables
to be submitted with pre-operative PRO
data. The commenter suggested that the
Oswestry Index is lengthy and
burdensome to complete and is not
relevant for hip and knee surgery.
Response: We note that a joint
statement from multiple surgical
specialty societies received during the
public comment of the CJR Model
Proposed Rule included back pain as a
prioritized risk variable for the
voluntary PRO and risk variable data
collection [cite final rule (80 FR 73496)
and Ayers]. The commenter noted that
the Oswestry Index requires responses
to a lengthy set of questions. To
minimize data collection burden, we
have included a single question from
the Oswestry Index to capture patientreported back pain: My BACK PAIN at
the moment is (none, very mild,
moderate, fairly severe, very severe,
worst imaginable).127
Comment: One commenter suggested
that we reduce the number of responses
required to satisfy the HOOS and KOOS
completion rate.
Response: In response to the
commenter’s concern regarding the
burden of PRO data collection, we have
limited the number of PRO survey data
127 Fairbank JC, Pynsent PB. The Oswestry,
Disability Index. Spine 2000 Nov 15;25(22):2940–52
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elements to a minimum of 16 or 17
questions, depending upon whether the
patient is undergoing a THA or TKA
procedure, plus the additional risk
variable questions, which CMS believes
is a reasonable burden for elective
procedures intended solely for
improving pain and function. In
addition, comments received during the
public comment of the CJR Model
Proposed Rule indicate that high
patient-reported outcome data
collection rates are feasible. For
example, a commenter shared that its
institution reported a reliable 85 percent
response rate for its PRO data collection
(80 FR 73500).
Comment: Several commenters
expressed concerns about hospitals’
ability to collect post-operative PRO
data one year after surgery. One concern
was about the difficulty of locating
patients due to the possibility of a
beneficiary’s death, incapacity, a move,
or an unwillingness to participate in a
survey. One commenter suggested CMS
shorten the timeframe for assessing the
PROs to 6 months and that CMS provide
a file of CJR/SHFFT patients who are
deceased at the start of the postoperative data collection period in order
to avoid mailing reminders or surveys to
the families of deceased beneficiaries.
One commenter suggested extending
proposed timing of PRO assessment
beyond 365 days in case patients do not
return to their provider within a year of
surgery.
Response: The PRO data will be
collected only for patients undergoing
elective THA/TKA procedures within
hospitals participating in the SHFFT
model and not for hip fracture patients.
The collection time window of 270 to
365 days for post-operative PRO data
was specified in conjunction with our
TEP and based on recovery trajectories
for primary elective THA/TKA patients.
Because experts and stakeholders have
identified this window as ideal for
capturing PROs, we encourage hospitals
to develop strategies to collect data
within the time window, such as
mailing surveys to patients well before
they return for their one-year follow up
visit.
Comment: One commenter suggested
that PRO performance measures should
be used to assess quality of post-acute
care services as well as acute care
hospitals.
Response: We thank the commenter
for their suggestion. We will consider
this feedback during ongoing measure
evaluation.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal, without
modification, for voluntary submission
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of THA/TKA data as included in
§ 512.413(b). We are also finalizing
these requirements for data collection
on an increasing percentage of eligible
patients starting with at least 60 percent
in SHFFT model performance year 1
and increasing to 80 percent of the
eligible elective primary THA/TKA
patients by SHFFT model performance
year 4.
d. Measure Used for All EPMs
(1) Hospital Consumer Assessment of
Healthcare Providers and Systems
(HCAHPS) Survey (NQF #0166)
(a) Background
The HCAHPS Survey (NQF #0166) is
a CMS survey and a national,
standardized, publicly reported survey
of patients’ experience of hospital care.
The HCAHPS Survey is endorsed by the
NQF (#0166); CMS is the measure
steward. The HCAHPS Survey, also
known as CAHPS® Hospital Survey, is
a survey instrument and data collection
methodology for measuring patients’
perceptions of their hospital experience.
The HCAHPS Survey asks recently
discharged patients 32 questions about
aspects of their hospital experience that
they are uniquely suited to address. The
core of the survey contains 21 items that
ask ‘‘how often’’ or whether patients
experienced a critical aspect of hospital
care. The survey also includes four
items to direct patients to relevant
questions, five items to adjust for the
mix of patients across hospitals, and
two items that support congressionally
mandated reports (77 FR 53513 through
53515). Eleven HCAHPS measures
(seven composite measures, two
individual items, and two global items)
are currently publicly reported on the
Hospital Compare Web site for each
hospital participating in the HIQR
Program (79 FR 50259). Each of the
seven currently reported composite
measures is constructed from two or
three survey questions. The seven
composites summarize the following:
• How well doctors communicate
with patients.
• How well nurses communicate with
patients.
• How responsive hospital staff are to
patients’ needs.
• How well hospital staff helps
patients manage pain.
• How well the staff communicates
with patients about medicines.
• Whether key information is
provided at discharge.
• How well the patient was prepared
for the transition to post-hospital care.
Lastly, the two individual items
address the cleanliness and quietness of
patients’ rooms, while the two global
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items report patients’ overall rating of
the hospital, and whether they would
recommend the hospital to family and
friends. We proposed to adopt a
measure in the EPMs that uses HCAHPS
survey data to assess quality
performance and capture patient
experience of care.
(b) Data Sources
The HCAHPS Survey is administered
to a random sample of adult inpatients
between 48 hours and 6 weeks after
discharge. The HCAHPS survey data is
collected on inpatient experience, is not
limited to Medicare beneficiaries, and
does not distinguish between types of
Medicare beneficiaries. Patients
admitted in the medical, surgical, and
maternity care service lines are eligible
for the survey; the survey is not
restricted to Medicare beneficiaries.
Hospitals may use an approved survey
vendor or collect their own HCAHPS
data (if approved by CMS to do so) (for
a detailed discussion see 79 FR 50259).
To accommodate hospitals, the
HCAHPS Survey can be implemented
using one of the following four different
survey modes:
• Mail.
• Telephone.
• Mail with telephone follow-up.
• Active Interactive Voice
Recognition (IVR).
Regardless of the mode used,
hospitals are required to make multiple
attempts to contact patients. Hospitals
may use the HCAHPS Survey alone, or
include additional questions after the 21
core items discussed previously.
Hospitals must survey patients
throughout each month of the year, and
hospitals participating in the HIQR
Program must target at least 300
completed surveys over 4 calendar
quarters in order to attain the reliability
criterion CMS as set for publicly
reported HCAHPS scores (see 79 FR
50259). The survey itself and the
protocols for sampling, data collection,
coding, and file submission can be
found in the current HCAHPS Quality
Assurance Guidelines manual, available
on the HCAHPS Web site located at:
https://www.hcahpsonline.org. (The
HCAHPS Survey is available in several
languages, and all official translations of
the HCAHPS Survey instrument are
available in the current HCAHPS
Quality Assurance Guidelines at https://
www.hcahpsonline.org/
qaguidelines.aspx.)
(c) Cohort
Hospitals, or their survey vendors,
submit HCAHPS data in calendar
quarters (3 months). Consistent with
other quality reporting programs, we
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proposed that HCAHPS scores would be
publicly reported on Hospital Compare
based on 4 consecutive quarters of data.
For each public reporting, the oldest
quarter of data is rolled off, and the
newest quarter is rolled on (see 79 FR
50259).
(d) Inclusion and Exclusion Criteria
The HCAHPS Survey is broadly
intended for patients of all payer types
who meet the following criteria:
• Eighteen years or older at the time
of admission.
• Admission includes at least 1
overnight stay in the hospital.
• Non-psychiatric MS–DRG/principal
diagnosis at discharge.
• Alive at the time of discharge.
There are a few categories of
otherwise eligible patients who are
excluded from the sample frame as
follows:
• ‘‘No-Publicity’’ patients—Patients
who request that they not be contacted.
• Court/Law enforcement patients
(that is, prisoners); patients residing in
halfway houses are included.
• Patients with a foreign home
address (U.S. territories—Virgin Islands,
Puerto Rico, Guam, American Samoa,
and Northern Mariana Islands are not
considered foreign addresses and are
not excluded).
• Patients discharged to hospice care
(Hospice-home or Hospice-medical
facility).
• Patients who are excluded because
of state regulations.
• Patients discharged to nursing
homes and skilled nursing facilities.
The HCAHPS Survey is intended for
short-term, acute care hospitals. Both
IPPS and Critical Access Hospitals
participate in the survey; specialty
hospitals, psychiatric hospitals and
children’s hospitals do not.
(e) Case-Mix Adjustment
To ensure that HCAHPS scores allow
fair and accurate comparisons among
hospitals, CMS adjusts for factors that
are not directly related to hospital
performance but which affect how
patients answer survey items. This
includes the mode of survey
administration and characteristics of
patients that are out of a hospital’s
control. Patient-mix adjustments (also
known as case-mix adjustment) control
for patient characteristics that affect
ratings and that are differentially
distributed across hospitals. Most of the
patient-mix items are included in the
‘‘About You’’ section of the survey,
while others are taken from hospital
administrative records. Based on the
HCAHPS mode experiment, and
consistent with previous studies of
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397
patient-mix adjustment in HCAHPS and
in previous hospital patient surveys, we
employ the following variables in the
patient-mix adjustment model:
• Self-reported general health status
(specified as a linear variable).
• Education (specified as a linear
variable).
• Type of service (medical, surgical,
or maternity care).
• Age (specified as a categorical
variable).
• Admission through emergency
room (discontinued in 2010).
• Lag time between discharge and
survey.
• Age by service line interaction.
• Language other than English spoken
at home.
Once the data are adjusted for patient
mix, there is a fixed adjustment for the
mode of survey administration (mail,
telephone, mail with telephone followup, and active Interactive Voice
Response). Information on patient-mix
adjustment (risk adjustment) and survey
mode adjustment of HCAHPS scores can
be found at https://
www.hcahpsonline.org/
modeadjustment.aspx.
(f) HCAHPS Scoring
Regarding the HCAHPS Survey (NQF
#0166) measure, we identified the
methodology used to assess hospitals in
the HIQR Program as reasonable for use
in the EPMs since this is a survey that
many hospitals and patients are familiar
with. In determining HCAHPS
performance, we proposed to utilize the
HCAHPS Linear Mean Roll-up (HLMR)
score. The HLMR summarizes
performance across 10 of the 11 publicly
reported HCAHPS measures for IPPS
hospitals with 100 or more completed
HCAHPS surveys in a 4-quarter period.
All of the publicly reported measures
are included except for how well
hospital staff helps patients manage
pain since revisions are under
consideration for that measure. The
HLMR is calculated by taking the
average of the linear mean scores (LMS)
for each of the 10 publicly reported
HCAHPS measures. We note that the
HLMR is not current publicly reported
but may be calculated using the LMS,
which are publicly reported in the
Patient Survey Results in the Hospital
Compare downloadable database found
on Data.Medicare.gov at https://
data.medicare.gov/data/hospitalcompare?sort=relevance&tag=
patient%20survey%20results. The LMS,
which was created for the calculation of
HCAHPS Star Ratings, summarizes all
survey responses for each HCAHPS
measure; a detailed description of LMS
can be found in HCAHPS Star Rating
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Technical Notes, at https://
www.hcahpsonline.org/
StarRatings.aspx.
We proposed that EPM participants
must have at least 100 completed
HCAHPS surveys over a given 4-quarter
period to be evaluated on HCAHPS for
the EPMs. The responses to the survey
items used in each of the 10 HCAHPS
measures described previously are
combined and converted to a 0 to 100
linear-scaled score as follows:
• ‘‘Never’’ = 0; ‘‘Sometimes’’ = 331⁄3;
‘‘Usually’’ = 662⁄3; and ‘‘Always’’ = 100
(For HCAHPS Survey items 1–9, 11, and
16–17).
• ‘‘No’’ = 0; and ‘‘Yes’’ = 100 (For
items 19 and 20).
• Overall Rating ‘‘0’’ = 0; Overall
Rating ‘‘1’’ = 10; Overall Rating ‘‘2’’ =
20; . . .; Overall Rating ‘‘10’’ = 100 item
21).
• ‘‘Definitely No’’ = 0; ‘‘Probably No’’
= 331⁄3; ‘‘Probably Yes’’ = 662⁄3; and
‘‘Definitely Yes’’ = 100 (For item 22).
• ‘‘Strongly Disagree’’ = 0; ‘‘Disagree’’
= 331⁄3; ‘‘Agree’’ = 662⁄3; and ‘‘Strongly
Agree’’ = 100 (For items 23, 24, and 25).
The linear-scaled scores are then
adjusted for patient mix, survey mode,
and quarterly weighting to create the
LMS, see https://www.hcahpsonline.org/
files/HCAHPS_Stars_Tech_Notes_
Apr2015.pdf.
The HLMR summarizes performance
across the 10 HCAHPS measures by
taking an average of each of the LMS of
the 10 HCAHPS measures, using a
weight of 1.0 for each of the 6 HCAHPS
composite measures, and a weight of 0.5
for each of the single item measures
(Cleanliness, Quietness, Overall
Hospital Rating and Recommend the
Hospital). The HLMR is calculated to
the second decimal place. Once the
HLMR score is determined for an EPM
participant, the hospital’s percentile of
performance can be determined by
applying the aforementioned methods to
the linear mean scores for all IPPS
hospitals with 100 or more completed
surveys in a 4-quarter period. As
previously noted, linear mean scores are
publicly reported, but HLMRs are not.
An EPM model participant can estimate
the national distribution of HLMRs and
the performance percentiles by using
the Patient Survey Results in the
Hospital Compare downloadable
database found on Data.Medicare.gov,
https://data.medicare.gov/data/
hospital-compare?sort=relevance&tag=
patient%20survey%20results, to
calculate the HLMRs for all IPPS
hospitals with 100 or more completed
surveys in a 4-quarter period.
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(g) Calculating the Rate and
Performance Period
We proposed to be consistent with the
HIQR Program, which uses 4 quarters of
data for HCAHPS (79 FR 50259). For the
EPMs, we proposed to use the most
recently available HCAHPS 4-quarter
roll-up to calculate the HLMR score for
the initial year of the EPMs. The
proposed measure performance period
is discussed in section III.E.5. of the
proposed rule (81 FR 50794), and
summarizes measure performance
periods for performance years 1 through
5 of the EPM performance years. We
note that improvement on the HCAHPS
Survey (#0166) measure would be
determined from the measure
performance period available for the
year immediately preceding the EPM
model performance year. We sought
comment on this proposal to include the
HCAHPS Survey (NQF #0166) measure
in the EPMs to assess quality
performance and capture patient
experience of care.
The following is a summary of the
comments received and our responses.
Comment: Several commenters did
not support or were skeptical of the
inclusion of HCAHPS because it is an
overall measure of all patients receiving
hospital services that is not specific to
heart attacks, bypass surgery, or joint
replacements. Therefore, HCAHPS does
not reflect quality for targeted episodes
of care. In addition, the measure is too
narrow because it only encompasses
patient experience during the inpatient
hospital stay and does not capture
information about patients’ experience
later in the episode of care. For these
reasons, commenters did not believe
that the measure captures the correct
information, and it will be of limited
value to clinicians for quality
improvement.
Response: We appreciate the concerns
from the commenters about the broad
patient population covered by this
measure. Although the HCAHPS Survey
encompasses a broader range of patients
than the model episode definitions, we
are not aware of evidence that such
patients’ experience of care differs
markedly from those of the larger group
of eligible patients after patient-mix
adjustment for service line (surgery) and
age have been applied. Having all
patients responding to the survey helps
to inform hospitals on areas for
improvement. From a survey
implementation standpoint, it is not
feasible to target only Medicare
beneficiaries who had a specific surgery,
or to calculate the HCAHPS Linear
Mean Roll-up score on the basis of
particular surgical patients. In addition
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to complicating the administration of
the survey, the number of completed
surveys from such a narrow set of
patients would be, for many hospitals,
too small to support reliable
measurement or comparison. The
inclusion of the HCAHPS Survey
measure (NQF #0166) as currently
implemented and the HLMR derived
from it in these models will present
participating hospitals with a further
incentive to improve experience of care
for all patients. HCAHPS, which was
launched in 2006 and has been
continuously administered ever since, is
familiar to over 4,000 hospitals.
Modifications to the standardized
implementation protocols would be
disruptive to the other programs that
employ HCAHPS data, such as the HIQR
Program and Hospital Value-Based
Purchasing program. We believe
through the HCAHPS Survey measure
(NQF #0166), CMS programs continue
to highlight the importance of assessing
patient experience of care.
Comment: Several commenters
recognized patient satisfaction as an
important component of quality and
supported the use of HCAHPS as a way
to measure patient feedback. One
commenter appreciated CMS not
creating a bar that is too high for the
quality measures included in the EPMs.
Response: We thank the commenters
for their support.
Comment: Several commenters were
concerned about compounding
penalties for the CJR participants that
are also selected for participation in the
SHFFT model. Commenters further
noted that the HCAHPS survey is
already a significant part of quality
measurement through its inclusion in
the Hospital Value Based Purchasing
Program.
Response: We appreciate the
commenters’ concerns regarding the
inclusion of HCAHPS in multiple CMS
programs. However, this measure aligns
with our priorities to reduce AMI and
CABG mortality and complications
while improving patient experience, as
well as our priorities to reduce major
LEJR surgery complications while
improving patient experience for SHFFT
model beneficiaries, like those in the
CJR model. Through HCAHPS, CMS
programs continue to highlight the
importance of assessing patient
experience of care. Furthermore, this
approach allows hospitals to align with
other CMS hospital quality programs,
including programs that tie payment to
performance such as the HVBP Program,
and streamlines EPM measures for EPM
participants testing more than one EPM.
Comment: Several commenters
recommended that CMS reduce the
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weight percentage assigned to HCAHPS.
One commenter suggested that HCAHPS
should only be 15 percent of the overall
quality score, whereas another
commenter recommended a reduced,
phased-in weighting at least for years 1
and 2.
Response: We believe that the
proposed weight percentage assigned to
HCAHPS is appropriate and a phased-in
weighting is not necessary. Hospitals
participating in these models have had
several years of experience with the
HCAHPS survey. Since July 2007,
hospitals subject to the IPPS annual
payment update provisions have been
required to collect and submit HCAHPS
data in order to receive their full annual
payment update (71 FR 48037). NonIPPS hospitals, such as CAHs, may
voluntarily participate in HCAHPS. The
incentive for IPPS hospitals to improve
patient experience was further
strengthened by the Patient Protection
and Affordable Care Act of 2010 (Pub.
L. 111–148), which specifically
included HCAHPS performance in the
calculation of the value-based incentive
payment in the Hospital Value-Based
Purchasing program beginning with
October 2012 discharges. With respect
to the HCAHPS Linear Mean Roll-up
score measure that we proposed for the
model, hospitals began receiving
HCAHPS Summary Star Rating in their
December 2014 Hospital Compare
Preview Report. The HLMR is the basis
for the HCAHPS Summary Star Rating;
see HCAHPS Star Rating Technical
Notes at https://www.hcahpsonline.org/
StarRatings.aspx. While the HLMR is a
relatively new calculation from the
existing measures, hospitals have been
using the HCAHPS survey for many
years and have had time to become
familiar with it, with their results, and
with their standing relative to other
hospitals through information presented
on the HCAHPS On-Line Web site such
as the HCAHPS Percentiles tables
(https://www.hcahpsonline.org/
SummaryAnalyses.aspx). IPPS hospitals
have available their HCAHPS scores’
relative rank compared to other
hospitals participating in the HVBP
program. As such, we believe that
hospitals are familiar with their
individual and relative performance on
the HCAHPS Survey measure (NQF
#0166).
Comment: One commenter expressed
concern that inclusion of HCAHPS in
the EPMs could negatively affect
essential hospitals if used as part of the
quality composite score used to
determine hospital eligibility to receive
reconciliation payments. The
commenter stated that patients admitted
through the ED report lower HCAHPS
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scores, thus essential hospitals with
higher ED volumes might score lower
despite the fact that their quality could
be the same or better than other
hospitals.
Response: We have examined the
performance of ‘‘safety net’’ hospitals,
sometimes referred to as ‘‘essential’’
hospitals, on the HCAHPS component
of the HVBP program. Although we do
not have an official definition or
designation of ‘‘safety net’’ hospital, we
understand that a safety net status
typically entails one or more of three
criteria: High Medicaid share; high
proportion of uncompensated patients;
and high county-associated poverty rate.
In general, after all HCAHPS
adjustments are applied (patient mix
and survey mode), we believe that socalled safety net hospitals, as we
understand the term, perform similarly
to other hospitals. The current
adjustment approach that CMS employs
is both well-validated and necessary to
ensure fair comparisons of HCAHPS
scores across hospitals. When these
adjustments are applied according to the
rules currently in place, the
performance of safety net hospitals for
the HCAHPS portion of HVBP is typical
of hospitals in general.
With respect to HCAHPS scores of
patients admitted through hospital
emergency departments, CMS is
investigating whether participating
hospitals could submit a valid and
standardized administrative record
regarding ED admission. When
HCAHPS was developed, such an
indicator was available and was
employed in HCAHPS patient-mix
adjustment, where it had a small,
negative effect on HCAHPS scores.
However, collection of this measure
ceased several years ago due to
misgivings about its validity.
Comment: One commenter requested
that the Pain Management scores be
included in the HCAHPS measure for
CJR Performance Year 1. The
commenter believed that removing the
Pain Management scores diminish the
importance of the role pain management
plays in the recovery and sustained
well-being of patients.
Response: We remain dedicated to
improving the quality of care provided
to patients, including the appropriate
management of pain and
communication between patients and
their providers regarding pain. We
continue to believe that pain control is
an appropriate part of routine patient
care that hospitals should manage and
is an important concern for patients,
their families, and their caregivers.
Furthermore, we are unaware of any
empirical evidence demonstrating that
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399
failing to prescribe opioids lowers a
hospital’s HCAHPS Survey scores.
However, we believe the potential
confusion about the appropriate use of
the Pain Management dimension
questions, coupled with the public
health concern about the opioid
epidemic, warrants removing these
questions from Hospital VBP Program
scoring calculations until alternative
pain management questions are
available. In response to possible
confusion about the Pain Management
measure, we have finalized our proposal
to remove this dimension from the
Hospital Value-Based Purchasing
payment formula beginning in FY 2018.
However, CMS will continue publicly
report the Pain Management measure on
the Hospital Compare Web site because
we continue to believe that pain control
is an appropriate part of routine patient
care that hospitals should manage and
is an important concern for patients,
their families, and their caregivers.
Comment: One commenter was
concerned about the use of HCAHPS for
PAC/LTC based practices as there are no
current requirements to use skilled
nursing facility patient satisfaction
surveys. The commenter believed that
the measure is not appropriate for PACbased clinicians because in many
situations the information source is not
reliable due to the cognitive status of the
patients being surveyed.
Response: Patients discharged to
nursing homes and SNFs are excluded
from HCAHPS survey administration
because of the difficulty contacting such
patients and consistently surveying
them in a timely manner. We are not
aware of evidence that patients
discharged to a nursing home or SNF
have different experience of care than
other inpatients in the hospital. Only
acute-care hospitals participate in the
HCAHPS Survey, not long term care
hospitals.
Comment: One commenter
recommended that CMS make the
HCAHPS Linear Mean Roll-up (HLMR)
score publicly available in order to
allow hospitals to not only know their
HLMR score, but that of other hospitals
in order to understand their percentile
levels. The commenter further
recommended that this data be released
automatically and at least quarterly to
facilitate hospitals’ ability to improve
performance and assess financial risk.
Response: We appreciate the concerns
from the commenters about the broad
patient population covered by this
measure. Although the HCAHPS Survey
encompasses a broader range of patients
than the model episode definitions, we
are not aware of evidence that such
patients’ experience of care differs
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markedly from those of the larger group
of eligible patients after patient-mix
adjustment for service line (surgery) and
age have been applied. Having all
patients responding to the survey helps
to inform hospitals on areas for
improvement. From a survey
implementation standpoint, it is not
feasible to target only Medicare
beneficiaries who had a specific surgery,
or to calculate the HCAHPS Linear
Mean Roll-up score on the basis of
particular surgical patients. In addition
to complicating the administration of
the survey, the number of completed
surveys from such a narrow set of
patients would be, for many hospitals,
too small to support reliable
measurement or comparison. The
inclusion of the HCAHPS Survey
measure (NQF #0166) as currently
implemented and the HLMR derived
from it in these models will present
participating hospitals with a further
incentive to improve experience of care
for all patients. HCAHPS, which was
launched in 2006 and has been
continuously administered ever since, is
familiar to over 4,000 hospitals.
Modifications to the standardized
implementation protocols would be
disruptive to the other programs that
employ HCAHPS data, such as the HIQR
Program and Hospital Value-Based
Purchasing program. We believe
through the HCAHPS Survey measure
(NQF #0166), CMS programs continue
to highlight the importance of assessing
patient experience of care.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal, without
modification, to include the HCAHPS
Survey (NQF #0166) measure in the
EPMs to assess quality performance and
capture patient experience of care.
e. Potential Future Measures
CMS recognizes that there remain
gaps in quality measures targeting AMI,
CABG, and hip fracture care.
Specifically with regard to hip fracture
care, examples of potential measures
suitable for consideration for inclusion
in the SHFFT model in future
performance years include: (1) Claimsbased or hybrid risk-standardized
hospital-level mortality, complication,
and/or readmission measures intended
for assessing hospital or provider
performance for patients with hip
fracture; and (2) patient-reported
outcome data-based measures of
functional status, symptom burden,
number of days at home and/or return
to home and/or independent living
suitable for patients with hip fractures
and/or patients undergoing total hip or
knee arthroplasty as referred to in 79 FR
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50259. Additionally, we would consider
including measures of all—cause harm
across the models in future years and
appropriateness of procedures. CMS
also recognizes that care for patients
with AMI, CABG, and hip fractures
extends across care settings and
providers, and includes care provided
by a multitude of clinicians and
possible post-acute care facilities (for
example, inpatient rehabilitation
facilities, intermediate care facilities,
and/or home health services). CMS
welcomed comments on measure
concepts for future measures that
potentially could be included in the
AMI, CABG, and SHFFT models,
including measures that are attributable
to acute care and post-acute care
facilities and clinicians. CMS also
welcomed information about existing
patient-centered outcomes measures
that address quality gaps relevant to the
AMI, CABG, and SHFFT models. Any
changes to the measures included in the
AMI, CABG, and SHFFT models would
be subject to future rulemaking.
The following is a summary of the
comments received and our responses.
Comment: Several commenters
recommended implementing quality
measures across the care continuum,
including post-acute care (PAC) and
measures that address providers beyond
the hospital that provides the surgery,
such as Independence at Home, FQHCs,
PCMHs, and ACOs.
Response: We appreciate the
commenters for the suggestion to
implement quality measures across the
care continuum. We recognize that there
are some gaps in the current proposed
measures relative to other settings in
which patients receive care posthospital discharge during EPM
episodes. We will take these
recommendations into consideration in
our measure development and testing
efforts, as well as in our ongoing efforts
to identify and propose appropriate
measures for the payment models in the
future.
Comment: Several commenters
recommended the use of registries to
report data for new measures.
Commenters suggested measures from
the Core Quality Measure Collaborative
(CQMC) Cardiovascular and Orthopedic
core quality measures set, National
Cardiovascular Data Registry (NCDR)
measures, and the STS CABG
Composite Score.
Response: We thank the commenters
for their recommendations. We believe
that registries may facilitate valuable
quality improvement feedback to
hospitals. However, we note that many
registry measures are proprietary. With
that said, we agree with commenters
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that the STS CABG Composite Score is
a comprehensive NQF-endorsed
measure with strong potential to
meaningfully improve quality. The STS
CABG Composite Score measures
surgical performance based on a
combination of 11 NQF-endorsed
process and outcomes measures. We
also note that 7 of the 11 NQF-endorsed
process and outcomes measures are
used for the Physician Quality
Reporting Program (PQRS) which
promotes alignment of measurement
across programs. We are incorporating
the STS CABG composite measure (NQF
#0696) data submission as a voluntary
option weighted at 10 percent. By
including this composite measure in the
CABG EPM, we are reducing proposed
HCAHPS and mortality weights by 5
percent each for those hospitals that
voluntarily report the STS measure. We
intend to address the weighting and the
use of the actual measure score in the
next EPM rulemaking cycle. For more
information about the STS Composite
Score, we refer readers here: https://
www.sts.org/sts-public-reporting-online/
cabg-composite-score.
Comment: Several commenters
recommended that CMS explore the
opportunity to develop and implement
quality of life and patient reported
outcome measures (PROMs).
Commenters identified PROMIS Global,
VR12, SAQ–7, PHQ–2, Rose Dyspnea
Score, and International Consortium for
Health Outcomes Measurement
(ICHOM) recommended measures as
candidates for future inclusion in the
EPMs. Furthermore, two commenters
supported the inclusion of PROMs in
the SHFFT model and encouraged CMS
to mandate the PROMs for the SHFFT
model as soon as possible.
Response: We thank the commenters
for their recommendations. We will take
these into consideration as candidates
for future inclusion in the EPMs and in
our measure development and testing
efforts.
Comment: One commenter
encouraged CMS to include other
CAHPS measures, such as CG–CAHPS
and S–CAHPS.
Response: We thank the commenter
for their recommendations.
Comment: One commenter supported
holding hospitals financially
responsible for quality and encouraged
CMS to maintain the proposed
measures.
Response: We thank the commenter
for their support.
Comment: Several commenters
recommended including functional
status measures, such as functional
status improvement from admission to
discharge, Functional status change for
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patients with Hip impairments (NQF
#0423), and other NQF-endorsed
functional outcome measures in the
EPM models.
Response: We thank the commenters
for their recommendations. We will take
these into consideration as candidates
for future inclusion in the EPMs and in
our measure development and testing
efforts.
Comment: Several commenters
recommended that CMS consider 90day measures and measures for highimpact areas including medication
errors, hospital-acquired infections, and
hospital-related injuries, such as
surgical site infection (SSI) following
hip fracture, complications rate
following hip fracture, 90-day
reoperations rate following hip fracture,
percent of patients returning to prefracture ambulatory status at 90 days,
length of stay following hip fracture,
arrival to surgical procedure, and 30-day
readmissions following hip fracture.
Response: We appreciate these
comments, including the suggestions for
priority areas for further measure
development. CMS acknowledges that
outcomes measures addressing a longer
timeframe, such as 90 days, should be
pursued. In developing measures that
use a longer timeframe, CMS will
conduct empirical analyses to ensure
that such measures are scientifically
robust and to identify appropriate riskadjustment approaches. CMS will begin
initial exploration of the suggested
priority areas as well as review
condition specific and procedure
specific measure concepts. The timeline
for this to occur is dependent upon
several factors including expert panel
review and comment periods,
reliability, and validity testing, thus is
varied and subject to change. This
timeline ranges between 24–36 months,
pending no major setbacks or delays
outside of CMS control. Once such
measures are fully developed, submitted
for NQF endorsement and available,
CMS will consider the most appropriate
time frame to incorporate these
measures into the EPM quality payment
methodology through future notice and
comment rulemaking.
Comment: One commenter supported
the use of shared decision-making
measures. The commenter believed that
patients and their family caregivers
should have the opportunity to receive
all relevant information, review all
options, weigh the benefits and
potential drawbacks, and make a
decision.
Response: We thank the commenter
for their comment and agree that
patients, families and caregivers should
have the opportunity to receive relevant
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information, review all options, weigh
the benefits and potential drawbacks, to
make the best decision. We will take
this measure concept into consideration
in our ongoing measure development
and testing efforts.
5. Form, Manner, and Timing of Quality
Measure Data Submission
We believe it is important to be
transparent and to outline the form,
manner and timing of quality measure
data submission so that accurate
measure results are provided to
hospitals, and that timely and accurate
calculation of measure results are
consistently produced to determine
annual reconciliation payment. We
proposed that data submission for
Hospital 30-Day, All-Cause, RiskStandardized Mortality Rate Following
Acute Myocardial Infarction (AMI)
Hospitalization (NQF #0230)(MORT–
30–AMI); Excess Days in Acute Care
after Hospitalization for an Acute
Myocardial Infarction (AMI Excess
Days); Hospital 30-Day, All-Cause, RiskStandardized Mortality Rate (RSMR)
Following Coronary Artery Bypass Graft
(CABG) Surgery (NQF# 2558)(MORT–
30–CABG); and Hospital-Level RiskStandardized Complication Rate (RSCR)
Following Elective Primary Total Hip
Arthroplasty (THA) and/or Total Knee
Arthroplasty (TKA) (NQF #1550)(Hip/
Knee Complications) be accomplished
through the existing HIQR Program
processes. Since these measures are
claims-based measures, hospitals will
not need to submit data.
We proposed that the same
mechanisms used in the HIQR Program
to collect HCAHPS Survey (NQF #0166)
measure data also be used in the AMI,
CABG, and SHFFT models (79 FR
50259). For the hospitals that
voluntarily submit data for the Hybrid
AMI mortality measure, we anticipate, if
it is technically feasible, for data
submission processes to be broadly
similar to those summarized for the
HIQR Program for electronic clinical
quality measures. We proposed to allow
hospitals to submit the data elements
using either QRDA–I or to submit to
data elements using a simpler
spreadsheet in performance year 1. We
proposed to require hospitals to submit
data elements using only QRDA–I in
performance years 2 through 5. We
would create a template for data
reporting, provide a secure portal for
data submission, and provide education
and outreach on how to use these
mechanisms for data collection and
where to submit the hybrid AMI
voluntary data. We describe processes
for voluntary data collection in section
III.E.4.c.(2)(ii) of the proposed rule (81
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401
FR 50794). The use of QRDA for
reporting of EHR data is aligned with
requirements used by the HIQR Program
for electronic clinical quality measures.
We sought comment on the proposal to
collect EHR data through either QRDA–
I or through a simple spreadsheet in
performance year 1 and to collect EHR
data through only QRDA–I in
performance years 2 through 5.
The following is a summary of the
comments received and our responses.
Comment: One commenter was
concerned that it will be difficult to link
episode data from all of the various
sources, such as hospitals, skilled
nursing facilities, and clinical practices.
The NPRM proposes to use a simple
spreadsheet in year 1 and QRDA–I files
in subsequent years, whereas
participants submitting AMI voluntary
data will receive hospital-specific
reports that detail submission results
from the most recent performance
period. The commenter believes this
scenario requires extra work and puts
burden on providers for two different
implementation solutions. The
commenter requests additional
information on how standardized the
spreadsheets will be, as well as who
will specify the format.
Response: We thank commenters for
their suggestion to align standards
across our programs. We agree that it is
important to align these data collection
requirements to reduce burden on
hospitals and improve interoperability.
We will take this feedback into
consideration as we shape future
proposals for hybrid measures.
One of the main tenets of the 2015
Edition Health IT Certification Criteria
final rule (80 FR 62601) is to facilitate
greater interoperability for several
clinical health information purposes
and enable health information exchange
through new and enhanced certification
criteria, standards, and implementation
specifications. We note that we have
worked closely with ONC to enhance
testing and validation of certified
technology’s ability to capture,
exchange, and report electronic patient
data, such as through improved testing
and certification through the Cypress
CQM testing and certification tool. As
another example, we note that ONC
proposed a 2015 Edition ‘‘CQM—
report’’ certification criterion in the FY
2016 IPPS/LTCH PPS proposed rule that
sought stakeholder input on the
standards for representing and reporting
CQM data in certified health IT to
improve the reliability and consistency
of such data reporting (80 FR 24613
through 24614). Furthermore, the 2015
Edition criteria related to eCQMs offer
increased data portability and user
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access using the established QRDA
standards. Because of the support for
testing and certification offered by ONC
and their certification tools and
programs, the widespread deployment
of the QRDA standard and CMS’ own
recent experience that QRDA can
provide superior clinical data for
assessing quality and performance, we
will finalize our selection of QRDA–I as
the primary reporting standard for the
EPM Model Rule for program years 1–
3. If QRDA–I cannot be available to all
participants for year 1, we will make a
transitional submission format available
to systems using a spreadsheet-based
approach that will allow these sites
additional time to meet the QRDA-based
reporting requirements. We thank
commenters for their continued support
of improving the electronic reporting
process and plan to continue to make
improvements as standards evolve.
Comment: One commenter requested
that CMS conduct an analysis of any
performance differences resulting from
the transition to ICD–10 for the
measures used in the EPMs, and for
CMS to make these analyses publicly
available.
Response: The AMI EDAC, AMI and
CABG 30-day mortality measures all
have 3-year measurement periods.
Because ICD–10 implementation began
in October 2015, measure results
calculated for program years 1 through
5 of the EMPs will be based on a
combination of ICD–9 and ICD–10
coded claims. Therefore, CMS cannot
provide hospitals with any meaningful
comparison of measure results with
ICD–9 claims alone or ICD–10 claims
alone. CMS continues to test ICD–10based measure specifications to ensure
ongoing validity of the measures. CMS
provides analysis of claims data for each
new performance year added to the 3year period in the measures’ Annual
Updates and Specifications Reports
posted on QualityNet each April during
the IPPS notice of proposed rulemaking.
Comment: Several commenters
expressed concern regarding the
administrative burden imposed by the
proposed data submission. One
commenter stated that the current
submission process is highly manual, as
data must be entered for each patient
separately into the CMS spreadsheet.
The commenter suggested a portal in
which data can be uploaded and
validated monthly with greater
efficiency than the spreadsheet. Another
commenter encouraged the use of
measurement instruments which can be
administered electronically to reduce
burden.
Response: We appreciate the
commenters’ concern, however, as
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stated in 81 FR 50910, for the Hybrid
AMI mortality measure, we proposed to
allow to submit the data elements using
either QRDA–I or to submit data
elements using a simpler spreadsheet in
performance year 1. We proposed
requiring the hospitals to submit data
elements using only QRDA–I in
performance years 2 through 5. We
disagree that increased burden is placed
on providers in that there are options to
use either QRDA–I or simpler
spreadsheet in performance year 1. The
purpose of the option to use a simpler
reporting format (spreadsheet) is to
allow hospitals to perfect data
extraction with the 2017 data and
postpone mastery of reporting in the
QRDA format to the following year.
CMS would create a template for data
reporting, provide a secure portal for
data submission, and provide education
and outreach on how to use these
mechanisms for data collection and
where to submit the hybrid AMI
voluntary data. We proposed the same
mechanisms used in the HIQR Program
to collect HCAHPS Survey measure data
also be used in the AMI, CABG, and
SHFFT models (79 FR 50259).
Comment: One commenter expressed
concern about collecting quality data
that may not yield meaningful results.
The commenter recommended a delay
in collecting and reporting quality data
for the EPMs until CJR data can be
examined to ascertain its utility and
determine whether it provides robust
quality information.
Response: We note that we currently
have broad experience with pay-forperformance in Medicare programs,
including the HRRP, HVBP Program,
HAC Reduction Program, and the
Shared Savings Program. These pay-forperformance programs have improved
the quality of care for Medicare
beneficiaries. For example, since the
implementation of HRRP in 2012,
readmission and complications rates for
various medical conditions such as
elective THA/TKA have been
significantly reduced, thereby resulting
in improvements in the quality of care
for Medicare beneficiaries undergoing
joint replacement procedures.
Furthermore, pay-for-performance is a
feature of a number of Innovation Center
models currently in testing. We refer
readers to section III.D.5. of the CJR
Final Rule (80 FR 73473) for further
discussion of public reporting of payfor-performance data during
performance year 1 of the model.
We have developed and adopted a
variety of new quality measures in
programs and models since 2011, as
well as gained experience with pay-forreporting and pay-for-performance in a
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variety of models and programs
involving a wide range of health care
providers and clinical conditions. Given
our extensive experience over the past
several years with pay-for-performance
approaches, the availability of existing
measures that reflect the quality of care
for AMI, CABG, and SHFFT episodes,
and the breadth of the EPMs, which
reaches substantially all IPPS hospitals
in the selected MSAs, including those
hospitals who otherwise would not
participate in a voluntary payment
model, we believe that a pay-for
performance approach is necessary and
appropriate beginning in the model’s
first performance year. IPPS hospitals
have substantial experience over
multiple years with CMS programs that
include pay-for-performance and we
believe, given the proposed quality
measures for the EPMs, that AMI,
CABG, and SHFFT pay-for-performance
in episode payment models is a natural
extension to bundled payment of payfor-performance measures used in
current CMS programs. While we
acknowledge that pay-for-performance
is not the only way for a model to
heighten a focus on maintaining or
improving the quality of care, we
believe that the EPMs, like other
Innovation Center models, should target
both improved quality and reduced
costs. Based on our experience in other
programs and models, we believe that
pay-for-performance under the EPMs
shows great promise in moving
participant hospitals toward greater
efficiency and higher quality care. In
view of successful implementation of
pay-for-performance in other CMS
hospital programs using similar quality
measures that has resulted in significant
improvements in the quality of care, we
believe IPPS hospitals have sufficient
experience to be ready for pay-forperformance under the AMI, CABG, and
SHFFT models.
We expect that other features of the
model design, including our plans for
data sharing, will help participant
hospitals committed to care redesign
toward these goals achieve success on
both quality and cost performance for
episodes. We note that the quality
measures finalized for the model as
discussed in section III.E.2 of this final
rule rely upon data that hospitals are
already submitting and which are
already analyzed by CMS for other
programs, so we see no reason to adopt
a period of pay-for-reporting for the first
performance year of the model or
longer. In the proposed rule, we
considered a similar policy that would
not penalize hospitals with regard to
their eligibility for reconciliation
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payments for failure to meet the
proposed quality measure thresholds in
performance year 1. However, we
continue to believe that adopting payfor- reporting and not pay-forperformance in performance year 1 or
longer would be inappropriate given
that two of the proposed quality
measures are administrative claims
based measures and impose no
additional reporting burden on
hospitals, the proposed measures are all
established measures in existing CMS
quality programs, and a central goal of
the EMPs is improving care for
Medicare beneficiaries. In this regard,
the EPMs are different from some other
CMS value-based initiatives where the
data for some measures were newly
submitted by providers or newly
analyzed by CMS early in the initiative.
Furthermore, we do not believe that
participant hospitals need a year of payfor-reporting to develop systems for
analyzing episode claims under the
model, as we expect hospitals to already
be focused on improving their
performance on these measures. The
measures finalized for the EPMs are
aligned with the goals of the models, are
familiar to hospitals based on their use
in other CMS hospital programs, and are
aligned with CMS priorities to reduce
mortality and complications while
improving the patient experience.
Because the measures reflect these goals
and accurately measure hospitals’ level
of achievement and improvement on
quality outcomes that are important to
beneficiaries, we are finalizing our
proposal to implement a pay-forperformance approach in the AMI,
CABG, and SHFFT models in the first
performance year by using quality
performance in the episode payment
methodology.
Comment: One commenter
recommended clarification on the
PROM, specifically the Veterans RAND
12 Item Health Survey (VR–12) data
submission requirement to
accommodate for the handling of
missing data elements consistent with
proven methods in the scientific
literature as it determines if a hospital
has successfully met its reporting
threshold.
Response: We thank the commenter
for their suggestion. One of the generic
health-related quality of life assessment
survey that hospitals can use is the
Veterans RAND 12 Item Health Survey
(VR–12). Hospitals who elect to use this
survey instrument must report patient
responses to all of the questions; that is,
all 14 questions from this survey.
Twelve questions or items (i.e., question
groups 1–7) in the survey are used to
calculate two scores, a ‘‘Physical Health
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Summary Measure (PCS-physical
component score)’’ and a ‘‘Mental
Health Summary Measure (MCS-mental
component score).’’ Two additional
questions are included as anchor
questions that CMS will use to gauge the
clinical significance of a (physical and/
or mental health) change following an
intervention. Likewise, hospitals who
elect to use the other generic healthrelated quality of life assessment, the
PROMIS-Global, must also report
patient responses to all of the questions
to be considered for the successful
voluntary reporting of the PRO and risk
variable data component of the SHFFT
model.
Comment: Several commenters
believed that measures should be
collected at intervals more immediately
post-surgery and more routinely
afterward throughout the 6 month postdischarge duration. One commenter
further noted that a participant
hospital’s quality performance must be
considered in parallel with its financial
performance and these components be
compared, in tandem, to a pre-EPM
baseline.
Response: The measures proposed for
the AMI, CABG, and SHFFT models use
a 3-year reporting period and are
updated annually. The 3-year reporting
period ensures that hospitals have a
sufficient number of cases for a reliable
and valid estimate of their risk-adjusted
outcome rate. The measures are not
designed for more frequent reporting of
results. CMS does assess trends in
hospitals’ performance on the proposed
measures to identify potential
unintended consequences in the HIQR
program.
Comment: Several commenters were
supportive of the proposed approach to
reporting and data collection.
Commenters stated that it demonstrates
CMS’ effort to minimize administrative
burden on providers when
implementing new care models. One
commenter appreciated that many of the
proposed quality measures are currently
being reported for the Inpatient Quality
Reporting Program (IQR), thereby
reducing additional reporting burden for
hospital staff. Another commenter
commended CMS for treating and
separately bundling services for patients
who fall under the SHFFT model rather
than including them in CJR.
Response: We thank the commenters
for their support.
Comment: Several commenters raised
concerns about the proposed timeline
for voluntary data submission in the
SHFFT model. Specifically commenters
were concerned that the data
submission timeline did not align with
the model performance years. The
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403
commenters suggested that the data
submission deadline closely align with
the start date of the model so CMS can
receive relevant data and have time to
analyze initial CJR changes to make
necessary changes before
implementation of SHFFT data
collection.
Response: The intent of the proposed
timeline for voluntary data submission
for the SHFFT model is to reduce
confusion by proposing to use the same
3-year rolling time periods for
calculating readmissions and
complications performance that are
used in the hospital IQR program and to
align the data collection timeline with
the CJR model timeline starting in
program year 1. CMS will assess data
submitted for the CJR model and will
consider any necessary changes in
future rulemaking cycles for the CJR and
SHFFT models.
Comment: One commenter
recommended that CMS allow hospitals
to submit using either the QRDA–I or
QRDA–III approach for the first
performance period to allow maximum
flexibility and to assess which approach
is most feasible.
Response: For the Hybrid AMI
Mortality measure, CMS is seeking to
risk adjust individual patients, thus we
have specified QRDA–I, which
describes patient level data, as the
appropriate standard. The QRDA–III
standard, which describes aggregate
data, would not be appropriate for this
purpose. One of the main tenets of the
2015 Edition Health IT Certification
Criteria final rule (80 FR 62601) is to
facilitate greater interoperability for
several clinical health information
purposes and enable health information
exchange through new and enhanced
certification criteria, standards, and
implementation specifications. We note
that we have worked closely with ONC
to enhance testing and validation of
certified technology’s ability to capture,
exchange, and report electronic patient
data, such as through improved testing
and certification through the Cypress
CQM testing and certification tool. As
another example, we note that ONC
proposed a 2015 Edition ’’CQM—
report’’ certification criterion in the FY
2016 IPPS/LTCH PPS proposed rule that
sought stakeholder input on the
standards for representing and reporting
CQM data in certified health IT to
improve the reliability and consistency
of such data reporting (80 FR 24613
through 24614). Furthermore, the 2015
Edition criteria related to eCQMs offer
increased data portability and user
access using the established QRDA
standards. Because of the support for
testing and certification offered by ONC
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and their certification tools and
programs, the widespread deployment
of the QRDA standard and CMS’ own
recent experience that QRDA can
provide superior clinical data for
assessing quality and performance, we
will finalize our selection of QRDA–I as
the primary reporting standard for the
EPM Model Rule for program years 1–
3. If QRDA–I cannot be available to all
participants for year 1, we will make a
transitional submission format available
to systems using a spreadsheet-based
approach that will allow these sites
additional time to meet the QRDA-based
reporting requirements.
Comment: Several commenters raised
concerns about the proposed timeline
for voluntary data submission in the
SHFFT model. Specifically commenters
were concerned that the data
submission timeline did not align with
the model performance years. The
commenters suggested that the data
submission deadline closely align with
the start date of the model so CMS can
receive relevant data and have time to
analyze initial CJR changes to make
necessary changes before
implementation of SHFFT data
collection.
Response: The intent of the proposed
timeline for voluntary data submission
for the SHFFT model is to reduce
confusion by proposing to use the same
3-year rolling time periods for
calculating readmissions and
complications performance that are
used in the hospital IQR program and to
align the data collection timeline with
the CJR model timeline starting in
program year 1. CMS will assess data
submitted for the CJR model and will
consider any necessary changes in
future rulemaking cycles for the CJR and
SHFFT models.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal, without
modification, to collect EHR data
through either QRDA–I or through a
simple spreadsheet in performance year
1 and to collect EHR data through only
QRDA–I in performance years 2 through
5.
The proposed quality measure
performance periods for required and
voluntary reporting measures by the
performance year of the AMI, CABG,
and SHFFT models are displayed in
Tables 41, 42, 43, 44, and 45.
TABLE 41—SUMMARY OF QUALITY MEASURE PERFORMANCE PERIODS BY YEAR OF THE AMI MODEL
Model performance year
Measure title
1st
MORT–30–AMI * ..........................
AMI Excess Days ........................
2nd
July 1, 2014–June
30, 2017.
July 1, 2014–June
30, 2017.
3rd
July 1, 2015–June
30, 2018.
July 1, 2015–June
30, 2018.
July 1, 2016–June
30, 2019.
July 1, 2016–June
30, 2019.
4th
July 1, 2017–June
30, 2020.
July 1, 2017–June
30, 2020.
5th
July 1, 2018–June
30, 2021
July 1, 2018–June
30, 2021
* Hospital 30-Day, All-Cause, Risk-Standardized Mortality Rate Following Acute Myocardial Infarction (AMI) Hospitalization (NQF #0230)
(MORT–30–AMI).
** Excess Days in Acute Care after Hospitalization for Acute Myocardial Infarction (AMI Excess Days).
TABLE 42—SUMMARY OF QUALITY MEASURE PERFORMANCE PERIODS BY YEAR OF THE CABG MODEL
Model year
Measure l
1st
MORT–30–CABG * ......................
2nd
July 1, 2014–June
30, 2017.
3rd
July 1, 2015–June
30, 2018.
July 1, 2016–June
30, 2019.
4th
July 1, 2017–June
30, 2020.
5th
July 1, 2018–June
30, 2021
* Hospital 30-Day, All-Cause, Risk-Standardized Mortality Rate (RSMR) Following Coronary Artery Bypass Graft (CABG) Surgery (NQF# 2558)
(MORT–30–CABG).
TABLE 43—SUMMARY OF QUALITY MEASURE PERFORMANCE PERIODS BY YEAR OF THE VOLUNTARY DATA SUBMISSION
Model performance year
1st
2nd
3rd
4th
5th
July 1, 2017–August 31, 2017.
September 1 2017–
June 30, 2018.
July 1, 2018–June
30, 2019.
July 1, 2019–June
30, 2020.
July 1, 2020–June
30, 2021.
July 1, 2017–August 31, 2017.
July 1, 2019–June
30, 2020.
July 1, 2020 –June
30, 2021.
September 1,
2016–June 30,
2017.
September 1,
2017–June 30,
2018.
July 1, 2017–June
30, 2018.
July 1, 2018–June
30, 2019.
Submission of functional status
data for elective primary THA/
TKA procedures.
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Submission of EHR data elements for the Hybrid AMI Mortality Measure.
Submission of STS CABG Composite Measure data.
July 1, 2018–June
30, 2019.
July 1, 2019–June
30, 2020.
July 1, 2020–June
30, 2021.
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TABLE 44—SUMMARY OF QUALITY MEASURE PERFORMANCE PERIODS BY YEAR OF THE SHFFT MODEL
Model performance year
Measure title
1st
Hip/Knee Complications * ..
2nd
3rd
4th
5th
April 1, 2014–March
31, 2017.
April 1, 2015–March
31, 2018.
April 1, 2016–March
31, 2019.
April 1, 2017– March
31, 2020.
April 1, 2018–March
31, 2021
* Hospital-Level Risk-Standardized Complication Rate (RSCR) Following Elective Primary Total Hip Arthroplasty (THA) and/or Total Knee
Arthroplasty (TKA) (NQF #1550) (Hip/Knee Complications).
TABLE 45—SUMMARY OF QUALITY MEASURE PERFORMANCE PERIODS BY YEAR FOR REQUIRED MEAURES FOR ALL EPMS
Model performance year
Measure title
1st
HCAHPS * .........................
2nd
July 1, 2016–June
30, 2017.
July 1, 2017–June
30, 2018.
3rd
July 1, 2018–June
30, 2019.
4th
July 1, 2019–June
30, 2020.
5th
July 1, 2020–June
30, 2021
* Hospital Consumer Assessment of Healthcare Providers and Systems (HCAHPS) Survey (NQF #0166).
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6. Display of Quality Measures and
Availability of Information for the
Public From the AMI, CABG, and
SHFFT Models
We believe that the display of
measure results is an important way to
educate the public on hospital
performance and increase the
transparency of the model. We proposed
to display quality measure results on the
Hospital Compare Web site (https://
www.hospitalcompare.hhs.gov). We
believe that the public and hospitals are
familiar with this Web site and how the
information is displayed. The proposed
measures have been displayed on
Hospital Compare over the past few
years. Finally, we believe that the public
and hospitals’ familiarity with the
Hospital Compare Web site will make it
simpler to access data. We sought
comment on this proposal.
The following is a summary of the
comments received and our responses.
Comment: Several commenters
supported the proposal to publicly
report hospitals’ EPM quality
performance data on Hospital Compare.
Response: We thank the commenters
for their support.
Comment: Several commenters
expressed concern that the description
of data publicly displayed on Hospital
Compare should accurately reflect
performance. Rather than placing
hospitals with insufficient volume on a
quality measure at the 50th percentile in
the ‘‘Good’’ category, it should be
placed in a separate category noting that
there was insufficient volume to
determine a performance score. One
commenter further suggested that
hospitals be provided an opportunity to
preview and offer corrections to data
provided by CMS before reporting on
Hospital Compare.
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Response: While we understand the
concerns of the commenter that we have
no actual outcome measure results for
certain hospitals, we continue to believe
it would be unfair to disadvantage a
participant hospital in the pay-forperformance methodology of this model
based on insufficient number or no
applicable cases alone and, therefore,
we will assign these hospitals to the
50th performance percentile, which is
the middle of the national measure
performance distribution, and assign
quality performance points to the
participant hospital accordingly based
on the performance percentile scale
identified in Table 41.
We note that the Hospital Compare
Web site is the vehicle that provides
public reporting and within this Web
site we indicate that this Web site
fulfills section 1886(b)(3)(B)(viii)(VII) of
the Act, as amended by section
3001(a)(2) of the Affordable Care Act,
which requires the Secretary to establish
procedures for making information
regarding measures submitted available
to the public after ensuring that a
hospital has the opportunity to review
its data before they are made public.
Prior to the release of data on Hospital
Compare, hospitals are given the
opportunity to review data during a 30day preview period via the QualityNet
Secure Portal (https://
www.qualityreportingcenter.com/
wpcontent/uploads/2015/07/IQR_FY2017_Hospital-IQR-ProgramReferenceChecklist_Tool_7.21.2015_
FINAL508.pdf). With respect to the
HCAHPS Survey measure (NQF #0166),
CMS similarly provides hospitals with
their confidential preview reports on a
quarterly basis, before the results are
publicly reported on Hospital Compare
Web site (https://
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www.hospitalcompare.hhs.gov/) (78 FR
50778).
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal, without
modification, to display quality measure
results on the Hospital Compare Web
site (https://
www.hospitalcompare.hhs.gov).
Regarding the voluntary PRO data
collection, because we are collecting the
data required to develop a future PRObased performance measure that will
assess hospital quality of care for
patients undergoing elective primary
THA/TKA procedures, we do not plan
to publicly report on Hospital Compare.
For the STS CABG Composite measure,
which is voluntary for year one, we
intend to publicly report if operationally
feasible. We plan to utilize notice and
comment rulemaking if CMS decides to
require this measure in the future and
will thus discuss plans for public
reporting.
F. Compliance Enforcement and
Termination of an Episode Payment
Model
1. Overview and Background
The following discussion details the
enforcement mechanisms we proposed
to make available to CMS for the EPM
when an EPM participant or certain
other individuals or entities fails to
comply with the requirements of the
model.
Section 510.410 established that CMS
will enforce the CJR model requirements
against CJR participant hospitals, and
will hold each participant hospital
responsible for its own and its CJR
collaborators’ compliance with CJR
model requirements. Given that CJR
participant hospitals may receive
reconciliation payments, and may
choose to distribute or share those
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payments with their CJR collaborators,
CMS believes that enhanced scrutiny
and monitoring of CJR participant
hospitals was necessary and
appropriate. We also noted in the CJR
Final Rule (80 FR 73464) that by making
the CJR participant hospitals
responsible for compliance with the
model, CMS indirectly will be
accounting for CJR collaborators’
compliance, in addition to any direct
monitoring of such CJR collaborators
that HHS (including CMS and OIG)
conducts. Furthermore, § 510.410
established that upon discovering an
instance of CJR collaborator
noncompliance with the CJR model,
CMS, HHS, or a respective designee may
take remedial action against the CJR
participant hospital, including requiring
the participant hospital to terminate a
sharing arrangement with a CJR
collaborator and to prohibit further
engagement in the CJR model by that
collaborator, and CMS may also increase
a participant hospital’s repayment.
Section 510.410 as well as section
1115A of the Social Security Act
authorizes CMS to reduce or eliminate
a participant hospital’s reconciliation
payment as well as increase a
participant hospital’s repayment
amount. We proposed an enforcement
structure for the EPM that will be
consistent with the CJR model, as we
believe the CJR model and the EPM
share many of the same policy
characteristics.
2. Compliance Enforcement for the
EPMs
We proposed that CMS will have the
remedial actions detailed in
§ 512.460(b)(2) available for use against
any EPM participant where the EPM
participant or its EPM collaborator,
collaboration agent, or downstream
collaboration agent is not compliant
with the applicable requirements as set
forth in § 512.460(b)(1). These
compliance tools will support CMS’
objectives for the EPM to maintain or
improve quality of care, reduce program
expenditures, safeguard program
integrity, protect against fraud and
abuse, and deter noncompliance with
EPM requirements. Furthermore,
preventing EPM participants from
engaging in avoiding high-cost and
high-severity patients or from targeting
low-cost and low-severity patients will
further CMS’ goals under the CR
incentive payment model to reduce
cardiovascular mortality, improve
health-related quality of life, and reduce
the risk of hospital admission.
Additionally, these compliance tools
will support CMS’ aim under the EPM
that beneficiaries receive complete and
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accurate information, including notices
which promote increasing consumer
engagement and freedom of choice.
Given that EPM participants may choose
to enter into sharing arrangements with
EPM collaborators, those EPM
collaborators may have distribution
arrangements with collaboration agents,
and those collaboration agents may have
downstream distribution arrangements
with downstream collaboration agents,
we believe that enhanced scrutiny and
monitoring of EPM participants and
their EPM collaborators, collaboration
agents, and downstream collaboration
agents is necessary and appropriate in
order to mitigate program integrity risks.
Similar to the CJR model, we
proposed to hold the EPM participant
responsible for its own and its EPM
collaborators’ compliance with the EPM
requirements. Additionally, in the EPM
proposed rule we proposed to add EPM
participant responsibility for the other
individuals and entities with financial
arrangements under the EPM. This was
based in part on the proposed addition
of ACOs and hospitals, including CAHs,
as EPM collaborators. Specifically,
because we proposed to allow
additional entities and individuals to be
EPM collaborators, collaboration agents,
or downstream collaboration agents, we
must have tools to address
noncompliance with the requirements
of the EPM by these entities and
individuals as well. Overall, we
concluded in the proposed rule that
EPM participants should ensure that
any entity or individual with a financial
arrangement under the EPM complies
with model requirements in order to
safeguard program integrity.
We proposed that CMS have authority
to take remedial action against an EPM
participant if its related EPM
collaborator, collaboration agent, or
downstream collaboration agent fails to
comply with the requirements of the
EPM; has signed a sharing arrangement,
distribution arrangement, or
downstream distribution arrangement
that is noncompliant with the
requirements of the EPM; takes any
action that threatens the health or safety
of patients; avoids at-risk beneficiaries;
avoids patients on the basis of payer
status; is subject to sanctions or final
actions of an accrediting organization or
federal, state, or local government that
could lead to the inability to comply
with the requirements of the EPM; takes
any action that CMS determines for
program integrity reasons is not in the
best interests of the applicable EPM, or
fails to take any action that CMS
determines for program integrity reasons
should have been taken to further the
best interests of the EPM; is subject to
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action to redress an allegation of fraud
or significant misconduct; or is subject
to action involving violations of certain
laws, rules, or regulations that are
relevant to the EPM. Moreover, we
proposed that for purposes of this
provision, ‘‘failure to comply with the
requirements of the EPM’’ would
specifically include, but not be limited
to, avoiding potentially high-cost or
high-severity patients; targeting
potentially low-cost or low-severity
patients; failing to provide medically
appropriate services or systematically
engaging in the over- or under-delivery
of appropriate care; failing to provide
beneficiaries with complete and
accurate information, including
required notices; failing to allow
beneficiary choice of medically
necessary options, including nonsurgical options; or failing to follow the
requirements related to sharing
arrangements.
Proposed remedial actions included
issuing a warning letter to the EPM
participant; requiring the EPM
participant to develop a corrective
action plan; reducing or eliminating the
EPM participant’s reconciliation
payment; reducing or eliminating the
EPM participant’s CR incentive
payment; requiring the EPM participant
to terminate a sharing arrangement with
an EPM collaborator and prohibit
further engagement by the EPM
participant in sharing arrangements
with the EPM collaborator; and
terminating the EPM participant’s
participation in the EPM. Where a
participant is terminated from the EPM,
we proposed that the EPM participant
would remain liable to CMS for all
negative NPRA generated from episodes
of care that occurred prior to
termination. In addition, we noted that
any information collected by CMS in
relation to termination of a participant
from the EPM would be shared with our
program integrity colleagues at HHS, the
Department of Justice, and their
respective designees. We noted further
that should an EPM participant, or one
of its related EPM collaborators,
collaboration agents, or downstream
collaboration agents, be noncompliant
with the requirements of the EPM or
engage in unlawful behavior related to
participation in the EPM, such
information could be used in
proceedings unrelated to the
administrative enforcement mechanisms
in this section. We believe these
remedial actions are necessary tools to
safeguard program integrity, including
protecting against fraud and abuse and
deterring noncompliance with EPM
requirements.
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In summary, we set forth in proposed
§ 512.460 that EPM participants must
comply with all requirements outlined
in part 512. We specified that, except as
specifically noted in this part, the
regulations under this part must not be
construed to affect the applicable
payment, coverage, program integrity, or
other requirements under this chapter
(such as those in parts 412 and 482).
Further, we proposed in § 512.460
that CMS may take remedial actions if
an EPM participant or its related EPM
collaborators, collaboration agents, or
downstream collaboration agents—
• Fails to comply with any applicable
requirements of this part or is identified
as noncompliant through monitoring by
HHS (including CMS and OIG) of the
EPM, including but not limited to—
++ Avoiding potentially high-cost or
high-severity patients;
++ Targeting potentially low-cost or
low-severity patients;
++ Failing to provide medically
appropriate services or systematically
engaging in the over- or under-delivery
of appropriate care;
++ Failing to provide beneficiaries
with complete and accurate
information, including required notices;
++ Failing to allow beneficiary choice
of medically-necessary options,
including non-surgical options; or
++ Failing to follow the requirements
related to sharing arrangements.
• Has signed a sharing arrangement,
distribution arrangement, or
downstream distribution arrangement
that is noncompliant with the
requirements of this part;
• Takes any action that threatens the
health or safety of patients;
• Avoids at risk Medicare
beneficiaries, as this term is defined in
§ 425.20 of this part;
• Avoids patients on the basis of
payer status;
• Is subject to sanctions or final
actions of an accrediting organization or
federal, state, or local government
agency that could lead to the inability
to comply with the requirements of this
part;
• Takes any action that CMS
determines for program integrity reasons
is not in the best interests of the EPM,
or fails to take any action that CMS
determines for program integrity reasons
should have been taken to further the
best interests of the EPM;
• Is subject to action by HHS
(including OIG and CMS) or the
Department of Justice to redress an
allegation of fraud or significant
misconduct, including intervening in a
False Claims Act qui tam matter, issuing
a pre demand or demand letter under a
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civil sanction authority, or similar
actions; or
• Is subject to action involving
violations of the physician self-referral
law, civil monetary penalties law,
Federal anti-kickback statute, antitrust
laws, or any other applicable Medicare
laws, rules, or regulations that are
relevant to the EPM.
We proposed the remedial actions to
include the following:
• Issuing a warning letter to the EPM
participant.
• Requiring the EPM participant to
develop a corrective action plan,
commonly referred to as a CAP.
• Reducing or eliminating the EPM
participant’s reconciliation payment.
• Reducing or eliminating the EPM
participant’s CR incentive payment.
• Requiring the EPM participant to
terminate a sharing arrangement with an
EPM collaborator and prohibit further
engagement by the EPM participant in
sharing arrangements with the EPM
collaborator.
• Terminating the EPM participant’s
participation in the EPM. Where a
participant is terminated from an EPM,
the EPM participant will remain liable
for all negative NPRA generated from
EPM episodes that occurred prior to
termination.
Furthermore, we proposed that CMS
may add 25 percent to a repayment
amount on the EPM participant’s
reconciliation report if all of the
following conditions are met:
• CMS has required a corrective
action plan from the EPM participant.
• The EPM participant owes a
repayment amount to CMS.
• The EPM participant fails to timely
comply with the corrective action plan
or is noncompliant with the EPM’s
requirements.
The proposals for compliance
enforcement were included in proposed
§ 512.460. We sought comment on our
proposals.
The following is a summary of the
comments received and our responses.
Comment: Several commenters
acknowledged the need for remedial
actions proposed by CMS under the
EPM to address EPM participant
noncompliance with EPM requirements.
However, some commenters expressed
concern about CMS’ proposal that EPM
participants would be held responsible
for the compliance of their related EPM
collaborators, collaboration agents, and
downstream collaboration agents. The
commenters claimed that such an
expansive accountability for the
conduct of others would create a large
regulatory and legal burden for the EPM
participant, especially regarding
collaboration agents and downstream
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407
collaboration agents with which EPM
participants do not have direct
contractual relationships. One
commenter stated their belief that while
EPM participants can and should
validate that each EPM collaborator,
collaboration agent, and downstream
collaboration agent has a compliance
program, EPM participants should not
be responsible for the compliance of
these individuals and entities with the
requirements of the EPM. The
commenter asserted that the compliance
of these parties is essentially out of the
EPM participant’s control when the
individual or entity with a financial
arrangement under the EPM is not
owned or operated by the EPM
participant. The commenter urged CMS
to instead hold each EPM collaborator,
collaboration agent, and downstream
collaboration agent accountable for its
own compliance with the requirements
of the EPM or, at a minimum, to identify
specific elements for which the EPM
participant would be responsible for the
compliance of its related EPM
collaborators, collaboration agents, and
downstream collaboration agents.
Response: We appreciate the concerns
of some of the commenters regarding the
potential burdens on EPM participants
associated with accountability for the
conduct of other individuals and
entities, especially for those individuals
and entities that do not have direct
contractual relationships with the EPM
participant. With regard to the
commenter’s belief that EPM
participants can and should validate
that each EPM collaborator,
collaboration agent, and downstream
collaboration agent has a compliance
program, we want to clarify that our
proposal for financial arrangements
would only require that an EPM
collaborator have a compliance program
that includes oversight of the sharing
arrangement as proposed in
§ 512.500(b)(4). We did not propose to
require that collaboration agents or
downstream collaboration agents have a
compliance program.
We note that under the EPM, the EPM
participant is the sole entity that is
financially accountable to CMS. It is
only through an EPM participant that
the opportunity exists for EPM
collaborators, collaboration agents, and
downstream collaboration agents to
have financial arrangements under the
EPM. In addition, because only EPM
participants can generate internal cost
savings and receive reconciliation
payments and then choose to distribute
those funds through gainsharing
payments to EPM collaborators, we
believe a focus on EPM participants is
necessary and appropriate. Therefore,
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the enforcement authority over the EPM
participant is key to successfully
implementing these models and
ensuring program integrity.
We note that the Shared Savings
Program regulations in § 425.210(b) and
§ 425.218 similarly permit CMS to hold
ACOs accountable for not only the
noncompliance of their ACO
participants and ACO providers/
suppliers but also for the
noncompliance of any other individuals
or entities performing functions or
services related to ACO activities.
Furthermore, CMS may terminate the
participation agreement with an ACO
when an ACO, ACO participants, ACO
providers/suppliers, or other
individuals or entities performing
functions or services related to ACO
activities fail to comply with any of the
requirements of the Shared Savings
Program under the regulations. The
scope of the compliance enforcement
authority in the Shared Savings Program
is similar to our proposal to hold the
EPM participant accountable for the
noncompliance of its related EPM
collaborators, collaboration agents, and
downstream distribution agents.
In the EPM proposed rule and in this
final rule, we provide our rationale for
the EPM requirements that we proposed
and are finalizing, which we believe are
necessary to advance the goals of the
EPM, protect beneficiaries from
potential adverse consequences of the
EPM, and provide program integrity
safeguards for the Medicare program.
We believe it is important that EPM
participants, EPM collaborators,
collaboration agents, and downstream
collaboration agents consider these
requirements holistically and determine
how to best to achieve compliance.
Thus, we will not identify only a subset
of EPM requirements or the other
proposed provisions to identify
noncompliance specified in
§ 512.460(b)(1)(i) through (ix) for which
we will hold the EPM participant
responsible with respect to its related
EPM collaborators, collaboration agents,
or downstream collaboration agents.
Finally, we emphasize that entering
into sharing arrangements is a choice
that EPM participants may make, and
EPM participants also have the choice
as to whom to select as an EPM
collaborator based on selection criteria
developed by the EPM participant as
specified in § 512.500(a)(3) and
finalized in this final rule. In addition,
EPM participants have the authority
through their contracts with their EPM
collaborators to address the conduct of
collaboration agents and downstream
collaboration agents.
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Comment: One commenter asserted
that the compliance enforcement
provisions that CMS proposed will not
protect EPM beneficiaries in a timely
manner. The commenter observed that
CMS specifically proposed to allow for
termination of an EPM participant’s
participation in the EPM or termination
of a sharing arrangement when an EPM
participant or its related EPM
collaborator, collaboration agents, or
downstream collaboration agent
discriminates against at-risk Medicare
beneficiaries by avoiding caring for
them or takes an action that threatens
patients’ health or safety. However, the
commenter expressed concern that CMS
did not appear to allow the termination
of an EPM participant or termination of
a sharing arrangement for an EPM
participant or EPM collaborator,
respectively, found to have purposefully
steered a patient to a particular provider
which it knew, or should have known,
would fail to provide needed care. The
commenter claimed that CMS’ proposal
also did not address the termination of
providers found to have deliberately
administered substandard care. The
commenter stated that termination or
exclusion of poorly performing
providers from the EPM is important
because participants cannot ultimately
control patient choice and where
beneficiaries choose to go postdischarge. The commenter urged CMS
to expressly allow for remedial action in
the case of an EPM participant or an
EPM collaborator who repeatedly
withholds care as referenced in other
parts of the proposed rule, or steers
patients to particular providers which it
knew, or should have known, would fail
to provide needed care.
Response: We appreciate the
commenter’s concern about protecting
beneficiaries under the EPM from the
potentially harmful consequences of
withholding care, providing
substandard care, or steering
beneficiaries to particular providers
who fail to provide needed care. These
are serious concerns, and we believe
that our proposal for compliance
enforcement under the EPM allows CMS
to take remedial action if any of these
circumstances are discovered. We
proposed in § 512.460(b)(1)(iii) that
CMS may take remedial action against
any EPM participant when the EPM
participant or its related EPM
collaborator, collaboration agent, or
downstream collaboration agent takes
any action that threatens the health or
safety of patients. If an EPM participant,
EPM collaborator, collaboration agent,
or downstream collaboration agent is
found to have taken any action that
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threatens the health or safety of patients,
including but not limited to,
withholding care, providing
substandard care, or steering
beneficiaries to certain providers or
suppliers who will fail to provide
needed care, the regulations adopted in
this final rule allow CMS to take
remedial action. Moreover, CMS may
take remedial action in response to
actions that threaten health and safety
that include the types of actions the
commenter requested, including issuing
a warning letter to the EPM participant;
requiring the EPM participant to
develop a corrective action plan;
reducing or eliminating the EPM
participant’s reconciliation payment;
increasing the EPM participant’s
repayment amount; reducing or
eliminating the EPM participant’s CR
incentive payment; requiring the EPM
participant to terminate a sharing
arrangement with an EPM collaborator
and prohibit further engagement by the
EPM participating in sharing
arrangements with the EPM
collaborator; or terminating the EPM
participant’s participation in the EPM.
Comment: One commenter requested
that CMS address how a patient’s
clinical outcome may be considered
when determining noncompliance with
the requirements of the EPM. The
commenter stated there could be
scenarios where health care that may
not be in the best interest of an EPM
participant’s cost performance under the
EPM may be clinically in the best
interest of the patient.
Response: We appreciate the
commenter’s concern that compliance
enforcement take into account what is
clinically in the best interest of the
patient. We note that the types of
noncompliance we identified in our
proposal in § 512.460(b)(1)(i) included
failing to provide medically appropriate
services or systematically engaging in
the over- or under-delivery of
appropriate care or failing to allow
beneficiary choice of medically
necessary options, including nonsurgical options. Each case of
noncompliance determined based on
the provisions in § 512.460(b)(1) will be
considered on a case-by-case basis, and
CMS will weigh both the financial
interests of the Medicare program and
the clinical needs of beneficiaries when
determining the appropriate remedial
action.
Comment: One commenter
encouraged CMS to clarify the proposal
in § 512.460(b)(1)(vii) that CMS may
take remedial action if an EPM
participant or its related EPM
collaborator, collaboration agent, or
downstream collaboration agent ‘‘takes
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any action that CMS determines for
program integrity reasons is not in the
best interests of the applicable episode
payment model, or fails to take any
action that CMS determines for reasons
of program integrity should have been
taken to further the best interests of the
EPM.’’ The commenter requested that in
the final rule, CMS provide examples of
actions that are not clear violations of
existing fraud and abuse statutes that
would fall into this category of
noncompliance.
Response: The proposed provision in
§ 512.460(b)(1)(vii) where the
commenter requested that CMS provide
examples would allow CMS the
flexibility to take remedial action where
the EPM participant or its related EPM
collaborator, collaboration agent, or
downstream collaboration agent takes
any action that CMS determines is not
in the best interests of the EPM, or fails
to take any action that CMS determines
for program integrity reasons should
have been taken to further the best
interests of the EPM. This provision is
purposefully structured to include
noncompliance that is not a clear
violation of existing fraud and abuse
statutes. For example, an EPM
participant could fail to respond to a
request from CMS for records to enable
the investigation into concerns about
the potential selection of EPM
collaborators based on the volume and
value of referrals. In this scenario, CMS
could determine that the EPM
participant was noncompliant based on
this proposed provision because the
EPM participant failed to provide access
to records so that the potential program
integrity concerns could be assessed.
Thus, CMS could take remedial action
in this example by issuing a warning
letter to the EPM participant regarding
the need to supply the requested
records. In another example, if an audit
of claims for physicians’ services
furnished to EPM beneficiaries by a
collaboration agent found a high error
rate in payment due to incorrect coding,
CMS could determine for program
integrity reasons that the coding errors
of the collaboration agent are not in the
best interests of the EPM. CMS could
then take remedial action by requiring
the EPM participant to develop a
corrective action plan to address the
coding errors.
Comment: One commenter expressed
concern about the proposal in
§ 512.460(b)(1)(ix) that CMS may take
remedial action when the EPM
participant or its related EPM
collaborator, collaboration agent, or
downstream collaboration is subject to
action involving violations of the
physician self-referral law, civil
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monetary penalties law, Federal antikickback statute, antitrust laws, or any
other applicable Medicare laws, rules,
or regulations that are relevant to the
EPM. The commenter stated specifically
that violations ‘‘of any other applicable
Medicare laws, rules, or regulations that
are relevant to EPM’’ is overly broad so
that CMS should apply a reasonable
knowledge standard to the EPM
participant’s awareness of a
collaborator’s involvement in such
matters.
Response: We appreciate the
commenter’s interest in the standard
that CMS will apply for purposes of the
proposed provision in
§ 512.460(b)(1)(ix) in identifying
circumstances when an EPM participant
or its related EPM collaborator,
collaboration agent, or downstream
collaboration agent is subject to action
for violations of the specified laws, or
any other applicable Medicare laws,
rules, or regulations that are relevant to
the EPM. However, we disagree with the
commenter’s suggestion that CMS apply
a reasonable knowledge standard to the
EPM participant’s awareness of a
collaborator’s involvement in such
matters. We believe the information
regarding whether an individual or
entity is ‘‘subject to action’’ should be
readily available to the EPM participant.
EPM participants can also include
provisions in their contracts to require
that they be notified when such
circumstances exist. Accordingly, we
believe it is reasonable to expect that the
EPM participant will be aware of all
such circumstances when its related
EPM collaborator, collaboration agent,
or downstream collaboration agent is
specifically subject to action involving
violations of the physician self-referral
law, civil monetary penalties law,
Federal anti-kickback statute, antitrust
laws, or any other applicable Medicare
laws, rules, or regulations that are
relevant to the EPM. Therefore, we
believe that use of a bright-line standard
is more appropriate to determine
compliance with this provision,
regardless of what specific individual or
entity is subject to action for a violation.
Comment: One commenter
recommended that CMS strengthen the
accountability for EPM participants that
are found to withhold or delay care by
imposing a separate financial penalty
that is independent of repayment
responsibility. The commenter reasoned
that an EPM participant that has already
had to repay CMS the maximum
percentage permitted under the EPM,
that is, met the stop-loss limit, will have
little incentive to refrain from other
potentially harmful cost-cutting
strategies unless the EPM participant
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409
could be subject to a separate financial
penalty that is not subject to the EPM
stop-loss limit.
Response: Given the proposed
compliance tools for the EPM, as well as
the existing laws and regulations that
prohibit care stinting, provision of
substandard care, or denial of medically
necessary care, we believe that it is
unnecessary to implement a process for
a separate financial penalty outside of
the compliance tools that we proposed.
When an EPM participant or its related
EPM collaborator, collaboration agent,
or downstream collaboration agent
engages in these noncompliant
behaviors, CMS may take remedial
action, including reducing or
eliminating the EPM participant’s
reconciliation payment or reducing or
eliminating the EPM participant’s CR
incentive payment amount. In addition,
under circumstances where CMS has
required a corrective action plan, the
EPM participant owes a repayment
amount to CMS, and the EPM
participant fails to timely comply with
the corrective action plan or is
noncompliant with the EPM’s
requirements, we proposed that CMS
may add 25 percent to a repayment
amount on an EPM participant’s
reconciliation report. We are clarifying
in regulation in this final rule that the
25 percent is a penalty.
Moreover, we note that in accordance
with the provisions finalized in
§ 512.305(d) for determination of the
reconciliation payment or repayment
amount, we first calculate the NPRA for
a performance year that is adjusted, if
applicable, for the stop-loss or stop-gain
percentage that applies. Next, we add in
the results from the post-episode
spending and ACO overlap calculations,
if applicable, for the prior performance
year. Finally, we adjust the
reconciliation or repayment amount as
described in §§ 512.460(b) and (c). Thus,
the potential financial penalty of up to
25 percent of the repayment amount on
an EPM participant’s reconciliation
report if certain conditions are met is
not subject to the EPM stop-loss
limitation. Therefore, the EPM
participant has a continuing financial
incentive to refrain from other
potentially harmful cost-cutting
strategies that could lead CMS to apply
this financial penalty even if that EPM
participant already has to repay CMS
the maximum percentage permitted
under the stop-loss limitation under the
EPM. We believe this structure for the
financial penalty is consistent with the
request of the commenter.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposals in § 512.460 for
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compliance enforcement, with
modification to clarify that the 25
percent that CMS may add to the
repayment amount under certain
conditions is a penalty. The compliance
enforcement provisions for the EPM are:
• EPM participants must comply with
all of the requirements outlined in this
part. Except as specifically noted in this
part, the regulations under this part
must not be construed to affect the
applicable payment, coverage, program
integrity, or other requirements under
this chapter (such as those in parts 412
and 482 of this chapter).
• CMS may take one or more of the
remedial actions set forth in this section
if an EPM participant or its related EPM
collaborator, collaboration agent, or
downstream collaboration agent does
any of the following:
++ Fails to comply with any
requirements of this part or is
identified as noncompliant through
monitoring by HHS (including CMS
and OIG) of the EPM, including but
not limited to any of the following:
—Avoiding potentially high-cost or
high-severity patients.
—Targeting potentially low-cost or lowseverity patients.
—Failing to provide medically
appropriate services or systematically
engaging in the over- or underdelivery of appropriate care.
—Failing to provide beneficiaries with
complete and accurate information,
including required notices.
—Failing to allow beneficiary choice of
medically necessary options,
including non-surgical options.
—Failing to follow the requirements
related to sharing arrangements.
++ Has signed a sharing arrangement,
distribution arrangement, or
downstream distribution arrangement
that is noncompliant with the
requirements of this part.
++ Takes any action that threatens the
health or safety of patients.
++ Avoids at-risk Medicare
beneficiaries, as this term is defined
in § 425.20 of this chapter.
++ Avoids patients on the basis of
payer status.
++ Is subject to sanctions or final
actions of an accrediting organization
or Federal, state, or local government
agency that could lead to the inability
to comply with the requirements and
provisions of this part.
++ Takes any action that CMS
determines for program integrity
reasons is not in the best interests of
the EPM, or fails to take any action
that CMS determines for program
integrity reasons should have been
taken to further the best interests of
the EPM.
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++ Is subject to action by HHS
(including OIG and CMS) or the
Department of Justice to redress an
allegation of fraud or significant
misconduct, including intervening in
a False Claims Act qui tam matter,
issuing a pre-demand or demand
letter under a civil sanction authority,
or similar actions.
++ Is subject to action involving
violations of the physician selfreferral law, civil monetary penalties
law, Federal anti-kickback statute,
antitrust laws, or any other applicable
Medicare laws, rules, or regulations
that are relevant to the EPM.
• Remedial actions include the
following:
++ Issuing a warning letter to the EPM
participant.
++ Requiring the EPM participant to
develop a corrective action plan,
commonly referred to as a CAP.
++ Reducing or eliminating the EPM
participant’s reconciliation payment.
++ Reducing or eliminating the EPM
participant’s CR incentive payment.
++ Requiring the EPM participant to
terminate a sharing arrangement with
an EPM collaborator and prohibit
further engagement by the EPM
participant in sharing arrangements
with the EPM collaborator.
++ Terminating the EPM participant’s
participation in the EPM. Where a
participant is terminated from an
EPM, the EPM participant will remain
liable for all negative NPRA generated
from EPM episodes that ended prior
to termination.
• CMS may add a 25 percent penalty
to a repayment amount on the EPM
participant’s reconciliation report if all
of the following conditions are met:
++ CMS has required a corrective
action plan from the EPM participant.
++ The EPM participant owes a
repayment amount to CMS.
++ The EPM participant fails to timely
comply with the corrective action
plan or is noncompliant with the
EPM’s requirements.
3. Termination of an Episode Payment
Model
We set forth in proposed § 512.900
that CMS may terminate any EPM for
reasons including, but not limited to,
the following:
• CMS no longer has the funds to
support the applicable model.
• CMS terminates the applicable
model in accordance with section
1115A(b)(3)(B) of the Act. As provided
by section 1115A(d)(2) of the Act,
termination of the model is not subject
to administrative or judicial review.
We did not receive any comments on
these proposals.
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Final Decision: We are finalizing the
proposals in § 512.900 for termination of
an EPM, with editorial modifications.
CMS may terminate any EPM for
reasons including, but not limited to,
one of the following:
• CMS no longer has the funds to
support the EPM; or
• CMS terminates the EPM in
accordance with section 1115A(b)(3)(B)
of the Act. As provided by section
1115A(d)(2) of the Act, termination of
the model is not subject to
administrative or judicial review.
G. Monitoring and Beneficiary
Protection
1. Introduction and Summary
With the AMI, CABG, and SHFFT
models, we proposed to complement the
CJR model implemented in 2016, as we
believe the proposed EPMs represented
additional opportunities to improve
beneficiary access, patient outcomes,
and overall quality of care across a
broader spectrum of clinical conditions.
The proposed EPM policies were
intended to support making care more
easily accessible to beneficiaries when
and where they need it, increasing
beneficiary engagement and thereby
informing beneficiary choices.
In the proposed rule, we stated our
belief that the proposed EPMs would
improve beneficiary access and
outcomes, but we further noted that
these same opportunities could be used
to try to steer beneficiaries into lower
cost services without an appropriate
emphasis on maintaining or increasing
quality. We refer to section III.E.3 of the
proposed rule (81 FR 50881 through
50893) for discussion of the
methodology for incorporating quality
into the payment structure and the
measures utilized for these models,
which we believe could help identify
and mitigate these possibilities.
2. Beneficiary Choice
As with the CJR model, we proposed
that all hospitals (with some limited
exceptions) in the selected geographic
areas for each EPM would participate in
the proposed EPMs. An individual
beneficiary will retain full choice of
providers as they do currently, but upon
agreeing to be admitted to an EPM
participant that results in discharge
from an MS–DRG that initiates an EPM
episode, the beneficiary will not be able
to opt out of his or her care being
included in an EPM episode under the
responsibility of that EPM participant.
We do not believe that it is appropriate
or consistent with other Medicare
programs to allow a patient to opt out
of a payment system that is unique to
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a particular geographic area. For
example, the state of Maryland has a
unique payment system under
Medicare, but that payment system does
not create an alternative care delivery
system, nor does it in any way impact
beneficiary decisions. Moreover, we do
not believe that an ability to opt out of
a payment system is a factor in
upholding beneficiary choice or is
otherwise advantageous to beneficiaries
or even germane to beneficiary
decisions, given that the proposed EPMs
will not increase beneficiary costsharing. However, we also believe that
full notification and disclosure of the
EPMs and their possible implications is
critical for beneficiary understanding
and protection. Further, it is important
to create safeguards for beneficiaries to
ensure that care recommendations are
based on clinical needs and not
inappropriate cost savings. This is
particularly important when one entity
is held accountable for payments across
multiple provider settings as in the
design of the proposed EPMs. It also is
important for beneficiaries to know that
they can raise any concerns with their
physicians, with the 1–800–MEDICARE
helpline, or with their local Quality
Improvement Organizations (QIOs).
As with the CJR model and other
episode-based payment models, the
proposed EPMs will not limit a
beneficiary’s ability to choose among
Medicare providers or the range of
services that will be available to them.
Beneficiaries will continue to choose
any Medicare participating provider, or
any provider that has opted out of
Medicare, with the same costs,
copayments and responsibilities as they
have for other Medicare services that are
not included in an EPM episode.
Although the proposed EPMs will allow
EPM participants to enter into sharing
arrangements with certain providers,
suppliers, and ACOs and allow EPM
participants to recommend to
beneficiaries preferred providers and
suppliers, within the constraints of
applicable laws and regulations, EPM
participants may not restrict
beneficiaries to a list of preferred or
recommended providers or suppliers
that surpass any restrictions that already
exist under current statutes and
regulations. Moreover, an EPM
participant may not charge any EPM
collaborator a fee to be included on a
list of preferred providers or suppliers,
nor may the EPM participant accept
such payments, which would be
considered to be outside the realm of
sharing arrangements. Although the
emergent nature of some of the clinical
conditions that are the focus of the
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proposed EPMs may limit beneficiaries’
abilities to plan the hospital where they
will be treated for these conditions,
such constraint should be no different
than it will be in the absence of the
EPMs. Thus, the proposed EPMs will
not create any new restriction of
beneficiary freedom to choose
providers, including surgeons,
hospitals, post-acute care providers, or
any other providers or suppliers.
To specifically safeguard beneficiary
freedom of choice in decision-making
about care following hospital discharge,
we proposed to require that, similar to
CJR participant hospitals, EPM
participants must, as part of discharge
planning, account for potential financial
bias by providing each patient with a
complete list of all available post-acute
care options in the applicable service
area consistent with medical need,
including beneficiary cost-sharing and
quality information (where available
and as applicable). We stated our
expectation that the treating physician,
as well as all other treating
practitioners, would continue to
identify and discuss all medically
appropriate options with the
beneficiary, and that the EPM
participant will discuss the various
facilities and providers available to meet
the clinically identified needs. These
proposed requirements for EPM
participants would supplement the
discharge planning requirements under
existing CoPs. We also specifically note
that neither the CoPs nor this proposed
transparency requirement preclude EPM
participants from recommending
preferred providers and suppliers
within the constraints created by
current laws and regulations, as
coordination of care and optimization of
care are important factors for successful
participation in the EPMs.
We invited comment on these
proposals, including additional
opportunities to ensure high quality
care.
The following is a summary of the
comments received and our responses.
Comment: Several commenters
requested that beneficiaries be
permitted to opt out of the EPMs. One
commenter was concerned that a
beneficiary may try to ‘‘opt out’’ by
driving to another hospital that is not an
EPM participant, thus restricting the
beneficiary’s freedom of choice.
Response: In proposing that
beneficiaries are not able to opt out of
the EPMs, we meant that beneficiaries
are not able to opt out of having their
care, when furnished in an EPM
episode, paid for under the EPM
methodology. Once a beneficiary
initiates an episode through admission
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411
to an EPM participant for a clinical
condition that results in discharge from
an MS–DRG that begins an EPM
episode, their care is automatically
included in the EPM and they are
unable to opt out of having their care
included in an EPM episode. In the
geographic region of that EPM
participant, the EPM is how Medicare
pays for care for the clinical condition
that is the focus of that EPM episode.
Beneficiaries do have the choice to
avoid their care being paid for under the
EPM by choosing to be admitted to a
hospital that is not an EPM participant,
which would require that the hospital
be in a different MSA that has not been
selected for EPM participation. In some
cases, such as elective CABG, a
beneficiary may choose to travel to a
hospital that is not a CABG model
participant for surgery that is planned in
advance if the beneficiary does not want
his or her care to be paid for under the
CABG model. However, in most cases
under the proposed EPMs this choice is
infeasible because beneficiaries with
AMI or hip fracture are often
transported to hospitals by emergency
medical services that use transport
protocols to determine the hospital that
will receive the beneficiary. In other
cases of AMI, even though beneficiaries
may travel themselves to an emergency
department, it is likely that the severity
of AMI symptoms will lead them to go
to the nearest hospital emergency
department. Once the treatment plan for
the hip fracture or AMI is established in
the emergency department, to the extent
that plan may include immediate
admission for surgery or medical
management, it is infeasible and unsafe
for the beneficiary to choose to travel to
another hospital at that point to avoid
their care being included in an EPM.
By not allowing beneficiaries to opt
out of having their care paid for under
the EPM, this does not mean that their
right to choose or decline otherwise
covered Medicare items and services is
limited. EPM beneficiaries retain their
right to choose or decline items and
services that are covered by Medicare.
The EPMs are testing changes to how
Medicare pays for care but, like
Medicare payment systems, they neither
define nor limit coverage, nor limit
beneficiary choices to any specific
covered services. In both the EPMs and
other Medicare payment methodologies,
providers are expected to not treat
Medicare beneficiaries differently from
other patients based on differences in
Medicare payment. Moreover, the
beneficiary safeguards adopted in this
final rule ensure that the EPM payment
structure does not disadvantage
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Medicare beneficiaries. We note that
within traditional FFS Medicare we do
not allow beneficiaries to opt out of any
Medicare payment systems as payment
systems exist to ensure appropriate
payment for similar services across
beneficiaries and across providers.
Furthermore, because beneficiary costsharing is unchanged under the EPMs,
it does not have a direct financial effect
on beneficiaries and, therefore,
minimizes any impacts on beneficiary
freedom of choice.
We discuss in the next section our
requirement for beneficiary notification
under the EPMs that must contain an
explanation of the model and how it
may or may not impact their care;
notification that the beneficiary retains
freedom of choice to choose providers
and services for the EPM episode (where
those choices are especially relevant
during the 90 days following hospital
discharge); explanation of how patients
can access care records and claims data
through an available patient portal, and
how they can share access to their Blue
Button® electronic health information
with caregivers; a statement that all
existing Medicare beneficiary
protections continue to be available to
the beneficiary, including the ability to
report concerns of substandard care to
the QIOs and the 1–800–MEDICARE
helpline; and a list of the providers and
suppliers with whom the EPM
participant has a sharing arrangement.
We also require that individuals and
entities with financial arrangements
under the EPMs furnishing care to EPM
beneficiaries provide notice to the
beneficiary of the EPM’s structure and
the existence of the financial
arrangement. Even if the clinical
condition of a beneficiary makes it
unrealistic for the beneficiary to make
an active choice about whether or not
his or her care is included in an EPM
episode, we believe the notification
policies provide important safeguards to
protect beneficiary freedom of choice
and access to care throughout EPM
episodes which continue for 90 days
following discharge from the anchor
hospitalization. Notification allows
beneficiaries to understand the potential
impact of the EPMs on their care and
gives them the opportunity to
understand the interests of all parties
when they are presented with care
recommendations that may lead to less
costly care under the EPMs.
Comment: Many commenters
commended CMS for providing
beneficiaries with the ability to choose
among Medicare providers and the
range of services that would be available
to them under the EPM. Some
commenters were pleased that EPM
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participants may not limit beneficiaries
upon hospital discharge to receiving
services only from preferred or
recommended providers. Other
commenters believe that changes to
beneficiary care patterns under the
EPMs may result in beneficiaries not
being given true choice to continue to
receive care within their home
community and advocated for stronger
protections to ensure that this choice is
available.
Several commenters provided
suggestions about strategies CMS could
employ to ensure that beneficiary
freedom of choice is not being
compromised under the EPMs. They
encouraged CMS to monitor EPM
episode claims data and publish these
findings as part of the EPM evaluation
to promote transparency and an
understanding of the EPM’s effects. The
commenters supported CMS’ proposal
to review and audit hospitals if CMS has
reason to believe an EPM participant is
compromising beneficiary access to
care. The commenters also
recommended that CMS explore both
the retrospective monitoring reviews
discussed in the proposal rule, as well
as the potential for real-time monitoring
to provide more immediate information
about EPM beneficiary care.
Response: We appreciate the support
of the commenters for our proposal that
beneficiaries retain their freedom to
choose providers and suppliers, as well
services, under the EPMs, in the context
of the EPMs that encourage increased
care coordination and clinical pathways
that may improve the quality and
efficiency of EPM episodes. We
understand and share the interest of the
commenters in ensuring that this
freedom of choice is realized in practice
in the experience of EPM beneficiaries,
when the financial incentives under the
EPMs may lead EPM participants and
treating providers and suppliers to make
specific treatment recommendations to
advance the EPM goal of improving the
quality and efficiency of care. We
believe that our final policies for
beneficiary notification, including our
requirements for the provision of a list
of post-acute care providers as part of
discharge planning and for monitoring
throughout the EPMs as discussed in
sections III.G.3. through 6. of this final
rule, provide important safeguards for
EPM beneficiary freedom of choice.
Monitoring will help us to confirm that
EPM beneficiary freedom of choice is
not being restricted and to address
timely issues of noncompliance by EPM
participants or their related EPM
collaborators, collaboration agents, or
downstream collaboration agents that
arise.
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Comment: Many commenters
provided a variety of perspectives on
CMS’ proposal to require, as part of
discharge planning and referral, EPM
participants to inform beneficiaries of
all Medicare participating post-acute
care providers in an area and identify
those post-acute care providers with
whom the EPM participant has sharing
arrangements, as well as the proposal
that EPM participants may recommend
preferred provider and suppliers,
consistent with applicable statutes and
regulations.
The commenters in favor of CMS’
proposal reasoned that it was most
consistent with maintaining beneficiary
choice under the EPMs, in the context
of the financial incentives of the EPMs
to reduce episode spending. However,
even under CMS’ proposal, multiple
commenters were apprehensive about
the potential for patient ‘‘soft steering’’
between EPM participants and postacute care providers to occur due to the
incentives for EPM participants to
reduce expenditures, which could result
in stinting on care or directing
beneficiaries to low-cost providers that
may provide substandard care. Several
commenters were concerned that if an
EPM participant reduced the number of
preferred providers the EPM participant
recommends in response to the financial
incentives under the EPMs, patients
may be required to travel further for care
or be cared for by a provider that is not
the best fit for their medical needs. A
number of commenters recommended
that CMS could mitigate the potential
for soft steering by adding additional
requirements for the information
provided to EPM beneficiaries about
post-acute care providers. One
commenter urged CMS to institute such
additional requirements for those
preferred providers that are
recommended by an EPM participant,
including requiring that any preferred
provider furnished enhanced services
and/or higher quality services. Another
commenter urged CMS to minimize
steering by requiring hospitals to inform
patients and their families of the postacute care options available in their
geographic area, as well as the pros and
cons of selecting a particular post-acute
care provider, including the provider’s
capabilities and limitations.
Other commenters disagreed with
elements of CMS’ proposed
requirements for the information that
EPM participants must provide to
beneficiaries as part of the discharge
planning process. Some commenters
objected to CMS’ proposal that the EPM
participant provide each patient with a
‘‘complete list of all available post-acute
care options in the applicable service
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area,’’ arguing that a complete list may
be difficult to keep current because
post-acute care providers change often.
Other commenters claimed that
providing a complete list of post-acute
care providers is not useful and will
confuse and overwhelm beneficiaries
when they receive this list, as well as a
list of preferred providers and suppliers.
The commenters pointed out that the
complete list does not identify the
quality of the post-acute care providers.
As such, commenters suggested that
EPM participants be permitted to
provide a preferred list of post-acute
care providers only, as long as that list
is compiled based upon objective
quality metrics which are explained to
the beneficiary. Several commenters
requested that CMS allow EPM
participants to provide a list of postacute care options based on the patient
need.
The commenters who urged CMS to
allow EPM participants to provide a
preferred list also requested that all
Medicare discharge planning
requirements be waived since EPM
participants are being held financially
accountable for costs throughout the
episode. The commenters contended
that by receiving a targeted list of postacute care providers to choose from,
EPM beneficiaries would be more likely
to engage in their follow up care.
Alternatively, the commenters
recommended that if CMS does not
allow EPM participants to provide only
a preferred list that EPM participants
should be allowed to exclude certain
post-acute care providers with poor
quality performance from the complete
list. They rationalized these suggestions
by stating that continuity of care efforts
may be hampered between EPM
participants and preferred providers if
beneficiaries choose to receive postacute care services from providers on
the complete list as opposed to the
preferred list, particularly if those postacute care providers have poor quality
performance, yet the EPM participant is
still responsible for the cost and quality
performance of the EPM episode. The
commenters further asserted that in
order to align with the goals of the EPM
to reduce cost and improve quality of
care and care coordination through care
redesign efforts, EPM participants
should be permitted collaborate with
post-acute care providers by selectively
targeting those post-acute care providers
best able to meet the need for
consistency of care and ongoing
collaboration and communication with
EPM participants regarding the care of
EPM beneficiaries.
Other commenters in favor of
providing only a preferred list believe
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this approach would make it easier for
physicians to know which beneficiaries
are in the EPMs and for which they are
accountable. Several commenters urged
CMS to allow hospitals, physicians, and
post-acute care facilities to organize into
provider teams that can better
coordinate care for patients and improve
adherence to treatment plans
throughout the episode. The
commenters were concerned about EPM
participants that would be held
accountable for EPM episode quality
and spending if the patient chooses a
sub-optimal post-discharge facility and
believe that EPM participants should be
able to recommend post-acute care
providers that they have evaluated and
work with to provide higher quality,
lower cost care.
Response: Given the wide range of the
commenters’ views, we believe that our
proposed policy on the information
about post-acute care providers that
must be shared with beneficiaries as
part of discharge planning and referral
represents a middle position that
appropriately balances transparency and
beneficiaries’ need to be informed of
their full range of post-acute care
provider options to maintain freedom of
choice, with EPM participants’ desire to
inform beneficiaries of those post-acute
care providers that are most efficient
and provide the highest quality care.
We believe that requiring the
provision of a complete list is most
consistent with the CoP on discharge
planning in § 482.43 and ensures that
beneficiaries have full information
about post-acute care providers in the
area. To allow EPM participants to
provide only a preferred list, even if that
list were compiled based on objective
criteria, could restrict beneficiary
freedom of choice of providers and
suppliers under the EPM and would be
inconsistent with the discharge
planning CoP on that basis. It could also
increase the risk of patient ‘‘soft
steering’’ between EPM participants and
post-acute care providers due to the
incentives for EPM participants to
reduce expenditures, which could result
in stinting on care or directing
beneficiaries to low-cost providers that
may provide substandard care. We did
not propose to waive any aspect of the
discharge planning CoP and continue to
believe the CoP provides important
protections for Medicare beneficiaries,
including those in an EPM episode,
regarding discharge planning, while the
proposed EPM requirements are
designed to supplement existing
discharge planning requirements in the
context of the EPMs. We also disagree
with the commenters that providing a
complete list of post-acute care
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413
providers in the area would reduce the
likelihood of meaningful beneficiary
engagement in follow up care as
compared to their engagement if we
were to permit EPM participants to
provide only a list of preferred
providers and suppliers.
Therefore, as we proposed we are
requiring EPM participants to provide a
complete list of post-acute care
providers to EPM beneficiaries as part of
discharge planning and referral, and we
will not waive Medicare’s discharge
planning CoP. EPM participants need to
make sure the complete list provided to
EPM beneficiaries is based on the most
current, available information. There are
publicly available sources that can be
used to maintain and update complete
lists of post-acute care providers in the
area. Because such complete lists are
required to be presented to patients for
whom home health care or post-hospital
extended care services are indicated and
appropriate as determined by the
discharge planning evaluation under the
discharge planning CoP in the discharge
plan for patients who are likely to suffer
adverse health consequences upon
discharge if there is no adequate
discharge planning under § 482.43, we
believe that EPM participants already
prepare such lists for many
beneficiaries. Therefore, applying this
requirement to all EPM beneficiaries
with a medical need for a specific level
of post-acute care services does not
result in any significant additional
administrative burden on EPM
participants.
While we proposed to require that
EPM participants provide each patient
with a complete list of all available postacute care options in the applicable
service area consistent with medical
need, we did not propose the
parameters related to medical need in
regulation. We agree with the
commenters that the complete list of
post-acute care providers presented to
EPM beneficiaries should be based on
medical need. For example, we do not
believe it would be appropriate for an
EPM participant to provide a complete
list of SNFs to an EPM beneficiary as
part of discharge planning and referral
if SNF care would not be medically
necessary for the beneficiary following
hospital discharge. Therefore, we are
clarifying in § 512.450(a)(1) that as part
the discharge planning and referral,
EPM participants must provide a
complete list of HHAs, SNFs, IRFs, or
LTCHs that are participating in the
Medicare program in an area, and that
this list must be presented to EPM
beneficiaries for whom home health
care, SNF, IRF, or LTCH services are
medically necessary.
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We further note that, while this list
must include all post-acute care
providers that meet the regulatory
requirements and, therefore, may not
exclude those post-acute care providers
with poor quality performance based on
the provisions of the EPM, we also
proposed to require that the complete
list include beneficiary cost-sharing and
quality information (where available
and as applicable), although we did not
incorporate this in our proposed
regulations. We do not believe it would
be appropriate for the complete list to
require that beneficiary cost-sharing and
quality information be included due to
the potential burden on EPM
participants to prepare this additional
information. However, we are
confirming that EPM participants may
provide beneficiary cost-sharing and
quality information about post-acute
care providers on the complete list, as
long the EPM participant includes costsharing and quality information that is
comparable for all the post-acute care
providers on the complete list.
Providing this information on only a
subset of post-acute care providers on
the complete list could be used to steer
beneficiaries to certain post-acute care
providers and that would be contrary to
the purposes of transparency and
beneficiary freedom of choice that are
the underlying reasons for providing the
complete list.
In response to the commenters who
expressed concern that beneficiaries
would be confused by the complete list
of post-acute care providers, especially
if also provided with a preferred list of
providers, we believe that discharge
planning involves discussions with
beneficiaries and caregivers and that
those professionals engaged in discharge
planning, including the treating
physician as well as all other treating
practitioners, will continue to identify
and discuss all medically appropriate
options with the beneficiary to meet the
beneficiary’s clinically identified needs.
In addition, we expect that the EPM
participant will discuss the various
facilities and providers available to meet
the clinically identified needs, taking
into account patient and family
preferences when they are expressed.
We are confident that through these
important discussions related to postdischarge planning EPM participants
will be available to satisfactorily address
any confusion on the part of
beneficiaries and caregivers about the
list(s) of post-acute care providers that
the EPM beneficiary receives.
We proposed that EPM participants
could also identify preferred providers
and suppliers as part of the discharge
planning and referral process, consistent
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with applicable statutes and regulations.
This would allow EPM participants to
provide information to EPM
beneficiaries about high-quality,
efficient providers that an EPM
participant would prefer patients
choose, on the basis of internal
assessments of quality and cost. Because
we recognize that there may be many
high quality and efficient post-acute
care providers and suppliers who do not
enter into sharing arrangements with
EPM participants, we do not believe that
the EPM participant’s list of preferred
providers and suppliers must include
only EPM collaborators, nor do we
believe that all EPM collaborators must
be considered to be preferred providers
and suppliers.
While we understand that some
commenters would like us to
additionally require that the preferred
providers and suppliers recommended
by the EPM participant be determined
based on specific criteria such as the
provision of enhanced services or higher
quality care in order to further safeguard
against patient steering in discharge
planning, we believe that establishing
such requirements would be overly
prescriptive and is unnecessary.
Because EPM participants are
responsible for EPM episode cost and
quality performance, and the EPM
episode includes the period of time
during which an EPM beneficiary would
be receiving post-acute care services
following discharge from the anchor
hospitalization, EPM participants have a
vested interest in recommending only
those post-acute care providers on a
preferred list that the EPM participant
has reason to believe will provide care
that will advance the EPM goals.
Therefore, we do not believe it is
necessary for to us to set additional
requirements for the list of preferred
providers and suppliers beyond those
already applicable under existing
statutes and regulations because to do so
would limit the flexibility of EPM
participants to identify such preferred
providers and suppliers. We
recommend that EPM participants be
transparent in how preferred providers
and suppliers are generally selected,
and note that policies that define the
relationships between the EPM
participant and the physicians and postacute care providers and suppliers in its
region must be consistent with
applicable laws and regulations, but we
do not believe that the details of
hospitals’ internal business processes
must be disclosed.
Allowing EPM participants to
recommend post-acute care providers
on the preferred list to EPM
beneficiaries, in addition to providing
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the complete list, meets the need of
EPM participants for care redesign that
improves the quality and reduces the
cost of EPM episodes through
collaboration with post-acute care
providers that are best able to provide
consistency of care and ongoing
collaboration and communication with
EPM participants regarding the care of
EPM beneficiaries, while not restricting
beneficiary freedom of choice. We
disagree that considerations of ease of
physician identification and tracking of
EPM beneficiaries should be a
consideration in determining the lists of
post-acute care providers that are
provided to EPM beneficiaries as part of
the discharge planning and referral
process. EPM participants are
accountable for EPM episodes and,
therefore, have the primary
identification and tracking
responsibility for EPM beneficiaries.
We agree with those commenters who
believe that hospitals, physicians, and
post-acute care facilities that organize
into provider teams may better
coordinate care for patients and improve
adherence to treatment plans
throughout the EPM episodes. Our
provisions for financial arrangements
under the EPMs that are discussed in
section III.I. of this final rule facilitate
the financial alignment of providers,
suppliers, and ACOs in care redesign
that advances the goals of the EPMs. By
allowing EPM participants to
recommend to EPM beneficiaries postacute care providers on a preferred list,
while requiring transparency about the
existence of sharing arrangements with
post-acute care providers on the list and
prohibiting EPM participants from
charging fees or accepting payments
from any EPM collaborator to be on the
list, we expect that EPM participants
will be able to capitalize on the care
redesign work of such teams, without
restricting beneficiary freedom of
choice. EPM participants are able to
recommend post-acute care providers
on a preferred list that is developed in
a way that is consistent with applicable
statues and regulations and who they
have evaluated and work with to
provide higher quality, lower cost care,
as long as the financial relationships
among the parties are disclosed.
Finally, since there is no requirement
that the beneficiary receive post-acute
care services from a provider on a
preferred list, we do not believe the size
of the preferred list will influence the
distance an EPM beneficiary needs to
travel for post-acute care services. The
beneficiary may select any provider of
post-acute care services for care, and the
EPM participant must also provide a
complete list of post-acute care
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providers in the area so that the
beneficiary has complete information to
make his or her choice.
Comment: Several commenters
requested clarification of ‘‘in the area’’
in the context of the requirement that
EPM participants must inform
beneficiaries of all Medicare
participating post-acute care providers
in the area as part of discharge planning
and referral because the proposed
regulation did not define this phrase.
The commenters observed that ‘‘in the
area’’ could have different meanings for
different EPM participants and
beneficiaries. One commenter noted that
for EPM participants that provide
tertiary care, it would be unreasonable
to require them to provide a complete
list of post-acute care providers in the
patient’s home service area when it is
not the same service area as the EPM
participant.
Response: As discussed in the
proposed rule (81 FR 50915), the
proposed requirement for EPM
participants to inform beneficiaries of
all participating post-acute care
providers in an area as part of discharge
planning and referral would supplement
the discharge planning requirements
under the existing CoP. The intention of
this EPM requirement is to ensure that
beneficiaries are given information
about potential post-acute care options
in a geographic area that is convenient
to the beneficiary after discharge from
the hospital. Therefore, for consistency
with the complete lists of HHAs or SNFs
already required for some patients in the
discharge plan under the discharge
planning CoP, we are requiring that
EPM participants provide a list of
HHAs, SNFs, IRFs, or LTCHs that are
available to the EPM beneficiary, that
are participating in the Medicare
program, and that serve the geographic
area (as defined by the HHA) in which
the patient resides, or in the case of a
SNF, IRF, or LTCH, in the geographic
area requested by the patient. As
discussed previously, this list must be
presented to EPM beneficiaries for
whom home health care, SNF, IRF, or
LTCH services are medically necessary.
We have added to § 512.2 the definition
of area that is the same definition used
in the CoP for discharge planning. Area
means ‘‘as defined in § 400.200 of this
chapter, the geographical area within
the boundaries of a State, or a State or
other jurisdiction, designated as
constituting an area with respect to
which a Professional Standards Review
Organization or a Utilization and
Quality Control Peer Review
Organization has been or may be
designated.’’ We note that we expect the
SNF list provided to an EPM beneficiary
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would also include all rural hospital
providers of SNF-level care in swing
beds in the geographic area requested by
the patient.
In response to the commenter who
was concerned that it would be
unreasonable to require EPM
participants to provide a complete list of
post-acute care providers in the
patient’s home service area when it is
not the same service area as the EPM
participant, we note that this
requirement already exists under the
CoP for discharge planning for those
Medicare beneficiaries who need a
discharge plan and for whom home
health care is indicated and appropriate
as determined by the discharge planning
evaluation. The EPMs simply extend
this requirement to all EPM
beneficiaries so we believe the provision
of such lists is feasible for EPM
participants. We emphasize that the
EPMs do not restrict Medicare
beneficiaries’ ability to choose to receive
post-acute care services from any
Medicare-enrolled provider, regardless
of the geographic location of that
provider.
Comment: Several commenters
encouraged CMS to allow EPM
participants to educate beneficiaries on
where electronic listings of post-acute
care providers can be found, rather than
providing EPM participants with hard
copy lists. The commenters suggested
that beneficiaries could be provided
with a notification advising where the
complete, electronic list could be
located, and that beneficiaries may
receive a hard copy upon request.
Other commenters requested that
CMS, rather than the EPM participant,
provide a list of all Medicareparticipating post-acute care providers
through the CMS and/or MAC Web
sites, as CMS already has this
information. The commenters asserted
that compiling, updating and providing
this information is an administrative
burden on EPM participants that could
be better handled by CMS.
Response: We appreciate commenters’
feedback regarding the form and
preparation of the complete list of postacute care providers that EPM
participants must provide to EPM
beneficiaries based on medical necessity
as part of discharge planning and
referral. We believe it is imperative to
provide the complete list, as well as a
preferred list if applicable, in a written
manner as part of discharge planning
and referral. Beneficiaries may not have
online access at the time of discharge
planning, and we believe that the
presentation of hard copy lists is key to
facilitating productive discharge
planning discussions with beneficiaries
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415
and caregivers. EPM participants are
welcome to post these lists on their Web
site to supplement any hard copy list
provided as a part of discharge planning
and referral.
Finally, we believe that the EPM
participant, rather than CMS, is in the
best position to provide the complete
list of post-acute care providers that is
medically necessary for an EPM
beneficiary. Because such complete lists
are required to be presented to patients
for whom home health care or posthospital extended care services are
indicated and appropriate as
determined by the discharge planning
evaluation under the discharge planning
CoP in the discharge plan for patients
who are likely to suffer adverse health
consequences upon discharge if there is
no adequate discharge planning under
§ 482.43, we believe that EPM
participants already prepare such lists
for many beneficiaries. In addition, we
expect that the EPM participant will
discuss with the EPM beneficiary the
various facilities and providers available
to meet the clinically identified needs,
taking into account patient and family
preferences when they are expressed
and, therefore, the EPM participant is
best-positioned to prepare the complete
list and provide it to the EPM
beneficiary.
Comment: Several commenters stated
their belief that the best approach to
avoiding patient steering and promoting
patient choice is by educating the
beneficiary about the EPMs and the
effects on the care they may receive.
Some commenters further requested that
CMS mandate shared decision-making
tools be used during the discharge
planning process, such as a patientdecision aid to provide balanced,
evidence-based sources of information
about treatment options. Several
commenters encouraged CMS to adopt
more detailed requirements for an allinclusive discharge planning process
that engages a broad team of health
professionals in the discharge decisionmaking process, considers the
beneficiary’s personal health care goals
and preferences in order to provide for
better access to care, and does not lose
sight of what best meets the needs of the
individual patient, while still being
cost-effective. One commenter urged
CMS to specifically require that
discharge planning involve an
interdisciplinary team that incorporates
expertise in all post-acute care
capabilities.
One commenter who believes that
discharge planning has historically been
focused on getting the patient out of the
hospital rather than any extended
planning relative to post-hospital care
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urged CMS to consider the wider and
time-extended responsibility for posthospital care planning that occurs under
an EPM. The commenter requested that
CMS require the EPM participant to
offer advance care planning discussions
as part of care planning that represents
the evolution of hospital discharge
planning to fit the needs of EPMs.
Other commenters requested that
CMS provide a discharge planning
notice template to ensure that discharge
planning under the EPMs leads to
successful transitions. One commenter
further recommended that CMS soften
the language in the CoP for discharge
planning to enable more fruitful
conversations between patients and
their care teams, and ultimately more
effective and efficient transitions of
care.
Response: We appreciate the interest
of the commenters in successful
discharge planning for EPM
beneficiaries that results in improved
quality and reduced costs for EPM
episodes. As discussed previously, we
did not propose to waive any aspect of
the discharge planning CoP and
continue to believe the CoP provides
important protections for Medicare
beneficiaries, including those included
in an EPM episode of care, regarding
discharge planning, while the proposed
EPM requirements are designed to
supplement existing discharge planning
requirements in the context of the
EPMs. We believe that adopting
additional requirements under the EPMs
for discharge planning or care planning
beyond those that currently exist under
all applicable statues and regulations
would be overly restrictive for EPM
participants without providing
additional, necessary beneficiary
safeguards and is, therefore,
unnecessary. Therefore, we will not
require EPM participants to engage in
specific additional activities such as
advance care planning, use specific
strategies such as shared decisionmaking tools, or involve specified teams
of health professionals, beyond any
existing requirements under applicable
statutes and regulations. For these same
reasons, we also decline to adopt the
commenters’ suggestion that CMS
provide a discharge planning template
to EPM participants, as we believe such
a template would be overly restrictive.
We expect that the accountability of
EPM participants for the cost and
quality of EPM episodes will lead them
to work toward successful discharge
planning that results in post-discharge
services and beneficiary experiences
that advance the EPM goals. As part of
care redesign, we expect that EPM
participants may make changes to their
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current discharge planning processes to
improve care coordination and informed
beneficiary decision-making to the
extent these factors are expected to
improve the quality and efficiency of
EPM episode care and the revised
approaches are consistent with all
applicable statutes and regulations.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposals in § 512.450(a)
for beneficiary choice under the EPMs,
with modification to clarify the
complete list of post-acute care
providers to be provided to the EPM
beneficiary as part of discharge planning
and referral. Additionally, we are
finalizing the proposal that beneficiaries
cannot opt out of having their care
included in an EPM episode, without
modification. The EPM beneficiary
choice policies are the following:
• The EPMs do not restrict Medicare
beneficiaries’ ability to choose any
Medicare enrolled provider or supplier,
or any physician or practitioner who has
opted out of Medicare.
++ As part of discharge planning and
referral, EPM participants must provide
a complete list of HHAs, SNFs, IRFs, or
LTCHs that are participating in the
Medicare program, and that serve the
geographic area (as defined by the HHA)
in which the patient resides, or in the
case of a SNF, IRF, or LTCH, in the
geographic area requested by the
patient.
—This list must be presented to EPM
beneficiaries for whom home health
care, SNF, IRF, or LTCH services
are medically necessary.
—EPM participants must specify on the
list those post-acute care providers
on the list with whom they have a
sharing arrangement.
—EPM participants may recommend
preferred providers and suppliers,
consistent with applicable statutes
and regulations.
—EPM participants may not limit
beneficiary choice to any list of
providers or suppliers in any
manner other than that permitted
under applicable statutes and
regulations.
—EPM participants must take into
account patient and family
preferences when they are
expressed.
—EPM participants may not charge any
EPM collaborator a fee to be
included on any list of preferred
providers or suppliers, nor may the
EPM participant accept such
payments.
3. Beneficiary Notification
As we stated in the EPM proposed
rule, we believe that beneficiary
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notification and engagement is essential
because under the proposed EPMs, there
will be a change in the way EPM
participants are paid, which could affect
the type of care or treatments
beneficiaries receive. While we believe
that existing Medicare provisions are
effective in protecting beneficiary
freedom of choice and access to
appropriate care, we also believe that
the additional safeguards implemented
with the CJR model will also be
appropriate under the proposed EPMs.
We believe that appropriate beneficiary
notification should—(1) explain the
model; (2) advise beneficiaries and their
families or caregivers of the
beneficiaries’ clinical needs and caredelivery choices; and (3) clearly specify
that any non-hospital provider holding
a risk-sharing arrangement with the
EPM participant should be identified to
the beneficiary as a financial partner of
such EPM participant for the purposes
of services covered under the proposed
EPMs’ episodes. Through these policies,
we sought to enhance beneficiaries’
understanding of their care, improve
their abilities to share in the decisionmaking, and give them the opportunity
to consider competing benefits even as
they are presented with cost-saving
recommendations. We believe that
appropriate beneficiary notification
should do all of the following:
• Explain the model and how it may
or may not impact their care.
• Inform patients that they retain
freedom of choice to choose providers
and services.
• Explain how patients can access
care records and claims data through an
available patient portal and through
sharing access to care-givers to their
Blue Button® electronic health
information.
• Advise patients that all standard
Medicare beneficiary protections remain
in place, including the ability to report
concerns of substandard care to Quality
Improvement Organizations (QIO) and
the 1–800–MEDICARE helpline.
However, we acknowledged that
because of the emergent nature of
admissions related to the clinical
conditions that are the focus of the
proposed EPMs, in particular the AMI
and SHFFT models, many patients
initially admitted for such episodes may
not, at the time of admission, be capable
of receiving appropriate notification. In
addition, there may be situations in
which it is not determined until after an
admission that the patient’s care will be
included in an EPM episode. In such
situations, because the decision to admit
may not be made in advance, it would
be appropriate that the notifying entity
be the EPM participant. Nonetheless,
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consistent with CJR policy, we proposed
that EPM participants must: (1) Require
all providers and suppliers that execute
EPM sharing arrangements with such
EPM participants to share with
beneficiaries or beneficiary
representatives certain notification
materials, to be developed or approved
by CMS, that detail the applicable EPM;
and (2) where feasible, provide such
information in advance of admission for
services included in EPM episodes.
When, due to the emergent nature of the
admission, it is not feasible to provide
such notification in advance of
admissions, we proposed that the EPM
participant would be responsible for
providing such notifications as soon as
reasonably practicable but no later than
discharge from the hospital accountable
for the episode. Under our proposal,
EPM participants would be required to
provide such notifications as a
condition of any EPM sharing
arrangements. Where an EPM
participant does not have such sharing
arrangements with providers or
suppliers that furnish services to
beneficiaries during EPM episodes, or
where admissions for covered episodes
of care are ordered by physicians who
do not have such EPM sharing
arrangements, we proposed that the
EPM participant must provide such
beneficiary notification materials at the
earliest time that is reasonably
practicable but no later than discharge
from the hospital accountable for the
episode.
Further, we proposed that each
participant of an ACO that has entered
into a sharing arrangement with the
EPM participant provide to each EPM
beneficiary a written notice of the EPM’s
structure and the existence of the ACO’s
sharing arrangement with the EPM
participant. Under this proposal, the
ACO must require any ACO participant
with which such ACO has relevant
distribution arrangements, to provide
the written notification. We proposed
the ACO must provide such beneficiary
notification no later than the time at
which the beneficiary first receives
services from such ACO participant
and/or an ACO PGP member
collaboration agent during the EPM
episode. We understand that various
providers and suppliers, including
hospitals, may be ACO participants;
therefore, if, due to the emergent nature
of a particular admission, it is not
feasible to provide such notification in
advance of such admission, the ACO
participant would be responsible for
providing such notification as soon as
reasonably practicable but no later than
discharge from the hospital accountable
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for the episode. The purpose of this
proposed policy was to ensure that all
beneficiaries who initiate EPM episodes
and/or their designated representatives
receive the beneficiary notification
materials as early as possible. We
believe that this proposal targeted
beneficiaries for whom information is
relevant, and increased the likelihood
that patients would become engaged
and seek to understand the EPMs and
their potential impact on their care.
We also proposed that an EPM
participant must provide the beneficiary
with a written notice of any potential
financial liability associated with noncovered services recommended or
presented as an option as part of
discharge planning, no later than the
time that the beneficiary discusses a
particular post-acute care option or at
the time the beneficiary is discharged,
whichever occurs earlier. We proposed
that if the hospital knows or should
have known that the beneficiary is
considering or has decided to receive a
non-covered post-acute care service or
other non-covered associated service or
supply, the hospital must notify the
beneficiary that the service would not
be covered by Medicare. Moreover, if
the hospital is discharging a beneficiary
to a SNF prior to the occurrence of a 3day hospital stay, and the beneficiary is
being transferred to or is considering a
SNF that would not qualify under the
SNF 3-day waiver discussed in section
III.J.6.a. of the proposed rule (81 FR
50939 through 50041), the hospital must
notify the beneficiary that he or she will
be responsible for costs associated with
that stay, except those which would be
covered by Medicare part B during a
non-covered inpatient SNF stay.
We proposed that all providers and
suppliers that are required to provide
notice to beneficiaries of the EPM model
(participant and collaborator hospitals,
PGPs, physicians, nonphysician
practitioners, post-acute care providers
and suppliers, and ACOs) must be able
to, upon request by CMS, indicate
compliance with the beneficiary
notification requirements outlined in
this section. The participant or
collaborator should be able to generate
a list of beneficiaries that received such
notification and when the notification
was received and provide it to CMS
upon request. We noted that the method
employed to document beneficiary
notification may vary; for example,
some hospitals and collaborators may
retain a list of all beneficiaries that
received the notification; document in
the medical record that the beneficiary
received the beneficiary notification;
add a barcode to the notification form to
be scanned into the medical record; or
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417
employ another method of
recordkeeping. Regardless of the method
used for recordkeeping, the entity must
be able to provide CMS with a list of all
beneficiaries that received the
notification materials in a specified time
period. This requirement will aid CMS
in monitoring EPM participant and
collaborator compliance with the EPM
notification requirements.
We noted that Medicare beneficiaries
are accustomed to receiving similar
notices of rights and obligations from
health care providers prior to the start
of inpatient care, or, as appropriate,
under emergency conditions. In
following the same guidelines
established for the CJR model, we aimed
to limit confusion and to provide
consistent direction to hospitals which
may be participating in both the CJR
model and the EPMs. We invited
comment on ways in which the timing
and source of beneficiary notification
might be modified to best serve the
needs of beneficiaries without creating
unnecessary administrative work for
providers.
The following is a summary of the
comments received and our responses.
Comment: A number of commenters
stressed that education and counseling
for patients and caregivers is crucial to
patient outcomes. From the perspective
of the commenters, when patients and
caregivers receive real-time information
from providers in language they can
understand, patients and caregivers can
then take on more active roles and
participate more fully in the care
patients receive and make more
informed decisions. The commenters
commended CMS for recognizing the
importance of communication between
providers, patients, and caregivers in
favorably influencing health outcomes.
In addition, the commenters agreed that
beneficiaries should be adequately
educated about applicable Medicare
provisions for their care so that they can
make informed choices about what care
is appropriate for them. Most
commenters were pleased that CMS
proposed detailed beneficiary
notification requirements that would
require EPM participants and CJR
hospital participants to advise patients
and caregivers of care choices and
explain how the EPMs or CJR model
might impact the care they receive. One
commenter suggested that detailed
beneficiary notification should only be
provided upon beneficiary request.
Other commenters stated that the
proposed notification requirements
imposed on EPM participants and CJR
hospital participants add a significant
unnecessary burden with no notable
impact on beneficiary care. One
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commenter stated that EPM beneficiary
notification is unnecessary because
providers and suppliers do not provide
such notices under the IPPS when a
beneficiary is admitted to the hospital.
Another commenter stressed that the
complexities of patient identification,
attribution, and precedence rules make
providing the correct notification at the
correct time an operational barrier to
successful beneficiary notification
under the EPM. While several
commenters agreed with the idea of
promoting transparency for
beneficiaries, from their perspective this
ideal was outweighed by the
administrative burden of beneficiary
notification. The commenters stated that
the beneficiary notification requirement
will require investment in significant
heath IT resources to build the
necessary tools and reminders in the
Electronic Health Record in order to
comply with the detailed notification
requirement. Several commenters also
objected to the proposed requirement
that EPM participants furnish to CMS
upon request the list of patients who
received beneficiary notification and the
date the notification was provided on
the grounds that it is unduly
burdensome. One commenter on the
proposal for the CJR model requested
that CMS delay the proposed
requirement that CJR hospital
participants be able to report
beneficiaries who received notification
until July 1, 2017, noting that it will
take time for participants to develop and
build information technology programs
to retrieve the names of beneficiaries
who have received a beneficiary
notification, including the date
received, for any period of time that
CMS may request.
Other commenters urged CMS to be
responsible for providing the detailed
beneficiary notification to alleviate the
administrative burden on EPM
participants. Furthermore, because
participation in the EPMs is required in
the selected geographic regions, some
commenters suggested that CMS be
responsible for providing the
beneficiary notification for this reason
as well. The commenters speculated
CMS could provide the beneficiary
notifications via the annual ‘‘Medicare &
You’’ handbook that is mailed to all
Medicare beneficiaries by adding an
insert with the mailing clearly notifying
the beneficiary of the Innovation Center
models being tested in their MSA and
describing how those models may
impact beneficiaries who are admitted
to a hospital with certain conditions or
have certain procedures.
Response: We believe that providing
full notification and disclosure of the
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EPMs or CJR model and the possible
implications for beneficiaries’ access to
care is essential to ensuring that
beneficiaries understand the EPMs or
CJR model, are protected from potential
harm under the EPMs or CJR model, and
maintain freedom of choice of providers
and suppliers, as well as services,
throughout EPM or CJR episodes. We
previously finalized detailed beneficiary
notification requirements for the CJR
model in the CJR Final Rule (80 FR
73516 through 73521). We believe it is
essential that this notification be
specific to beneficiaries whose care is
actually included in the EPMs or CJR
model and provided in close proximity
(or during) the EPM or CJR episode so
it is meaningful to the beneficiary while
he or she is receiving recommendations
for care during the EPM or CJR episode.
In addition, we believe that all
beneficiaries whose care is included in
an EPM or CJR episode should be
provided with detailed information
about the model, not just those
beneficiaries who request such
information. It is not possible for CMS
to target notification to the specific
Medicare beneficiaries who initiate an
EPM or CJR episode; instead, the entity
with the best, most timely information
on a beneficiary’s status is the EPM
participant or CJR hospital participant
because the beneficiary’s EPM or CJR
episode initiates at the EPM participant
or CJR hospital participant.
Like the CJR model, the EPMs
incorporate financial incentives for
reducing the cost of care for all related
items and services furnished to EPM
beneficiaries during the anchor
hospitalization and the 90 days posthospital discharge. This payment
methodology creates the potential for
the unintended consequences of
reduced access to care or care stinting
that are not present under the IPPS,
which provides a single payment to the
hospital for a hospitalization, without
regard to payments for Part B services
during the inpatient hospitalization or
payment for any Part A or Part B items
or services furnished after hospital
discharge. Thus, while such notification
is not required under the IPPS, we
believe the EPM detailed beneficiary
notification requirement encourages
care recommendations that are based on
the clinical needs of beneficiaries and
not on inappropriate cost savings.
Moreover, we note that all existing
Medicare beneficiary protections
continue to be available to the EPM
beneficiary. These include the ability to
report concerns of substandard care to
the 1–800–MEDICARE helpline and the
QIOs, where staff will be trained to
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assist EPM beneficiaries with any
concerns they may have about their care
under the EPMs.
While we understand that this
detailed notification requirement places
some additional burden on EPM
participants and CJR hospital
participants, we believe the value of the
notification in protecting beneficiaries
from harm and maintaining beneficiary
freedom of choice outweighs this
burden, given the potential for
beneficiary steering and care stinting
that may result from the financial
incentives under the EPM or CJR model.
Based on their early implementation
experience with the CJR model, CJR
hospital participants already have
significant experience with similar
detailed notification requirements to
those we proposed for the EPMs and
CJR model. We further note that EPM
participants have experience with
required notification of beneficiary
rights and obligations upon hospital
admission, and we expect EPM
participants will draw upon this
experience in operationalizing the
beneficiary notification requirement for
the EPMs. We encourage EPM
participants to notify all beneficiaries
under circumstances where it is likely
that the beneficiary’s care will be
included in the EPM, even if the EPM
participant may be unable to be certain,
in view of the rules around model
attribution and precedence or the rapid
pace of clinical care, in a timeframe that
would otherwise allow timely
beneficiary notification that meets the
EPM requirements.
In response to those commenters who
specifically objected to the proposed
requirement that EPM participants
provide to CMS upon request the list of
beneficiaries who received notification
and the date of that notification, this
record access and retention requirement
is the same as the requirement for other
records under the EPMs where those
records must be maintained and the
Government provided access to enable
audit, evaluation, inspection, or
investigation as discussed in section
III.H. of this final rule. Given the
importance of beneficiary notification as
a beneficiary safeguard under the EPMs,
we must be able to monitor the
sufficiency of such notifications.
Additionally, regarding the request of
one commenter that we delay
implementing the proposed requirement
that CJR hospital participants be able to
provide information on beneficiaries
notified upon request by CMS, as
discussed in section V.H. of this final
rule, the effective date of the full
amended beneficiary notification
regulations in § 510.405 for the CJR
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model is July 1, 2017, which is
consistent with the commenter’s request
for the delayed timing of the effective
date of this requirement.
Comment: Several commenters
provided their perspectives on CMS’
proposal for the contents and timing of
the detailed beneficiary notification.
The commenters urged CMS to adopt
the proposed detailed notification
elements, including a detailed
explanation of the EPM and how it
might be expected to affect the
beneficiary’s care; notification that the
beneficiary retains freedom of choice to
choose providers and services;
explanation of how patients can access
care records and claims data; a
statement about all existing Medicare
beneficiary protections that continue to
be available to the beneficiary; and a list
of the providers and suppliers with
whom the beneficiary has a sharing
arrangement. One commenter suggested
that the notification should highlight
that participation in an EPM is intended
to improve quality and reduce waste,
rather than focus on notifying
beneficiaries of sharing arrangements.
Several commenters stated that while
patients should be informed that they
are receiving care from a hospital that is
required to participate in the EPM,
beneficiaries should not be given reason
to be unnecessarily worried about the
quality of care they will receive.
Some commenters suggested that the
beneficiary notification be provided
prior to admission for an anchor
hospitalization. One commenter stated
that notification at the point of
admission for LEJR under the CJR model
was too late because it would not occur
at a time when beneficiaries could
process and act on the information.
Several commenters on the CJR model
proposal for the detailed beneficiary
notification recommended that the
delivery of the notification to a
beneficiary occur before admission to an
anchor hospitalization, stating that
notification could be provided by the
admitting physician regardless of his or
her participation in the CJR model as a
collaborator or, alternatively, the CJR
participant hospital could convey the
notification prior to admission once the
surgery is scheduled. Another
commenter requested that CMS allow
the beneficiary notification to be given
at any time during a CJR episode,
arguing that requiring providers to
furnish beneficiary notifications prior to
admission for surgery under the CJR
model leads to additional administrative
burden on providers.
Other commenters were concerned
that given the emergent nature of some
EPM episodes, notice may not always be
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able to be provided upon admission
since MS–DRGs are not assigned to
beneficiaries until the claim is coded
and submitted for payment following
the beneficiary’s discharge from the
hospital. One commenter urged CMS to
work with the provider community to
identify exceptions where delivering a
notification is not possible prior to
discharge and create an exception to the
detailed beneficiary notification
requirement in these cases. The
commenter provided the example of
instances where patients are admitted
and then subsequently transferred to
another facility for a higher level of care,
claiming that in this scenario there may
not be time to provide the notification.
As a result, the commenter believes that
EPM participants may be penalized due
to a clinical situation that is beyond
their control.
Response: We appreciate the
commenters’ support for the proposed
elements of the detailed beneficiary
notification. We do not believe that
providing detailed notification to a
beneficiary that his or her care is
included in an EPM in a format that
presents the proposed elements should
lead to undue beneficiary concerns
about the quality of their care,
especially given the beneficiary
safeguards that are being adopted for the
EPMs. Given the importance of
transparency of financial arrangements
under the EPMs that have the potential
to influence care recommendations for
EPM beneficiaries, we disagree with the
commenter that providing information
on sharing arrangements in the EPM
participant’s detailed notification to the
beneficiary is unnecessary.
We have further considered the
timing of the required detailed
beneficiary notification in view of the
public comments. For the EPMs, we
proposed that the EPM participant must
provide notification upon admission to
the hospital or immediately following
the decision to schedule a procedure or
provide a service which would result in
a patient being discharged under a
covered episode. The proposed EPM
regulation text specified that where, due
to the patient’s condition, it may not be
feasible to provide notification at such
times, the notification must be provided
to the beneficiary or his or her
representative as soon as is reasonably
practicable but no later than discharge
from the hospital accountable for the
episode. We believe this timing is
generally appropriate and provides EPM
participants and, similarly, CJR hospital
participants with necessary flexibility
regarding the timing of the detailed
notification for beneficiaries with the
clinical conditions that are the focus of
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419
EPM or CJR episodes. We disagree with
the commenter who suggested that
beneficiary notification could be
provided any time during a CJR episode
because it is important that beneficiaries
be advised as early as possible in an
episode (if not before the episode
begins) that their care is included in an
EPM or CJR episode, in order to
safeguard beneficiary freedom of choice
of providers and services and ensure the
beneficiary’s understanding of how the
model might be expected to affect the
beneficiary’s care.
We believe that the earliest point in
time that the detailed beneficiary
notification could be provided by the
EPM participant or CJR hospital
participant is when the admission is
scheduled in advance with the EPM
participant or CJR hospital participant,
consistent with the request of some
commenters that the notification be
provided prior to hospital admission for
the anchor hospitalization. However,
under the EPMs many admissions will
be unscheduled due to the clinical
conditions that are the focus of the
models and in those circumstances,
beneficiary notification must be
provided upon admission or as soon as
is reasonably practicable but no later
than discharge from the EPM participant
accountable for the EPM episode.
Similarly, while we believe that the
detailed beneficiary notification under
the CJR model should be provided by
the CJR hospital participant that CMS
holds financially responsible for the CJR
episode rather than the admitting
physician, the earliest point in time that
this notification could be provided is
when the admission is scheduled in
advance with the CJR hospital
participant, consistent with the
alternative suggested by one commenter
as an alternative to admitting physician
notification of the model. This timing
will allow beneficiaries with scheduled
admissions to process and act on the
beneficiary notification prior to the
beneficiary’s admission to the hospital,
although this notification timing is not
possible for those admissions that are
not scheduled in advance with the CJR
hospital participant.
We note that in view of our final AMI
transfer policy as discussed in section
III.C.4.a.(5) of this final rule which
cancels the AMI episode initiated at the
initial treating hospital when the
beneficiary is transferred to another
hospital for care, the timing of
notification issues raised by the
commenter who urged CMS to allow for
exceptions should no longer pose a
concern. All beneficiaries in the AMI
model will be discharged from the acute
care hospital responsible for the AMI
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episode so we do not believe exceptions
to the detailed notification requirement
are necessary. We expect that EPM
participants will generally be able to
identify EPM beneficiaries upon
admission given the clinical conditions
that are the focus of the EPMs.
Moreover, in the case of any uncertainly
about the MS–DRG that will ultimately
be assigned to the beneficiary’s claim,
we encourage EPM participants to
provide notification to those
beneficiaries whose care may be
included in the EPM so that the
notification requirement is met in the
event the beneficiary’s care is ultimately
included in the EPM.
Given that the EPM participant is
required to provide the detailed
notification, in our final regulations we
are clarifying the requirements for the
timing of the notification to be more
specific based on whether or not the
admission is scheduled in advance with
the EPM participant. We note that
scheduled admissions are especially
relevant to CABG episodes and
unscheduled admissions are relevant to
AMI, CABG, and SHFFT episodes. If the
admission is scheduled in advance, then
the EPM participant must provide
notice as soon as the admission is
scheduled. The notification must be
provided upon admission to the EPM
participant if the admission that
initiates the EPM episode is not
scheduled with the EPM participant in
advance. We believe this timing is
appropriate because hospitals provide
other information concerning patient
rights and responsibilities upon
admission to the hospital. In either case,
in circumstances where, due to the
patient’s condition, it is not feasible to
provide notification at such times, the
notification must be provided to the
beneficiary or his or her representative
as soon as is reasonably practicable but
no later than discharge from the EPM
participant accountable for the EPM
episode.
We are also clarifying in
§ 512.450(b)(1)(v) that the disclosure of
the EPM participant’s sharing
arrangements as part of the detailed
beneficiary notification may be satisfied
if the EPM participant provides a web
address where beneficiaries may access
the list of providers, suppliers, and
ACOs with whom the EPM participant
has a sharing arrangement. Section
512.500(d)(1)(ii)(A), as we are finalizing
it in this final rule, requires the EPM
participant to publicly post (and update
on at least a quarterly basis) on a Web
page on the EPM participant’s Web site
accurate current and historical lists of
all EPM collaborators. We expect that
allowing the detailed beneficiary
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notification to reference the Web site for
the list of providers, suppliers, and
ACOs with sharing arrangements will
reduce the burden on EPM participants
to prepare and keep current this element
of the notification.
We are finalizing the elements of the
detailed beneficiary notification in
§ 512.450(b)(1), specifically a detailed
explanation of the EPM and how it
might be expected to affect the
beneficiary’s care; notification that the
beneficiary retains freedom of choice to
choose providers and services;
explanation of how patients can access
care records and claims data through an
available patient portal, and how they
can share access to their Blue Button®
electronic health information with
caregivers; a statement that all existing
Medicare beneficiary protections
continue to be available to the
beneficiary, including the ability to
report concerns of substandard care to
Quality Improvement Organizations or
the 1–800–MEDICARE helpline; and a
list of the providers, suppliers, and
ACOs with whom the EPM participant
has a sharing arrangement, which may
be fulfilled by the EPM participant
including in the detailed notification a
web address where beneficiaries may
access the list.
Comment: A few commenters
expressed support for the proposed
requirement that EPM participants and
EPM collaborators disclose their
financial relationships and interests to
patients in the context of the structure
of the EPM. Other commenters stated
that the multiple beneficiary notices
required under CMS’ proposal would
create an overload for EPM and CJR
beneficiaries, result in administrative
burden on providers, and be infeasible
in some cases unless the EPM
participant or CJR participant hospital
administers the notice on behalf of
physicians. They also questioned the
rationale for the differences in the
proposed timing for such notices by
different collaborators that resulted in a
lack of uniformity, ranging from the
time the decision to undergo a
procedure or service covered under an
EPM is made and no later than
discharge from the hospital accountable
for the episode to when the beneficiary
first receives services from a provider or
supplier associated with the party with
the sharing arrangement. One
commenter pointed out that CMS’
proposal that a physician who is an
EPM collaborator notify the beneficiary
of his or her sharing arrangement at the
time that the decision to undergo a
procedure or service covered under the
EPM is made and no later than
discharge from the hospital accountable
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for the episode makes providing timely
notice impossible for an EPM
collaborator who is a physician who
does not furnish a service to the
beneficiary until after hospital
discharge. The commenter requested
clarification about whether such a
physician would need to provide notice
to the beneficiary of the sharing
arrangement and, if so, the timing of
such notice. Another commenter
asserted that it would be unlikely that
certain providers with a sharing
arrangement under the CJR model
would practically be able to collect
administrative documentation from the
beneficiary about the notice in the
course of clinical care, such as in the
case of an independent hospitalist who
only sees patients while they are
admitted to the CJR participant hospital
or an anesthesiologist who is working
on improving operating room efficiency.
Several commenters recommended
that beneficiary notices should only be
provided once by the EPM participant
or CJR hospital participant and should
provide information on all individuals
and entities with sharing arrangements
under the EPM or CJR model. The
commenters asserted that this approach
to notices would make the beneficiary
aware of all the individuals and entities
with a sharing arrangement with the
EPM participant or CJR hospital
participant, without overwhelming the
patient every time he or she sees a
clinician or goes to a facility for care.
One commenter who opposed the
collaborator notice requirement
requested that CMS provide specific
examples of when various EPM
collaborators would need to provide
notice if the policy is adopted. The
commenter described the example of an
ACO that has a sharing arrangement
with a CABG model participant, and
both an independent group of
cardiothoracic surgeons and an
independent group of primary care
physicians are ACO participants who
also have sharing arrangements with the
same CABG model participant. If the
notice requirement is finalized, the
commenter requested that CMS clarify
the notice requirements for the ACO and
both physician groups with respect to a
CABG beneficiary who receives
included services from physicians in
both groups during the CABG episode.
Response: We appreciate the support
of the commenters for disclosure to EPM
beneficiaries of EPM financial
relationships between the EPM
participant and other providers,
suppliers, and ACOs. We agree that a
single notice by the EPM participant to
the EPM beneficiary of all individuals
and entities with sharing arrangements
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under the EPM is important to provide
disclosure of these financial
arrangements that could potentially
influence the recommendations of the
EPM beneficiary’s treating providers
and suppliers and, therefore, we are
finalizing this requirement as part of the
detailed beneficiary notification
discussed previously. However, we
believe it is necessary also to provide
the EPM beneficiary with such
information again at the time and in the
context where the beneficiary can best
use that information to evaluate the
advice he or she is receiving from health
care providers and suppliers based on
the beneficiary’s specific knowledge of
any financial interests of those
providers and suppliers that could
influence their recommendations. By
providing additional notice of sharing
arrangements specific to the care the
beneficiary is receiving from the EPM
collaborator and providing this notice in
close proximity to when that care is
being furnished during the EPM
episode, the beneficiary will be better
able to assess the recommendations
from that individual or entity.
We have further considered the issues
raised by the commenters about the
potential for multiple notices to
beneficiaries and the inconsistency of
the proposed notice provisions for
different types of EPM or CJR
collaborators that would have had
different timing during the EPM or CJR
episode and might, therefore, have been
difficult for EPM or CJR collaborators to
comply with or been confusing to
providers and suppliers treating EPM or
CJR beneficiaries. We proposed different
timelines for some of the required EPM
notices, ranging from the time the
decision to undergo a procedure or
service covered under an EPM is made
to the time when the beneficiary first
receives a service from the entity or its
related providers and suppliers that
treat beneficiaries. We acknowledge that
our timing proposal for collaborating
physician, nonphysician practitioner,
PGP, and hospital notice of sharing
arrangements was a practical
impossibility for these types of EPM
collaborators if the individual or entity
did not furnish a service to the EPM
beneficiary prior to discharge from the
hospital accountable for the EPM
episode. Moreover, while our EPM
proposal for ACO notices was intended
to refer broadly to ACOs, the specific
proposed regulation text regarding the
timing appeared to narrow the notice
scope to only those ACO providers/
suppliers that are PGPs with
distribution arrangements, resulting in
lack of uniformity for ACO notices.
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Additionally, while we proposed that
physicians, nonphysician practitioners,
PGPs, post-acute care providers and
suppliers, hospitals, and ACOs with
sharing arrangements would be required
to provide written notice to EPM
beneficiaries of the structure of the EPM
and the existence of the individual’s or
entity’s sharing arrangement with the
EPM participant, we did not address
collaborator notice by providers or
suppliers of outpatient therapy services
or CAHs that we also proposed be
eligible to be EPM collaborators.
We continue to believe that it is an
important beneficiary safeguard to
provide EPM and CJR beneficiaries with
separate, specific notice of each sharing
arrangement that has the potential to
influence a provider’s or supplier’s care
recommendations, even if that results in
the beneficiary receiving multiple
notices during an EPM or CJR episode.
This rationale is applicable to all EPM
and CJR collaborators. We also continue
to believe that it is not feasible or
necessary to require those individuals
and entities with distribution
arrangements and downstream
distribution arrangements under the
EPM or CJR model to provide notice to
EPM or CJR beneficiaries. These other
arrangements are not entered into
directly with the EPM participant or CJR
hospital participant and, therefore, they
may not have the same potential for
affecting clinical decisions.
Furthermore, to require an additional
notice from each of these parties could
greatly increase the number of separate
notices to EPM or CJR beneficiaries,
potentially resulting in information
overload and confusion that do not
contribute to improved EPM or CJR
beneficiary understanding and greater
safeguards.
However, in response to concerns
raised by the commenters about the
uniformity and feasibility of the EPM
collaborator notice requirements we
proposed, we also are streamlining the
EPM collaborator notice requirements.
Specifically, we are adopting
requirements for the provision of notice
that are more equitable and consistent
across all the individuals and entities
with sharing arrangements under the
EPM, as those individuals and entities
are finalized in section III.I. of this final
rule, with a notice timeframe that is
appropriate and practical for EPM
collaborators. We believe our revisions
clarify which parties are responsible for
providing beneficiary notice of sharing
arrangements and when such notice
must be provided, and will minimize
any confusion among providers and
suppliers treating EPM beneficiaries. In
our final beneficiary notice
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421
requirements discussed later in this
section, we distinguish among EPM
collaborators that are individual
providers or suppliers that furnish items
and services directly to EPM
beneficiaries, and those EPM
collaborators that do not directly furnish
items and services to EPM beneficiaries,
namely PGPs, nonphysician practitioner
group practices (NPPGPs), therapy
group practices (TGPs), and ACOs.
First, an EPM participant must require
every EPM collaborator that furnishes
an item or service to an EPM beneficiary
during an EPM episode to provide
written notice to the beneficiary of the
structure of the EPM and the existence
of the individual’s or entity’s sharing
arrangement. The notice must be
provided no later than the time at which
the beneficiary first receives an item or
service from the EPM collaborator
during an EPM episode. In
circumstances where, due to the
patient’s condition, it is not feasible to
provide notice at such times, the notice
must be provided to the beneficiary or
his or her representative as soon as is
reasonably practicable. The EPM
collaborator must be able to generate a
list of all beneficiaries who received
such a notice, including the date on
which the notice was provided to the
beneficiary, to CMS upon request. We
believe this notice requirement is
feasible for all EPM collaborators that
furnish items and services to EPM
beneficiaries (that is, EPM collaborators
other than ACOs, PGPs, NPPGPs, or
TGPs) at any point in the EPM episode,
including the circumstances raised by
the commenter of an independent
hospitalist with a sharing arrangement
that only sees patients while they are
admitted to the model participant or an
anesthesiologist who has a sharing
arrangement related to improving
operating room efficiency. In the case of
both of these physicians, the EPM
participant must require the physician
to provide written notice to the
beneficiary of the structure of the EPM
and the existence of the physician’s
sharing arrangement when the
beneficiary first receives an item or
service from the physician during an
EPM episode. If the physician with a
sharing arrangement does not provide
an item or service to the beneficiary
during an EPM episode, no notice is
required. However, we point out that
ultimately to be eligible to receive a
gainsharing payment for an EPM
performance year, the physician who is
an EPM collaborator must have directly
furnished a billable item or service to an
EPM beneficiary during an EPM episode
that occurred during the performance
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year for which the EPM participant
accrued the internal cost savings or
earned the reconciliation payment that
comprises the gainsharing payment
according to the requirement in
§ 512.500(c)(2)(ii).
Second, an EPM participant must
require every EPM collaborator that is a
PGP, NPPGP, or TGP where a member
of the PGP, member of the NPPGP, or
member of the TGP furnishes an item or
service to an EPM beneficiary during an
EPM episode to provide written notice
to the beneficiary of the structure of the
EPM and the existence of the entity’s
sharing arrangement. The notice must
be provided no later than the time at
which the beneficiary first receives an
item or service from any member of the
PGP, member of the NPPGP, or member
of the TGP and the required notice may
be provided by that member. The PGP,
NPPGP, or TGP must be able to generate
a list of all beneficiaries who received
such a notice, including the date on
which the notice was provided to the
beneficiary, to CMS upon request. The
required notice for a PGP, NPPGP, or
TGP with a sharing arrangement need
only be provided once to a beneficiary
during an EPM episode. Different
members of the same group who furnish
items or services to the same beneficiary
later in the EPM episode do not need to
also provide notice.
Third, an EPM participant must
require an EPM collaborator that is an
ACO where an ACO participant bills for
or ACO provider/supplier furnishes an
item or service to an EPM beneficiary
during an EPM episode to provide
written notice to the beneficiary of the
structure of the EPM and the existence
of the entity’s sharing arrangement. The
notice must be provided no later than
the time at which the beneficiary first
receives an item or service from any
ACO participant or ACO provider/
supplier and the required notice may be
provided by that ACO participant or
ACO provider/supplier. The ACO must
be able to generate a list of all
beneficiaries who received such a
notice, including the date on which the
notice was provided to the beneficiary,
to CMS upon request. The required
notice for an ACO with a sharing
arrangement need only be provided
once to a beneficiary during an EPM
episode. Different ACO participants or
ACO providers/suppliers that furnish
items or services to the same beneficiary
later in the EPM episode do not need to
also provide notice. We note that in the
case of an ACO participant that is a
group practice that bills for but does not
itself directly furnish the first item or
service to an EPM beneficiary from any
ACO participant or ACO provider/
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supplier during an EPM episode, ‘‘the
time at which the beneficiary first
receives an item or service from any
ACO participant’’ means the time when
the beneficiary first receives an item or
service that is billed by the ACO
participant and furnished by a group
practice member. In these
circumstances, the required ACO notice
may be provided by that group practice
member.
These final notice provisions set forth
a consistent framework for beneficiary
notice of sharing arrangements that can
be applied to all EPM collaborators,
with additional details about the notice
for those entities that can be EPM
collaborators but that do not themselves
directly furnish items and services to
EPM beneficiaries. While a beneficiary
may receive multiple notices of sharing
arrangements during one EPM episode,
we only require that each individual or
entity that is an EPM collaborator
provide notice once during the episode,
including those circumstances where an
EPM beneficiary receives items or
services during an EPM episode from
more than one member of the PGP,
member of the NPPGP, or member of the
TGP with a sharing arrangement or more
than one ACO participant or ACO
provider/supplier in an ACO with a
sharing arrangement.
We believe this comprehensive
framework clarifies the notice
requirements for all EPM collaborators,
and that it is feasible for EPM
participants to require their EPM
collaborators to provide notices that
meet the requirements. However, we
also appreciate that developing and
coordinating the notice processes to fit
within the course of clinical care,
especially for those collaborators that
never themselves directly furnish items
and service to EPM beneficiaries, will
require effort that is related to the
number and complexity of the EPM
participant’s sharing arrangements, the
technological capacity of its
collaborators to document and retain
notices, the care patterns for EPM
beneficiaries for which a particular EPM
participant is responsible, and other
issues. Nevertheless, as discussed
previously, we believe that individual
notice of sharing arrangements by each
EPM collaborator to EPM beneficiaries
is necessary, and we expect that the
streamlined structure we are finalizing
for these notices minimizes, to the
extent possible, any additional burden
on EPM participants and their related
collaborators.
For purposes of illustration, we will
step through the application of these
provisions to the commenter’s example
of an ACO that has a sharing
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arrangement with a CABG model
participant and both an independent
group of cardiothoracic surgeons and an
independent group of primary care
physicians who are ACO participants
who also have sharing arrangements
with the same participating hospital. We
note that this example results in a
complex notice pattern that is highly
unlikely to occur in practice, because
we expect that in general the ACO
would contract with the CABG model
participant and then enter into
distribution arrangements with its ACO
participants, in this case the group of
cardiothoracic surgeons and the group
of primary care physicians, rather than
all three entities contracting
individually with the CABG model
participant. In the example, both
physician groups furnish included
services to a CABG beneficiary during a
CABG episode. We further assume that
a member of the cardiothoracic surgery
group furnishes a service to a CABG
beneficiary during a CABG episode
before a member of the primary care
physician group. In this scenario, when
the cardiothoracic surgeon furnishes the
first service to the CABG beneficiary
that is billed by the cardiothoracic
surgery group, that surgeon is required
to provide notice to the CABG
beneficiary about the sharing
arrangement of the group of
cardiothoracic surgeons and the sharing
arrangement of the ACO with the CABG
model participant. When the primary
care physician later in the CABG
episode furnishes the first service to the
CABG beneficiary that is billed by the
primary care physician group, the
primary care physician is required to
provide notice to the CABG beneficiary
about the sharing arrangement of the
group of primary care physicians with
the CABG model participant. The
beneficiary has already been notified
about the ACO’s sharing arrangement.
Comment: Several commenters urged
CMS to allow the required beneficiary
notifications and notices by any
individual or entity to be permitted on
an electronic basis, with proof of receipt
by the EPM beneficiary, rather than
through a paper process that requires a
beneficiary’s signature.
Response: We did not propose a
written signature requirement in
regulation. We agree that electronic
health records may be used to maintain
documentary evidence of written
communications, and we have not
specified a specific mechanism by
which proof of beneficiary notification
must be maintained.
Comment: Several commenters
expressed support for CMS’ proposal
that notification materials be developed
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or approved by CMS, because the
commenters believe that allowing
hospitals and other providers that stand
to profit from the EPM to describe the
EPM and how it might affect the
beneficiary’s care is unlikely to result in
objective information for consumers.
The commenters requested that CMS
provide samples of beneficiary
notifications to be provided by EPM
participants and samples of notices to
be provided by post-acute care
providers that are EPM collaborators.
One commenter pointed out that there
are cases where the determination of a
procedure, either LEJR or a hip pinning
for fracture, is not made until after the
surgery is in process, so the commenter
urged CMS to consider a combined CJR/
SHFFT notice that will incorporate all
needed elements and reduce confusion
for patients.
Other commenters requested that
CMS make available generic sample
notifications that could apply to all
models in order to reduce confusion for
beneficiaries, hospitals, physicians, and
the general public. The commenters
claimed that a single streamlined
beneficiary notification for all models
would relieve EPM participants of a
large operational burden and ensure that
beneficiaries receive appropriate notice
related to the care they are receiving,
without causing unnecessary confusion.
Several commenters stressed that a
sample notice will achieve a level of
accuracy and consistency that would
not occur with individual notice formats
and contents devised by each EPM
participant.
Response: We appreciate the interest
of the commenters in streamlining the
beneficiary notification materials that
are used for the EPMs, as well as other
models, in order to provide greater
clarity for beneficiaries, providers and
suppliers, and the general public.
However, we do not agree that a single
general notification could apply to all
models, given the elements we are
finalizing for the EPM detailed
beneficiary notification as discussed
previously in this section, which
include an explanation of the EPM and
how it might be expected to affect the
beneficiary’s care. While we agree that
certain beneficiary notification
elements, such as notification that the
beneficiary retains freedom of choice to
choose providers and services, may be
common across many models, other
elements differ. Therefore, we cannot
provide a single generic beneficiary
notification document that applies
across all models. Beneficiaries,
providers and suppliers, and the general
public with an interest in model
notifications need to know about the
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specific model features and how the
model might be expected to affect a
beneficiary’s care.
We also appreciate the commenters’
interest in having CMS develop or
approve the detailed beneficiary
notification about the EPMs in the
interest of transparency and accuracy of
the information for beneficiaries, for
whose benefit the notification is
provided. We prepared a detailed
beneficiary notification template for the
CJR model which is currently used by
CJR participant hospitals, and we
similarly plan to prepare and make
available prior to EPM implementation
a detailed beneficiary notification
template that EPM participants can use.
While we appreciate that a combined
notification template for the CJR and
SHFFT models could be desirable in
some circumstances, for expedience we
recommend that if there is uncertainty
about the hip fracture surgery that will
be performed, the CJR/SHFFT model
participant should provide both detailed
model notifications to the beneficiary
upon unscheduled admission to the
hospital that initiates the episode.
We will also consider the possibility
of preparing notice templates that may
be used for individuals and entities with
sharing arrangements under the EPMs
that are required to provide notice to
EPM beneficiaries. While we are not
certain that a single notice is
appropriate for all individuals and
entities with these arrangements, or
even for a single type of provider or
supplier (such as a physician or SNF)
with a sharing arrangement, we will
continue to explore the option of
making notice templates available to
EPM participants for their related EPM
collaborators to use.
Comment: A number of commenters
provided recommendations about how
CMS should monitor compliance with
the beneficiary detailed notification and
notice requirements. Some commenters
suggested that monitoring could be
carried out by a CMS contractor, such as
a state survey agency or a QIO.
Alternatively, the commenters asserted
that a hospital private accrediting body
could conduct the monitoring. The
commenters recommended that
monitoring should include submission
of any model notice format and content
to the monitoring entity in advance of
its use, certification of assurances of
compliance by EPM participants and
individuals with EPM sharing
arrangements, auditing of compliance
within the first 30 to 60 days of EPM
implementation or implementation of
the revised notification requirements in
the CJR model, and annual auditing of
compliance thereafter. Additionally,
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423
several commenters expressed
concerned regarding the implications
for the EPM participant should an EPM
collaborator fail to provide their
required notice to a beneficiary.
Response: We agree with the
commenters on the importance of
monitoring for the sufficiency of
beneficiary detailed notifications and
notices under the EPMs and CJR model.
We appreciate the specific suggestions
and will take them into consideration in
developing the specific monitoring
strategies for these notifications and
notices as we refine the plans with the
monitoring contractor that is currently
engaged with us in monitoring the CJR
model and the monitoring contractor
that we expect to assist us with
monitoring the EPMs.
Beneficiary notifications and notices
as finalized in § 512.450(b) are
requirements of the EPM and, as such,
CMS may take remedial action if an
EPM participant or one of its related
EPM collaborators, collaboration agents,
or downstream collaboration agents is
noncompliant with the requirements of
the EPM, including on the basis of
failure to provide required beneficiary
notices. As discussed in section III.F. of
this final rule, we require the EPM
participant to assume responsibility for
compliance of all of these parties to
ensure that its activities and those of its
related EPM collaborators, collaboration
agents, and downstream collaboration
agents comply with EPM requirements,
and our compliance tools for instances
of noncompliance apply to EPM
participants. We emphasize that
entering into sharing arrangements is a
choice that EPM participants may make,
and EPM participants also have the
choice as to whom to select as an EPM
collaborator based on selection criteria
developed by the EPM participant
Final Decision: After consideration of
the public comments received, we are
finalizing the proposals in § 512.450(b)
for required beneficiary notifications
under the EPMs, with modification to
streamline both the detailed beneficiary
notification and EPM collaborator notice
requirements, as well as to apply the
EPM collaborator notice requirements to
all individuals and entities with sharing
arrangements under the EPMs. We
emphasize that all information provided
to beneficiaries must be in a form and
manner which is accessible to the
beneficiary, including those
beneficiaries with disabilities and
beneficiaries with limited English
proficiency, consistent with applicable
law and CMS policy. Required
beneficiary notifications are—
• Each EPM participant must provide
written notification to any Medicare
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beneficiary that meets the criteria in
§ 512.240 of his or her inclusion in the
EPM. The notification must be provided
upon admission to the EPM participant
if the admission that initiates the EPM
episode is unscheduled. If the
admission is scheduled, then the EPM
participant must provide notice when
the decision to schedule admission is
made. In circumstances where, due to
the patient’s condition, it is not feasible
to provide notification at such times, the
notification must be provided to the
beneficiary or his or her representative
as soon as is reasonably practicable but
no later than discharge from the EPM
participant accountable for the EPM
episode. The EPM participant must be
able to generate a list of all beneficiaries
receiving such notification including
the date on which the notification was
provided to the beneficiary to CMS
upon request. The beneficiary
notification must contain all of the
following:
++ A detailed explanation of the EPM
and how it might be expected to affect
the beneficiary’s care.
++ Notification that the beneficiary
retains freedom of choice to choose
providers and services.
++ Explanation of how patients can
access care records and claims data
through an available patient portal, and
how they can share access to their Blue
Button® electronic health information
with caregivers.
++ A statement that all existing
Medicare beneficiary protections
continue to be available to the
beneficiary. These include the ability to
report concerns of substandard care to
Quality Improvement Organizations or
the 1–800–MEDICARE helpline.
++ A list of the providers, suppliers,
and ACOs with whom the EPM
participant has a sharing arrangement.
This requirement may be fulfilled by the
EPM participant including in the
detailed notification a web address
where beneficiaries may access the list.
• An EPM participant must require
every EPM collaborator to provide
written notice to applicable EPM
beneficiaries of the structure of the EPM
and the existence of its sharing
arrangement with the EPM participant.
++ Require every EPM collaborator
that furnishes an item or service to an
EPM beneficiary during an EPM episode
to provide written notice to the
beneficiary of the structure of the EPM
and the existence of the individual’s or
entity’s sharing arrangement. The notice
must be provided no later than the time
at which the beneficiary first receives an
item or service from the EPM
collaborator during an EPM episode. In
circumstances where, due to the
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patient’s condition, it is not feasible to
provide notice at such times, the notice
must be provided to the beneficiary or
his or her representative as soon as is
reasonably practicable. The EPM
collaborator must be able to generate a
list of all beneficiaries who received
such a notice, including the date on
which the notice was provided to the
beneficiary, to CMS upon request.
++ Require every EPM collaborator
that is a PGP, NPPGP, or TGP where a
member of the PGP, member of the
NPPGP, or member of the TGP furnishes
an item or service to an EPM beneficiary
during an EPM episode to provide
written notice to the beneficiary of the
structure of the EPM and the existence
of the entity’s sharing arrangement
under the EPM. The notice must be
provided no later than the time at which
the beneficiary first receives an item or
service from any member of the PGP,
member of the NPPGP, or member of the
TGP, and the required notice may be
provided by that member. In
circumstances where, due to the
patient’s condition, it is not feasible to
provide notice at such times, the notice
must be provided to the beneficiary or
his or her representative as soon as is
reasonably practicable. The PGP,
NPPGP, or TGP must be able to generate
a list of all beneficiaries who received
such a notice, including the date on
which the notice was provided to the
beneficiary, to CMS upon request.
++ Require every EPM collaborator
that is an ACO where an ACO
participant bills for or ACO provider/
supplier furnishes an item or service to
an EPM beneficiary during an EPM
episode to provide written notice to the
beneficiary of the structure of the EPM
and the existence of the entity’s sharing
arrangement under the EPM. The notice
must be provided no later than the time
at which the beneficiary first receives an
item or service from any ACO
participant or ACO provider/supplier
and the required notice may be
provided by that ACO participant or
ACO provider/supplier. In
circumstances where, due to the
patient’s condition, it is not feasible to
provide notice at such times, the notice
must be provided to the beneficiary or
his or her representative as soon as is
reasonably practicable. The ACO must
be able to generate a list of all
beneficiaries who received such a
notice, including the date on which the
notice was provided to the beneficiary,
to CMS upon request.
• An EPM participant must provide
the beneficiary with a written notice—
++ Of any potential financial liability
associated with non-covered services
recommended or presented as an option
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as part of discharge planning, no later
than the time that the beneficiary
discusses a particular post-acute care
option or at the time the beneficiary is
discharged, whichever occurs earlier.
++ Of any potential financial
liability, associated with non-covered
services recommended or presented as
an option as part of discharge planning,
no later than the time that the
beneficiary discusses a particular postacute care option or at the time the
beneficiary is discharged, whichever
occurs earlier.
• If the EPM participant knows or
should have known that the beneficiary
is considering or has decided to receive
a non-covered post-acute care service or
other non-covered associated service or
supply, the EPM participant must notify
the beneficiary that the service would
not be covered by Medicare.
• If the EPM participant is
discharging a beneficiary to a SNF prior
to the occurrence of a 3-day hospital
stay, and the beneficiary is being
transferred to or is considering a SNF
that would not qualify under the SNF 3day waiver in § 512.610, the EPM
participant must notify the beneficiary
in accordance with paragraph (b)(3)(i) of
this section that the beneficiary will be
responsible for payment for the services
furnished by the SNF during that stay,
except those services that would be
covered by Medicare Part B during a
non-covered inpatient SNF stay.
• Lists of beneficiaries that receive
notifications or notices must be retained
and access provided to CMS in
accordance with § 512.110.
4. Monitoring for Access to Care
Given that an EPM participant could
receive a reconciliation payment when
the EPM participant reduces average
actual EPM-episode spending below the
quality-adjusted target price and
achieves an acceptable or better level of
quality of care, the EPM participant
could have an incentive to avoid
complex, high-cost cases by not
admitting patients at all or by
transferring patients to nearby facilities
or specialty referral centers that are not
EPM participants. We intend to monitor
the EPM participants’ episode claims
data—for example, to compare each
EPM participant’s case mix relative to a
pre-model historical baseline—to
determine whether complex patients are
being systematically excluded from the
EPM participant’s EPM episodes. We
proposed to publish these data as part
of each EPM’s evaluation to promote
transparency and an understanding of
the EPM’s effects. We also proposed to
continue to review and audit EPM
participants if we have reason to believe
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that they are compromising beneficiary
access to care. For example, we would
review claims data to determine
whether there is an unusual pattern of
referral to regional hospitals located
outside of the EPM participant’s
catchment area or a clinically
unexplained increase or decrease in
CABG or rates of other related surgical
procedures that do not initiate EPM
episodes.
The following is a summary of the
comments received and our responses.
Comment: Many commenters
emphasized that a beneficiary’s access
to the full range of treatment options
appropriate for a given medical
condition is critical for positive health
care outcomes to be achieved under the
proposed EPMs. The commenters
expressed support for CMS’ goals for the
EPMs to encourage EPM participants
and providers and suppliers caring for
EPM beneficiaries to improve access to
care, manage patients to better
outcomes, and achieve improvements in
the efficiency of care.
Several commenters expressed
concern that the financial incentives
under the EPMs will affect both patient
selection and access to the most
appropriate care for the individual
beneficiary, especially because the EPM
pricing methodology does not risk
adjust EPM episode quality-adjusted
target prices for patient demographic
and disease characteristics. The
commenters claimed that frail, elderly,
disabled, sicker, and complex
beneficiaries with multiple
comorbidities who would be more likely
to initiate EPM episodes due to the
generally emergent nature of the clinical
conditions that are the focus of the
EPMs may experience unintended
consequences such as problems with
access to care, substandard quality of
care, and care stinting because these
patients commonly require more
therapeutic interventions, thereby
incurring higher costs, to achieve the
best health outcomes. Specifically, the
commenters speculated that EPM
participants may avoid caring for
beneficiaries likely to be complex, highcost cases by delaying treatment, not
admitting patients at all, or transferring
patients to nearby facilities or referral
centers that are outside of the EPM
participant’s MSA that was selected for
participation in the EPM. A few
commenters expressed particular
concern that small and rural hospitals
that are EPM participants would avoid
admitting frail patients in their home
communities. Another commenter noted
that care coordination for EPM
beneficiaries requires prompt attention
and early, accurate identification of
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beneficiaries. The commenter believes
that in view of the multiple clinical
scenarios and critical nature of the
physical condition of most beneficiaries
in the proposed EPMs, in many
instances the process of identifying
patients as being an EPM beneficiary
will be a secondary concern to the
importance of getting the beneficiary to
the proper level of care regardless of
inclusion or exclusion in an EPM,
which may make patient selection less
likely than in episodes in other models.
Many commenters believe the EPMs
do not include sufficient safeguards to
substantially improve the care
experience for the many and growing
numbers of Medicare beneficiaries.
Some commenters urged CMS to delay
testing the models, particularly the
CABG model, until the benefits of such
models can be proven.
Several commenters encouraged CMS
to closely monitor EPM participants’
claims data for changes in referral and
care patterns to ensure that complex
patients are not being excluded from the
EPMs and for other changes that may
indicate EPM participants are stinting
on necessary and appropriate care.
Some commenters stressed the
particular importance of monitoring for
beneficiary access to care because
beneficiaries cannot opt out of the
EPMs. One commenter recommended
that CMS conduct audits, both
internally and by an outside party, of a
sample of patient medical records to
determine whether the services actually
received by beneficiaries in the
proposed EPMs correspond to existing
standards of care—and whether they
also include innovative treatments and
procedures appropriate for a
beneficiary’s medical condition.
One commenter provided a detailed
crosswalk of potential monitoring
measures in the measure domains of
beneficiary freedom of choice; access,
quality, and cost of care; SHFFT
participants’ coding for hip and femur
fractures and ‘‘upcoding;’’ patient
shifting; and EPM participants’ use of
waivers and compliance with other
rules. The commenter matched potential
monitoring measures in these domains,
such as beneficiary complaints in the
freedom of choice domain, to the source
of information for the measure, which in
this example would be complaints
registered to the 1–800–MEDICARE
helpline and state QIOs. The
commenter’s list of recommended
sources of information for the
monitoring measures was extensive and
specific, including beneficiary surveys;
claims data; patient-reported outcome
data; hospital consumer assessment of
healthcare providers and systems
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425
(hospital CAHPS), home health CAHPS,
and clinician and group CAHPS; claims
data from EPM participants and EPM
collaborators linked to provider of
service and Medicare data on provider
practice and specialty (MD–PPAS) files;
agreements for financial arrangements;
site visits, beneficiary engagement
incentives documentation; financial
records of reconciled payments and
repayments; and claims data linked to
post-acute care provider data sets.
Another commenter requested
clarification about how CMS intends to
monitor EPM participants and EPM
collaborators for compliance other than
through claims review for changes in
utilization patterns. The commenter
asserted that meaningful claims data
required for oversight of the EPMs will
not be available for years after the
models have been implemented. In
addition, the commenter stated that
utilization patterns measure only one
aspect of compliance.
The commenters urged CMS to
strengthen the protections against EPM
participants engaging in cherry-picking
healthier patients and avoiding sick
patients in order to give the appearance
of improved EPM cost and quality
performance. Several commenters also
recommended that beneficiaries in the
models should be informed of the
hotlines available to convey grievances
on care at each level of service during
the episode. Some commenters
supported CMS’ proposal to monitor
compliance and to integrate the QIOs
into the process as an entity available to
handle beneficiary complaints.
Other commenters believe that any
discoveries of problems with access to
care should be publicly reported, and
that EPM participants found to be
participating in these practices should
not be able to receive reconciliation
payments. Another commenter urged
CMS to strengthen the accountability of
EPM participants by implementing a
separate financial penalty for hospitals
found to have deliberately withheld
medically necessary care or steered a
patient toward a health care provider
known to be delivering substandard
care. The commenter suggested that
such a penalty should be sizable enough
to act as a disincentive for hospitals and
other providers that might consider
stinting as potentially profitable.
Response: We appreciate the
commenters’ support for the goals of the
EPM and agree that a beneficiary’s
access to the full range of treatment
options appropriate for a given medical
condition should be maintained. We
believe that the final design of the EPMs
provides sufficient beneficiary
protections that there is no need to
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delay the EPMs and proceeding with
testing beginning on July 1, 2017 as we
proposed, coupled with close
monitoring and the patient safeguards
adopted in this final rule, is the most
appropriate way to move quickly to
gather new insights into the most
effective strategies to improve the
quality and reduce the cost of care
through episode payment.
We also acknowledge that patient
selection and underutilization are both
potential issues related to access to care
due to the financial incentives of the
EPMs. With respect to underutilization,
we agree that it is important to monitor
changes in utilization patterns and case
mix, and to generally monitor whether
barriers to patient access develop in
MSAs where hospitals are required to
participate in the EPMs. We appreciate
the extensive potential monitoring
measures recommended by one
commenter, many of which appear
promising and where information will
be available to operationalize these
measures. We note that the sources of
information for monitoring measures
extend well beyond claims data to
include information on beneficiary
experience and outcomes that cannot be
obtained through claims data. While
there is necessarily some lag in the
availability of claims data due to the
timing of claims submission and
processing, we disagree with the
commenter who suggested it would be
years after EPM implementation before
meaningful claims data for oversight
were available. For example, we will be
analyzing claims data on an ongoing
basis and will be performing the first
reconciliation process 9 months after
model implementation, for which we
expect to have reliable claims data for
EPM episodes during the first
performance year. We will take the
suggestions of monitoring measures
provided by the commenters into
consideration in developing the specific
metrics for monitoring for access to care
as we refine the plans with our
monitoring and evaluation contractors.
We note that further details about these
plans are currently unavailable.
We believe that it is appropriate to
use our existing oversight authority to
monitor the risks of the EPM regarding
access to care, just as we monitor the
various risks inherent in all payment
models and systems, but we do not
believe that new controls are necessary
in regulation, other than those which we
proposed and are finalizing for the
EPMs after consideration of the public
comments. We do not believe that
specific requirements for medical
necessity or review against specific
standards of care are necessary, beyond
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those broad requirements which are set
by the CoPs. We believe that the existing
influences of reputation, care
guidelines, QIO review, Joint
Commission review, quality metrics,
and our EPM monitoring and evaluation
activities are sufficient to ensure that
beneficiary access to care is not
impeded under the EPMs. We further
note that the existing antitrust laws help
to prevent anti-competitive practices in
the maintenance of hospital networks,
thereby allowing competition between
network providers to promote high
quality outcomes.
In response to concerns raised by the
commenters about our EPM pricing
methodology that the commenters
believe heightens the risk of patient
selection or hospital financial harm for
those hospitals disproportionately
caring for complex patients, we are
exploring incorporating risk adjustment
into the EPM payment methodologies by
performance year 3 of the EPMs, as
discussed in section III.D.4.b.(2) of this
final rule. Risk adjustment could
potentially reduce variation in payment
stemming from differences in case mix
rather than the value of care provided,
as well as help minimize the incentive
EPM participants may have to avoid
complex cases under the EPM. We agree
with the commenter that the risk of
patient selection under the EPM may be
reduced due to the generally emergent
nature of the clinical conditions that are
the focus of the EPMs, rather than
elective surgery such as in the CJR
model. However, the potential for
patient selection based on our final
payment policy for transfers of
beneficiaries with AMI from the
outpatient or inpatient setting of an
initial treating hospital to a transfer
hospital as discussed in section
III.C.4.a.(5) of this final rule may be
increased in comparison with our
proposal so we will be monitoring the
treatment patterns of beneficiaries with
AMI closely throughout the model
performance years.
In section III.F. of this final rule, we
describe the reasons that an EPM
participant or its related EPM
collaborator, collaboration agent, or
downstream collaboration may be
noncompliant under the EPM, which
include avoiding potentially high-cost
patients or high-severity patients;
targeting potentially low-cost or lowseverity patients; failing to provide
medically necessary services or
systematically engaging in the over- or
under-delivery of appropriate care;
failing to allow beneficiary choice of
medically necessary options, including
non-surgical options; taking any action
that threatens the health or safety of
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patients; or avoiding at-risk Medicare
beneficiaries. We will make a
determination of EPM participant
noncompliance based on all information
available to us, including the
information from our monitoring
activities regarding access to care,
quality of care, and delayed care as
discussed in this final rule.
We have several compliance tools
available to us for circumstances of
noncompliance, including issuing a
warning letter to the EPM participant;
requiring the EPM participant to
develop a corrective action plan;
reducing or eliminating the EPM
participant’s reconciliation payment;
reducing or eliminating the EPM
participant’s CR incentive payment;
requiring the EPM participant to
terminate a sharing arrangement with an
EPM collaborator and prohibit further
engagement by the EPM participant in
sharing arrangements with the EPM
collaborator; terminating the EPM
participant’s participation in the EPM;
and, when certain circumstances are
met, adding a 25 percent penalty to a
repayment amount on the EPM
participant’s reconciliation report. We
also note that we have the authority to
revoke provider enrollment in the
Medicare program for cause, such as
providing substandard care that places
beneficiaries at risk by under-delivering
care. This broad range of tools provides
us with the flexibility to address
noncompliant EPM participant
behaviors of varying levels of severity,
and provides strong safeguards for
beneficiaries and the Medicare program.
We note that the compliance tools do
not include public reporting of
problems with access to care found for
specific EPM participants because we
do not believe this would be appropriate
for EPM enforcement actions. Instead,
we may notify our federal program
integrity colleagues and, where
appropriate, law enforcement, of such
behavior, particularly in instances in
which HHS (including CMS and OIG)
discovered knowing violations or
patterns of violations of requirements
that directly impacted the safety and
health of patients.
Given the enforcement tools
delineated in this final rule, as well as
the prevalence of existing laws, rules,
and regulations prohibiting care
stinting, provision of substandard care,
or denial of medically necessary care,
we believe that it is unnecessary to
implement processes for a separate
financial penalty specifically for the
EPM as requested by one commenter,
outside of the compliance tools
finalized in section III.F. of this final
rule. Where an EPM participant engages
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in these behaviors, CMS could consider
reducing or eliminating that EPM
participant’s reconciliation payment or
applying a penalty to the repayment
amount, as well as notifying our federal
program integrity colleagues and, where
appropriate, law enforcement, of such
behavior.
Finally, as discussed in section
III.G.3. of this final rule, we require that
detailed beneficiary notification under
the EPMs includes advising EPM
beneficiaries that all standard Medicare
beneficiary protections remain in place.
The EPM beneficiary may voice
concerns or grievances regarding care,
such as to the QIOs or through the 1–
800–MEDICARE helpline.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposals for monitoring
beneficiary access to care, without
modification.
5. Monitoring for Quality of Care
As we noted previously, in any
payment system that promotes
efficiencies of care delivery, there may
be opportunities to direct patients away
from higher cost services at the expense
of better outcomes and higher quality.
However, we believe that
professionalism, the quality measures
proposed for the EPMs, and clinical
standards can be effective in preventing
stinting on medically necessary care in
both the inpatient and post-acute care
settings during the 90 days in the EPM
episode following discharge from the
anchor hospitalization. Accordingly, we
believe that the potential for the denial
of medically necessary care within the
EPMs is not be greater than that which
currently exists under the IPPS.
However, we also believe that we have
the authority and responsibility to audit
EPM participants’ and their EPM
collaborators’ medical records and
claims to verify that beneficiaries
receive medically necessary services,
and we proposed to perform such
auditing activities as we deem
appropriate. We also proposed to
monitor financial arrangements between
EPM participants and their EPM
collaborators to ensure that such
arrangements do not result in the denial
of medically necessary care or other
programmatic or patient abuses. Our
proposals were consistent with the
policies that have been established for
the CJR model.
In the proposed rule, we stated our
belief that the 90-day post-hospital
discharge episode duration is
sufficiently long so as to create financial
accountability for the EPM participant
and to encourage the provision of high
quality care that minimizes the risk of
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complications and readmissions that
typically could occur within such a time
period. Clinical standards of care also
constrain physician patterns of practice,
and we believe that the risk associated
with deviations from those standards
provides further deterrence to
compromising care.
We invited comment on the proposal,
including additional opportunities to
ensure high quality care.
The following is a summary of the
comments received and our responses.
Comment: Several commenters
expressed concern that the EPMs could
negatively affect a beneficiary’s access
to and quality of care based on the
financial incentives under the EPMs.
Some commenters claimed that these
incentives may discourage guidelinebased care and best practices identified
through clinical research. Other
commenters speculated that AMI model
participants may treat an AMI episode
with outpatient observation rather than
admit the beneficiary for medical
management so as to avoid the episode
from being initiated. Similarly, some
commenters claimed that beneficiaries
with AMI who need a PCI would receive
the procedure as an outpatient, also to
avoid the initiation of an AMI episode.
The commenters were concerned with
the potential for such site-of-service
shifting to result in lower quality of care
for AMI beneficiaries treated medically
or with a PCI, especially for those
complex beneficiaries that could result
in high-cost AMI episodes if admitted
for inpatient treatment.
Several commenters identified a
potential risk to quality of care that
could result from changes in the timing
of planned secondary PCIs after AMI
due to the financial incentives in the
AMI model, where AMI episodes
include planned, related care such as
readmissions for PCI and outpatient PCI
without a payment adjustment, except
in the case of a CABG readmission. The
commenters speculated that AMI model
participants will either perform this
secondary PCI during the initial hospital
stay, potentially causing harm to
patients, or intentionally delaying the
procedure until after the episode ends.
The commenters recommended that
CMS monitor and evaluate whether
these shifts in the timing of PCI occur
and whether they affect patient
outcomes.
One commenter claimed that the
performance of SHFFT procedures may
not be sustainable in rural hospitals that
are SHFFT model participants. The
commenter reasoned that rural hospitals
in regions selected for SHFFT model
participation that have, in the past,
provided to their community the service
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427
of local joint replacement and hip
fracture treatment may no longer be able
to sustain this practice given the
financial implications of the proposed
SHFFT model. Other commenters
discussed the unintended consequences
of limited access to care throughout the
5-year duration of the EPMs. One
commenter presented findings from
interviews of SNF staff members at
SNFs that experienced shorter lengthsof-stay in markets with heavy Medicare
Managed Care penetration who reported
having to discharge patients early when
the staff members believed those
patients were unsafe for release.
One commenter outlined in detail
their quality concerns about the
transitions at the beginning and end of
the EPM episode. The commenter
asserted that the required bundling in
the EPMs in the selected geographic
areas would create a new transition in
care, at the end of the 90 days following
hospital discharge, for persons for
whom care transitions are already
problematic. The commenter claimed
that the transition into the
hospitalization for serious conditions
like hip fracture, AMI, and CABG that
are the focus of the EPMs is a disruptive
event. They recommended that the
requirements for the EPMs should
attend to this initial transition at least
with respect to the quality of care
planning and the documentation of the
decision to operate. The commenter
specifically urged CMS to specify that
the merits of the decision to hospitalize
and to monitor or operate must be
documented, both for fracture patients
and for AMI, and that documentation
should show that the risks and expected
benefits had been discussed thoroughly.
In addition, the commenter believes that
at the end of the episode, the patient
would likely lose whatever care
coordination and supplemental benefits
that the hospital and its partners were
providing under the EPM. They pointed
out that this creates another transition,
with the associated risks of inadequate
information transfer, fear and anxiety in
creating and learning another set of care
arrangements, and cessation of
important services. The commenter
reasoned that persons with underlying,
serious chronic conditions will be
unlikely to be stable and doing well at
90 days following hospital discharge;
they will be more likely to be in fragile
health and may be continuing to
decline. Therefore, the commenter
suggested that the EPMs should require
attention to these issues by generating
quality metrics that track real
performance in this transition. The
commenter identified this last transition
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as an opportunity for CMS to tally
utilization and mortality shortly after
the EPM episode ends and also to
generate and use metrics that directly
monitor transition quality.
Response: We agree that the
commenters have accurately described
possible risks of unintended
consequences on care quality as a result
of the financial incentives under the
EPMs; however, we note that similar
risks are inherent in all bundled
payment models and systems. We agree
that monitoring is necessary in order to
further reduce these potential risks. We
believe that professionalism, the quality
measures proposed for the EPMs, and
clinical standards can be effective in
preventing denials of medically
necessary care in both the inpatient and
post-acute care settings during the 90
days post-hospital discharge.
Additionally, we have consistently
found that the traditional authorities
available to the Secretary, including
antitrust laws, anti-kickback provisions
and other existing laws and regulations
under the Medicare program, are
adequate to provide a counterbalance to
the economic incentives that could
drive under-delivery of care. Therefore,
we believe that we can use our existing
oversight authority to monitor the risks
of the EPMs, just as we monitor the
various risks inherent in all payment
models and systems, but we do not
believe that new controls are necessary
in regulation, other than those which we
proposed and are finalizing for the
EPMs after consideration of the public
comments.
We have a number of established
mechanisms by which we will monitor
for evidence of the under-delivery of
care, and by which we can react to and
mitigate any identified problems. We
will be monitoring data in the process
of calculating quality metrics, and we
have several reporting mechanisms,
such as the 1–800–MEDICARE helpline.
We monitor the quality of hospitals
stays and surgical procedures through
the QIOs, we routinely review medical
records in our claims audits, and we
specifically investigate outcomes as part
of our evaluations of new payment and
service delivery models. All of these
processes create opportunities to
identify potentially noncompliant
providers or suppliers. Providers or
suppliers who are investigated and
found to be inappropriately denying
care, diverting patients, providing
unsafe care, or furnishing care in a
setting that does not comply with
Medicare rules may be sanctioned using
our authorities under the Medicare
program as well as those adopted for the
EPMs, with penalties that may include
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EPM participant ineligibility for
reconciliation payments, revocation
from the Medicare program if patients
are placed at risk by substandard care,
or other applicable administrative
actions.
We agree that there are opportunities
to employ additional quality metrics in
the EPMs, including those around care
transitions at the beginning of the EPM
episode and the end of the episode.
However, we note that obstacles exist
not only in defining new measures, but
in implementing mechanisms to report
and assess those metrics without
creating undue administrative burden or
technological challenges for providers.
Therefore, we are not adopting any
additional requirements for these care
transitions under the EPMs.
We believe that there are
opportunities for rural SHFFT model
participants to improve the quality and
efficient of care under the SHFFT model
that are similar to those for hospitals
that are not located in rural areas. Rural
SHFFT model participants have the
same opportunity as other SHFFT
model participants to benefit financially
from improvements in the cost and
quality performance of SHFFT episodes.
In addition, as discussed in section
III.D.7.c.(1) of this final rule, we are
finalizing more protective limitations on
loss for rural hospitals, SCHs, MDHs,
and RRCs in recognition of the
importance of preserving Medicare
beneficiaries’ access to care from these
hospitals. Therefore, we disagree with
the commenter that the financial
implications of the SHFFT model are
likely to make the provision of surgical
hip fracture treatment in rural hospitals
unsustainable.
We agree with the commenters that
monitoring is essential to protect against
practices that may reduce the quality of
post-acute care services. We believe that
monitoring for this quality is best
accomplished at the population level
through monitoring for access to the
appropriate level and quantity of postacute care services. We also believe that
beneficiary knowledge and engagement;
the reliance on the medical direction of
the physician; the monitoring of quality
metrics; the complaint and oversight
opportunities through the 1–800–
MEDICARE helpline and the QIOs; and
the use of care coordination all
cooperate to ensure the quality of
individual services delivered to
individual beneficiaries, including postacute care services, is maintained or
improved under the EPMs.
We note that we will analyze the care
patterns for beneficiaries with AMI who
present to AMI model participants for
treatment, regardless of whether or not
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they are admitted to the hospital for
treatment, treated as an outpatient,
transferred to another hospital for the
initial hospitalization, or transferred
from an inpatient stay at the AMI model
participant to another hospital for an
inpatient hospitalization. Because best
AMI care practices for hospitals with
different cardiac care capacity are not
well-defined, we expect that our
analyses performed as part of
monitoring will help to identify the
effects on care quality and costs of
different patterns in relation to patient
complexity. Not all the beneficiaries we
examine through our monitoring
analyses will actually be included the
AMI model (for example, if the
beneficiary is treated for AMI only as an
outpatient), but we plan to examine the
experiences of all beneficiaries with
AMI who present to an AMI model
participant for treatment so we can
develop the full picture of all care
patterns for this emergent, common
clinical condition. We will also analyze
patterns of planned cardiac care for AMI
beneficiaries for consistency with
clinical guidelines and to examine the
effects of such patterns on beneficiary
outcomes.
Comment: Several commenters
expressed support for CMS’ proposal to
continuously monitor financial
arrangements between EPM participants
and EPM collaborators, as well as
auditing of patients’ medical records
and claims to allow early detection and
intervention in the case of quality
concerns. However, the commenters
requested that the monitoring be
conducted through the analysis of
already submitted documentation, and
not through an additional reporting
requirement.
Response: We appreciate the
commenters’ support for monitoring
financial arrangements and patient
medical records to allow for early
detection of quality concerns, as well as
their concerns over the increased
administrative burden on EPM
participants that could result from these
monitoring activities. We note that we
do not require routine submission of
most information under the EPMs,
including documentation on sharing
arrangements or EPM beneficiary
medical records. However, we proposed
in § 512.110 that EPM participants must
allow the Government access to all
books, contracts, records, documents,
and other evidence sufficient to enable
the audit, evaluation, inspection, or
investigation of several areas, including
the entity’s compliance with EPM
requirements and the quality of services
furnished to an EPM beneficiary during
EPM episodes. We expect that the
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proposed monitoring activities will
require records being made available to
CMS consistent with the access to
records and retention requirements as
discussed in section III.H. of this final
rule. We further note that CMS may also
designate contractors to which these
records will be required to be made
available. We understand the need to
balance our monitoring of financial
arrangements and auditing of EPM
beneficiaries’ medical records and
claims as a safeguard for beneficiary
quality of care with the administrative
burden on EPM participants to make
those records available to us, although
EPM participants are required retain
those records and provide access to
them upon request. Therefore, we will
be judicious in our request that records
be submitted to us to allow for
monitoring, keeping in mind the burden
on EPM participants of record
submission in relation to the value of
those records to provide program
integrity checks and allow early
detection of any quality concerns.
Comment: A few commenters
recommended that CMS develop a plan
to identify where and when
inappropriate reductions in care might
occur. While the commenters
commended CMS for articulating the
potential for such problems to occur
under the EPMs, they urged CMS to
create a clear and specific monitoring
and enforcement plan to ensure
beneficiary choice is protected and to
ensure that consumers receive the most
appropriate care, in the most
appropriate setting, at the right time.
The commenters suggested that CMS
develop training for 1–800–MEDICARE
call center employees to identify and
flag potential care reductions or
inappropriate steering under the EPMs.
They also encouraged CMS to ensure
that the State Health Insurance
Assistance Programs (SHIPs) are
appropriately trained and engaged by
the time the final EPMs are
implemented. Other commenters
suggested the CMS adopt an appeals
mechanism for beneficiaries who
receive poor quality care under the
EPMs.
The commenters further
recommended that CMS consider
establishing an independent
Ombudsman program for the purposes
of monitoring and assisting beneficiaries
in all model tests underway at the
Innovation Center, including the
proposed EPMs. The commenters
reported that Ombudsman programs are
being successfully used in the Financial
Alignment Initiative for MedicareMedicaid Enrollees, as well as to
monitor the Durable Medical Equipment
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Prosthetics, Orthotics and Supplies
(DMEPOS) Competitive Bidding
program authorized by the Medicare
Prescription Drug, Improvement, and
Modernization Act of 2003. The
commenters stated these independent
entities are responsible for monitoring
beneficiary access to care, in addition to
limiting beneficiary confusion and
promoting enhanced understanding.
With an increasing number of delivery
and payment system models ongoing at
the Innovation Center, the commenters
believe a dedicated Ombudsman is
warranted.
The commenters recommended that
beneficiaries be provided information
and data about improved outcomes and
satisfaction seen to date under payment
models. The commenters further believe
that general beneficiary education
programs regarding medical necessity
and beneficiary choice would be
advantageous to supporting providers
and suppliers furnishing services to
EPM beneficiaries. Specifically, one
commenter stated that some post-acute
care providers are not educated or are
continuing to operate with protocols
that encourage overuse of certain types
of care and result in lower quality
health care for Medicare beneficiaries.
An example provided by the commenter
included service patterns where all
patients are treated by the provider for
the maximum number of benefit days,
regardless of clinical or social need. The
commenter explained that in other
circumstances than under the EPMs,
events that create quality concerns may
be a financial benefit to the post-acute
care provider, such as when a patient
who resides in a SNF falls and fractures
his or her hip. The commenter claimed
that upon readmission to the SNF, it is
likely that the SNF will keep the patient
at an acute level of care for 90 days or
even longer, regardless of the original
functional status of the patient.
Finally, one commenter stated that
patients report that some post-acute care
providers are engaging in marketing
efforts that may not accurately portray
beneficiary choice. The commenter
asserted that in their direct experience,
some post-acute care providers establish
mandatory minimum stay requirements
that do not align with physician
discharge orders and show reluctance to
coordinate with the beneficiary’s care
team during the post-acute stay. In this
scenario, the commenter concluded that
there would be little an EPM participant
could do to influence the pattern of care
furnished by such post-acute care
providers if an EPM beneficiary is
treated by a provider that uses such
practices. The commenter requested that
CMS support EPM participants in
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improving the quality and efficiency of
EPM episodes by adopting revised
payment policies for institutional postacute care services that are better
aligned with medical necessity,
including payment for short stays that
include more appropriate types of
therapy that support improved
outcomes and increased quality. The
commenter further recommended that
CMS engage in marketing monitoring
activities in order to support EPM goals.
Response: We thank commenters for
their feedback regarding additional
mechanisms to monitor the quality of
care received by beneficiaries. We will
be developing the specific metrics for
monitoring for the quality of care as we
refine the plans with our monitoring
and evaluation contractors so further
details are currently unavailable. We
appreciate the recommendations of the
commenters on metrics for monitoring
quality of care as a counter to the
financial incentives under the EPMs and
will take them into consideration as we
finalize our plans for monitoring the
effects of the EPMs.
We do not believe that special
beneficiary appeal rights are necessary
under the EPMs. First, there are
numerous processes in place under the
EPMs and the Medicare program to
protect beneficiary choice. The
beneficiary retains all rights to choose
the provider or supplier for medically
necessary covered services. The
beneficiary retains the benefits of the
doctor-patient relationship, with
additional notification of any sharing
arrangement that could create a
potential conflict of interest. In
addition, the beneficiary must be
provided with a notice of non-coverage
for continuing services, such as a
continued stay in an EPM participant or
a SNF, and the beneficiary has access to
the existing expedited review process in
these cases. The beneficiary may also
voice concerns or grievances, such as to
the QIO or through the 1–800–
MEDICARE helpline. We agree that it
would be beneficial to distribute
educational materials to ensure that
beneficiaries can take advantage of the
support available at the 1–800–
MEDICARE helpline, SHIP, and the
QIOs, and we will consider developing
such materials for publication
contemporaneously with the start of the
EPMs. Additionally, 1–800–MEDICARE
helpline staff will be appropriately
trained and have access to relevant
EPM-specific informational materials
that allow them to respond to many
potential beneficiary concerns related to
the EPMs by the time the EPMs are
implemented.
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We further note that we intend to
establish an Alternative Payment
Models Beneficiary Ombudsman within
CMS who will complement the
Medicare Beneficiary Ombudsman in
responding to beneficiary inquiries and
concerns arising from care under the
models addressed in this final rule, as
well as other Innovation Center models,
under the existing Medicare processes.
These existing Medicare beneficiary
inquiry processes include the Quality
Improvement Organizations (QIO) and
the 1–800–MEDICARE helpline that
works with the Medicare Beneficiary
Ombudsman and CMS caseworker staff
to resolve beneficiary issues. We will
ensure that the QIOs, 1–800–MEDICARE
helpline, CMS casework staff and the
Alternative Payment Models Beneficiary
Ombudsman have the information
necessary, as well as access to program
experts, to the extent consistent with
applicable privacy and security laws, to
respond to beneficiary issues prior to
the implementation of the EPMs on July
1, 2017. The 1–800–MEDICARE
helpline staff, QIOs and the Medicare
Beneficiary Ombudsman already have
information and program expert access
for the CJR model, but we will ensure
that those same materials are also made
available to the Alternative Payment
Models Beneficiary Ombudsman and
CMS casework staff, to the extent
consistent with applicable privacy and
security laws.
While we will not revise our payment
policies under the Medicare program for
EPM participants or other providers or
suppliers beyond those discussed in this
final rule, we agree with commenters
regarding the need to continually
improve stakeholder education for
models to succeed and we intend to do
as much as we can to work to design
and deploy a helpful learning and
diffusion program. We currently
facilitate learning within models by
disseminating the lessons learned across
models so that participants can benefit
from the experiences of other models,
and are always looking for better ways
to educate and assist participants and
their partners in care redesign in
knowledge sharing. We continue to
believe that these efforts contribute to
reducing the administrative burden on
the health care delivery system and are
responsive to commenters’ requests that
we address the educational needs of
providers and suppliers caring for EPM
beneficiaries.
We also note that the usual tools
employed by CMS to monitor and
prevent overutilization all apply to the
services, including post-acute care
services, furnished during EPM
episodes. These tools include data
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analysis, the process of tracking patterns
of utilization and trends in the delivery
of care, and medical review, a clinical
audit process by which we verify that
services paid by Medicare were
reasonable and necessary in accordance
with section 1862(a)(1)(A) of the Act.
We believe that these tools as employed
by the MACs and by the QIOs are
sufficient to check for the medical
necessity of EPM services, including
post-acute care services.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposals for monitoring
quality of care, without modification.
6. Monitoring for Delayed Care
We proposed the EPMs in part to
incentivize EPM participants to create
efficiencies in the delivery of care
during a 90-day post-hospital discharge
episode duration following an acute
clinical event. Theoretically, the EPMs
also could create incentives for EPM
participants or their EPM collaborators
to delay services until after the 90-day
post-discharge period has ended.
Consistent with the CJR model, we
believe that existing Medicare
safeguards and other proposals under
the EPMs are sufficient to protect EPM
beneficiaries from harm due to delayed
care.
First, our experience with other
episode-based payment models such as
the BPCI initiative has shown that
providers focus first on appropriate care
and then on efficiencies only as
obtainable in the setting of appropriate
care. We believe that a 90-day postdischarge episode duration is sufficient
to minimize the risk that EPM
participants and their collaborators
would compromise services furnished
in relation to a beneficiary’s care. While
we recognize that ongoing care for
underlying conditions or continued
recovery may be required after the EPM
episode ends, we believe that EPM
participants would be unlikely to
postpone key services beyond a 90-day
post-discharge period because the
consequences of delaying care beyond
the episode duration would be contrary
to usual standards of care.
However, we also proposed that
additional monitoring for delayed care
would occur as a function of the
proposed EPMs. As with the CJR model,
we proposed as part of the EPM
payment policies (81 FR 50876 through
50877) that certain post-episode
payments occurring in the 30-day
window subsequent to the end of the
EPM episode would be counted as an
adjustment against savings achieved by
the EPM participant. We believe that
including such a payment adjustment
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would create an additional deterrent to
delaying care beyond the episode
duration. In addition, the data collection
and calculations used to determine the
adjustment would provide a mechanism
to check whether providers are
inappropriately delaying care. Finally,
we noted in the proposed rule that the
proposed quality measures would create
additional safeguards against delays in
medically necessary care under the
EPMs, as such measures are used to
monitor and influence clinical care at
the institutional level, including for
other CMS hospital programs.
In the proposed rule, we invited
public comment on our proposed
methods for monitoring EPM
participants’ actions and compliance, as
well as on other methods to safeguard
delivery of high quality, clinically
appropriate care.
The following is a summary of the
comments received and our responses.
Comment: Several commenters
acknowledged that a goal of alternative
payment models such as the proposed
EPMs is to reduce unnecessary services
and their associated costs, resulting in
inherent incentives in such models to
potentially delay or reduce medically
necessary care. The commenters
recommended that all alternative
payment models should be designed to
closely monitor health care received and
protect beneficiaries against potential
stinting of clinical treatment, delays in
care, and case mix shifts. They
recommended that CMS continue to
offer regular and structured
opportunities for stakeholder feedback
to ensure that as the number of models
increases, CMS continues to protect
beneficiary access to care and all
clinically appropriate treatment options.
Several commenters expressed
concern that AMI model participants
would delay costly, medically necessary
cardiac care until after the AMI episode
ends, a practice that would be
inconsistent with clinical guidelines.
The commenters identified planned
follow-up inpatient or outpatient PCI of
lesions identified at the time of the AMI
but not responsible for the AMI and
readmissions for cardiac surgery, such
as cardiac valve replacement or
implantable cardioverter defibrillator
implantation, as potential instances
where cardiac care could be delayed
until after the end of an AMI episode.
One commenter requested further
details regarding how CMS intends to
protect beneficiaries from delayed care.
Response: We appreciate the interest
of the commenters in ensuring that the
EPMs and other alternative payment
models are designed to closely monitor
care in order to detect and address any
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delays in care or other potentially
harmful care patterns that could be
incentivized by the financial incentives
under the models. We agree with the
commenters that because the EPM
episodes for which an EPM participant
is responsible extend 90 days postdischarge from the anchor
hospitalization, there is some risk that
care could be delayed until after the end
of the episode. However, we believe that
EPM participants and other providers
and suppliers furnishing services to
EPM beneficiaries will focus first on
clinically appropriate, timely care
consistent with evidence-based clinical
guidelines. We further note that
delaying medically necessary care for
more than 90 days following hospital
discharge could both be contrary to
usual clinical standards of care and
potentially lead to complications that
could result in utilization of health care
services that increases actual EPMepisode spending and endangers the
EPM participant’s episode cost and
quality performance under the EPM.
The potential for costly complications
serves to counter the theoretical
financial benefit that an EPM
participant could experience when care
is intentionally delayed until after the
episode ends.
Moreover, as discussed in section
III.E.3 of this final rule, we use quality
measures of patient outcomes and
patient experience in the pay-forperformance methodologies of the EPMs
where the financial opportunity for EPM
participants to receive savings for any
given level of actual EPM-episode
spending increases with higher quality
of care. Thus, we believe the use of
quality measures in the pay-forperformance methodologies of the EPMs
also serves to deter potentially harmful
delays in care. Finally, as discussed in
section III.D.7.e. of this final rule, EPM
participants with post-episode spending
in the 30 days following the end of EPM
episodes that exceeds a threshold set at
3 standard deviations above average
spending in their region for that period
of time need to repay Medicare for the
amounts in excess of the threshold. This
repayment is not subject to the stop-loss
limitations under the EPMs, resulting in
full risk for EPM participants. Therefore,
we believe this policy also discourages
delays in medically necessary care until
after an EPM episode ends.
We will be developing the specific
metrics for monitoring for delayed care
as we refine the plans with our
monitoring and evaluation contractors
so further details are currently
unavailable. We note that EPM
participants found to engage in delaying
medically necessary care would be
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noncompliant with the EPM under the
provisions finalized in § 512.460(b)(1)
due to actions that threaten the health
or safety of patients. In these
circumstances, CMS could utilize one of
the compliance tools finalized in
§§ 512.460(b)(2) and (b)(3), which
include requiring the EPM participant to
develop a corrective action plan;
reducing or eliminating the EPM
participant’s reconciliation payment;
adding a 25 percent penalty to the
repayment amount on the EPM
participant’s reconciliation report under
certain conditions, or terminating the
EPM participant’s participation in the
EPM. We believe that these compliance
tools allow us to take timely remedial
action for instances of noncompliance
by an EPM participant and that the
finalization of these tools provides a
significant beneficiary safeguard against
delayed care.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposals for monitoring
for delayed care, without modification.
H. Access to EPM Records and Record
Retention
Consistent with the Shared Savings
Program, the BPCI initiative, the CJR
model, and other Innovation Center
models, we proposed specific access to
EPM records and record retention
requirements for individuals and
entities involved with the EPM. For the
CJR model, the record access and
retention requirements were originally
located in Subpart F (Financial
Arrangements and Beneficiary
Incentives). However, we proposed to
include them in Subpart B (Episode
Payment Model Participants) for the
EPM and to move them to Subpart B for
the CJR model as discussed in section
V.L. of this final rule, so that these
requirements can be applied to
categories of information that are
broader than those solely related to
financial arrangements and beneficiary
incentives, as discussed later in this
section.
We proposed that EPM participants,
EPM collaborators, collaboration agents,
downstream collaboration agents, and
any other individuals or entities
performing EPM activities must allow
both scheduled and unscheduled access
to all books, contracts, records,
documents, and other evidence
(including data related to utilization and
payments, quality of care criteria,
billings, lists of EPM collaborators,
sharing arrangements, distribution
arrangements, downstream distribution
arrangements, and the documentation
required under §§ 512.500(d) and
512.525(d)) sufficient to enable the
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431
audit, evaluation, inspection, or
investigation of six categories of
information. We further proposed that
all such books, contracts, records,
documents, and other evidence be
maintained for a period of 10 years from
the last day of the EPM participant’s
participation in the EPM or from the
date of completion of any audit,
evaluation, inspection, or investigation,
whichever is later, unless CMS
determines a particular record or group
of records should be retained for a
longer period and notifies the EPM
participant at least 30 calendar days
before the disposition date; or there has
been a dispute or allegation of fraud or
similar fault against the EPM
participant, EPM collaborator,
collaboration agent, downstream
collaboration agents, or any other
individual or entity performing EPM
activities in which case the records
must be maintained for 6 years from the
date of any resulting final resolution of
the dispute or allegation of fraud or
similar fault.
In the CJR model, we applied these
record access and retention obligations
only to participant hospitals and CJR
collaborators (80 FR 73432 through
73433). However, because we proposed
additional types of EPM collaborators
and types of financial arrangements in
section III.I. of this final rule for the
EPM, as well as defined EPM activities
as those related to promoting
accountability for the quality, cost, and
overall care for EPM beneficiaries, we
proposed to apply the record access and
retention obligations to EPM
participants and all individuals and
entities with EPM financial
arrangements where payments are
substantially based on quality of care
and the provision of EPM activities, as
well as to other individuals and entities
providing EPM activities. While this
proposal is an expansion of the current
record access and retention obligations
under the CJR model to additional
categories of individuals and entities,
we believe the expansion is necessary
and appropriate for the six categories of
information to which we proposed that
the access and retention requirements
would apply. Access to this information
from those individuals and entities
providing EPM activities that are the
basis of care redesign in the EPM
provides an important program
safeguard by allowing monitoring for
compliance with EPM requirements.
The alternative of limiting the
requirements solely to EPM participants
and EPM collaborators as we finalized
for the CJR model would result in no
record access and retention obligation
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for certain individuals and entities that
have financial arrangements under the
EPM and engage in EPM activities,
thereby limiting the Government’s
ability to audit, evaluate, inspect, or
investigate compliance with EPM
requirements. We similarly proposed
changes to the individuals and entities
subject to record access and retention
obligations under the CJR model as
discussed in section V.L. of this final
rule.
We have identified six categories of
information related to key EPM
parameters for which we proposed that
the record access and retention
requirements would apply. Like the CJR
model, we proposed that one category of
information consists of those documents
related to the individual’s or entity’s
compliance with EPM requirements.
Given the individuals and entities who
must comply with the requirements of
the EPM either directly or through their
arrangements, including EPM
participants, EPM collaborators,
collaboration agents, and downstream
collaboration agents, an important
program safeguard is record access and
retention that allow compliance with
the EPM requirements to be monitored
and assessed.
Additionally, similar to the CJR
model, we proposed that a second
category of information consists of
documents related to the calculation,
distribution, receipt, or recoupment of
gainsharing payments, alignment
payments, distribution payments, and
downstream distribution payments.
This list includes all types of payments
proposed under EPM financial
arrangements as discussed in section
III.I. of this final rule and is different
from the current CJR model requirement
to the extent that we proposed
additional types of EPM financial
arrangements in view of our proposal
that ACOs can be EPM collaborators.
Because of the proposed EPM
requirements for these types of
payments that are designed to ensure
that all financial arrangements are for
the sole purpose of aligning the
financial incentives of individuals and
entities with the goals of the EPM
participant to improve the quality and
efficiency of EPM episode care, we
believe that these records of all the
individuals and entities who enter such
arrangements should be accessible and
retained to allow compliance with the
EPM requirements for the payments to
be monitored and assessed. We
proposed similar changes to this
category of information under the CJR
model as discussed in section V.L. of
this final rule.
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The third category of information for
which we proposed to require record
access and retention is related to an
EPM participant’s obligation to repay to
CMS any reconciliation payment or CR
incentive payments owed. The CR
incentive payment has been added to
this provision which otherwise applied
to the CJR model because we proposed
and finalize a CR incentive payment in
section VI. of this final rule for AMI and
CABG model participants in selected
MSAs, while the CJR model does not
include this payment. Requiring record
access and retention about repayment
obligations under the EPM provides an
important program integrity safeguard
for repayments to CMS.
We proposed to require record access
and retention on the quality of the
services furnished to an EPM
beneficiary during an EPM episode as
the fourth category of information.
While the CJR model specified the
quality of services furnished without
further limitation in the record access
and retention requirements, given our
EPM proposals that require gainsharing,
distribution, and downstream
distribution payments to be
substantially based on quality of care
and EPM activities, we believe that it is
appropriate to specify that the record
access and retention requirements apply
specifically to the services furnished to
an EPM beneficiary during an EPM
episode. The quality of services
furnished without further limitation
could result in an overly broad record
access and retention requirement for
services that are delivered outside of
EPM episodes, where these services are
not subject to EPM requirements.
Services furnished to EPM beneficiaries
during EPM episodes are the services for
which we will also be monitoring for
access to care, delayed care, and quality
of care, important activities to safeguard
the program and Medicare beneficiaries,
so access to documents to support this
monitoring is necessary. We proposed
similar changes to this category of
information under the CJR model and
discuss further in section V.L. of this
final rule
Given the beneficiary notification
requirements that we proposed for the
EPM in section III.G. of this final rule,
we proposed to require access to records
and record retention about the
sufficiency of EPM beneficiary
notifications. The beneficiary
notification requirement is an important
beneficiary protection under the EPM,
and the access to records and record
retention requirements provide a
program integrity safeguard to monitor
for compliance with this requirement.
We proposed to add this same category
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of information for the CJR model and
discuss this further in section V.L. of
this final rule.
Finally, we proposed to establish
CEHRT use attestation for EPM
participants so that an EPM participant
could be in a Track 1 EPM that meets
the requirements in the Quality
Payment Program final rule with
comment period (81 FR 77008) to be an
Advanced APM as discussed in section
III.A.2 of this final rule. Thus, we
proposed to require access to records
and record retention about the accuracy
of each Track 1 EPM participant’s
submissions under CEHRT use
requirements. Specifically, attestation to
CEHRT use and submission of clinician
financial arrangements lists are key
requirements for Track 1 EPMs that are
Advanced APMs, and the access to
records and record retention
requirements provide a program
integrity safeguard by allowing us to
assess the completeness and accuracy of
the EPM participant’s compliance with
the requirements for those submissions.
We proposed to add this same category
of information for the CJR model and
discuss this further in section V.L. of
this final rule.
As we stated in the proposed rule, we
believe the proposed requirements
regarding access to EPM records and
record retention are necessary to
safeguard program integrity and protect
against abuse, in view of the EPM
design and requirements as discussed
throughout this final rule that would
lead to achieving the EPM goals of
improved EPM episode quality and
efficiency. We also believe that by
providing access to EPM records, we
promote transparency of activities under
the EPM. Furthermore, as stated in the
proposed rule, we believe the proposed
access to records and record retention
requirements would promote the
compliance of EPM participants, EPM
collaborators, collaboration agents,
downstream collaboration agents, and
any other individuals or entities
providing EPM activities with EPM
requirements by ensuring that
compliance with these requirements can
be monitored and assessed. Finally,
these records may be necessary in the
event that an EPM participant appeals
any matter that is subject to dispute
resolution through CMS. As such, CMS
would have the resources necessary to
prepare and respond to any such appeal.
The proposals for access to records
and record retention are included in
§ 512.110. We sought comment on our
proposals, including whether it is
necessary, reasonable and appropriate to
impose these access and retention
obligations on all of the proposed
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categories of individuals and entities for
all the proposed categories of
information to be retained and made
accessible. In addition, we sought
comment on whether additional or
different safeguards would be needed to
ensure program integrity, protect against
abuse, and ensure that the goals of the
EPM are met.
The following is a summary of the
comments received and our responses.
Comment: One commenter who stated
that the ten year record retention policy
we proposed was excessive requested
that CMS change the proposed duration
of record retention from 10 years to 6
years for the CR incentive payment
model, the EPMs and CJR model. The
commenter believed that the proposed
retention policy is excessive as it
extends well beyond the proposed end
of the fifth performance year of the
EPMs on December 31, 2021 and that a
6-year record retention policy would be
more consistent with other CMS
programs. Another commenter
recommended that CMS also request
access to records on gainsharing and
other savings-related payments so as to
help examine the extent to which
savings are equitably being shared by
facilities with participating physicians
and other healthcare professionals.
Response: While we appreciate the
commenter’s concerns regarding the ten
year retention period, we note that the
proposed ten years is more consistent
with other models, including the CJR.
Furthermore, once an appeal is
initiated, such disputes can be lengthy
processes and we believe that
maintaining this requirement as
proposed at ten years, rather than the 6
years suggested by the commenter,
would give both the participant and
CMS, as well as those completing any
audit, evaluation, inspection, or
investigation, the resources to prepare
and respond to issues that may take
several years to surface. CMS will
consider requesting access to records of
gainsharing payments and other
arrangements that will assist in
evaluating and measuring the EPM goals
of improved EPM episode quality and
efficiency. CMS authority under
§§ 512.110(a)(1) and (2) allows the
Federal Government to sufficiently
access records and we believe this will
contribute to the ability to enable audits,
evaluations, inspections, or
investigations to ensure that payments
are consistent with model goals and are
not abusive.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal without
modification.
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I. Financial Arrangements Under the
EPM
1. Background
In November 2015 we finalized
regulations for financial arrangements
for the CJR model (80 FR 73550 through
73553), an episode payment model that
is similar to the three new proposed
EPMs. In this rulemaking, we proposed
three new episode payments models
that fall under the overarching term
EPM, specifically the AMI model, CABG
model, and SHFFT model. Both the CJR
model and the three proposed EPMs
would place financial responsibility for
the episode on the hospital where the
episode begins with a hospitalization
and would require participation of
hospitals in the selected MSAs for the
models. Like LEJR episodes under the
CJR model, the AMI, CABG, and SHFFT
episodes in the proposed EPMs would
be broadly defined to include most Part
A and Part B services and extend 90
days following discharge from the
hospitalization that initiates the EPM
episode. During the design of the EPMs,
we considered proposing the same CJR
financial arrangements that were
finalized through notice and comment
rulemaking because the proposed EPMs
have a similar design to the CJR model
with the same goals of improving the
quality and efficiency of model
episodes. We expected that the types of
financial arrangements needed to align
the financial incentives of CJR
participant hospitals and EPM
participants with other providers and
suppliers caring for CJR beneficiaries or
EPM beneficiaries during episodes to
improve episode quality and efficiency
would be similar. We also believed that
program integrity safeguards that would
provide protections against abuse under
the financial relationships permitted for
the EPMs should be comparable to those
for the CJR model. However, we
believed that it was possible to improve
on the current regulatory structure for
financial relationships that we
established for the CJR model in our
proposals for the EPM. Our proposals
reflected changes from the current CJR
model regulations that generally fell
into the following four categories:
• Removing duplication of
requirements in similar provisions.
• Streamlining and reorganizing the
provisions for clarity and consistency.
• Providing additional flexibility in
response to feedback from CJR
participant hospitals and other
stakeholders.
• Expanding the scope of financial
arrangements under the EPM.
We note that in section V.J. of the
proposed rule (81 FR 50958 through
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433
50968), we proposed changes to the CJR
model financial arrangements
regulations in Part 510 to parallel those
we proposed for the EPM. These
proposals would result in the same
provisions and requirements for CJR
model and EPM financial arrangements
when the first performance year of the
proposed EPM would begin on July 1,
2017.
2. Overview of EPM Financial
Arrangements
For purposes of this section, the term
‘‘EPM’’ refers to one model specifically
among the proposed AMI model, CABG
model, or SHFFT model and should be
read throughout Subpart F—Financial
Arrangements and Beneficiary
Incentives (§§ 512.500 through 512.525)
of the proposed regulations as a single
one of these three proposed EPMs. For
example, when reading the proposed
regulations for the CABG model,
§ 512.500(b)(6), the provision would
read as, ‘‘The board or other governing
body of the [CABG model] participant
must have responsibility for overseeing
the [CABG model] participant’s
participation in the [CABG model], its
arrangements with [CABG model]
collaborators, its payment of gainsharing
payments, its receipt of alignment
payments, and its use of beneficiary
incentives in the [CABG model].’’ We
used this approach because we meant
for the proposed requirements to apply
to every participant in the EPM
regardless of whether the EPM was the
AMI, CABG, or SHFFT model.
As discussed in section III.D.2.b. of
the proposed rule (81 FR 50844), we
proposed that each EPM would be a
retrospective episode payment model,
under which Medicare payments for
items and services included in an EPM
episode would continue to be made to
all providers and suppliers under the
existing FFS payment systems, and
episode payment would be based on
later reconciliation of actual spending
for an EPM episode under the FFS
payment systems to the EPM episode’s
quality-adjusted target price. If the
actual episode spending was less than
the quality-adjusted target price, the
EPM participant financially responsible
for the EPM episode would receive a
reconciliation payment, assuming the
EPM composite quality score for the
EPM participant was in the
‘‘acceptable,’’ ‘‘good,’’ or ‘‘excellent’’
quality category. If an EPM episode’s
actual spending exceeded the qualityadjusted target price, then, beginning in
performance year 2, the EPM participant
would begin to repay the difference to
Medicare up to the stop-loss threshold.
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Similar to our approach in the CJR
model (80 FR 73412), in the proposed
rule for the EPM we discussed our belief
that EPM participants might wish to
enter into financial arrangements with
providers and suppliers caring for EPM
beneficiaries to share financial risks and
rewards under the EPM, in order to
align the financial incentives of those
providers and suppliers with the EPM
goals of improving the quality and
efficiency of EPM episodes. We further
believed that EPM participants might
wish to enter into financial
arrangements with ACOs that
participate in EPM care redesign and
EPM beneficiary care management and
whose ACO participants and ACO
providers/suppliers care for EPM
beneficiaries. We expected that EPM
participants would identify key
providers and suppliers caring for EPM
beneficiaries, as well as ACOs to which
EPM beneficiaries were aligned, in their
communities and referral regions. The
EPM participants then could establish
close partnerships with these
individuals and entities to promote
accountability for the quality, cost, and
overall care for EPM beneficiaries,
including managing and coordinating
care; encouraging investment in
infrastructure, enabling technologies,
and redesigned care processes for high
quality and efficient service delivery;
the provision of items and services
during an EPM episode in a manner that
reduces costs and improves quality; and
carrying out other obligations or duties
under the EPM. These providers,
suppliers, and ACOs might invest
substantial time and other resources in
these activities, yet they would neither
be the direct recipients of any
reconciliation payments from Medicare,
nor directly responsible for repaying
Medicare for excess episode spending.
Therefore, we believed it would be
possible that an EPM participant that
might receive a reconciliation payment
from Medicare or might need to repay
Medicare might want to enter into
financial arrangements with other
providers, suppliers, or ACOs to share
risks and rewards under the EPM. We
expected that all financial relationships
established between EPM participants
and providers, suppliers, or ACOs for
purposes of the EPM would be those
permitted only under applicable law
and regulations, including the
applicable fraud and abuse laws and all
applicable payment and coverage
requirements.
In addition to providers, suppliers,
and ACOs with which the EPM
participant might want to enter into
financial arrangements to share risks
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and rewards under the proposed EPM,
in the proposed rule we discussed our
expectation that EPM participants might
choose to engage with organizations that
were neither providers nor suppliers to
assist with matters such as episode data
analysis; local provider and supplier
engagement; care redesign planning and
implementation; beneficiary outreach;
beneficiary care coordination and
management; monitoring EPM
participants’ compliance with the EPM’s
terms and conditions; or other EPMrelated activities. Such organizations
might play important roles in an EPM
participant’s plans to implement an
EPM based on the experience these
organizations might bring, such as prior
experience with bundled payment
initiatives; care coordination expertise;
familiarity with a particular local
community; or knowledge of Medicare
claims data. We expected that all
relationships established between EPM
participants and these organizations for
purposes of the EPM would be those
permitted only under existing law and
regulation, including any relationships
that would include the EPM
participant’s sharing of EPM risks and
rewards with such organizations. We
also expected that all of these
relationships would be based solely on
the level of engagement of the
organization’s resources to directly
support the participants’ EPM
implementation.
Finally, because the proposed broadly
defined EPM episodes would extend 90
days post-discharge from their
respective anchor or chained anchor
hospitalizations, similar to the CJR
model (80 FR 73433), in the proposed
rule we discussed our belief that EPM
participants caring for EPM
beneficiaries might want to offer
beneficiary engagement incentives to
encourage adherence to recommended
treatment and active patient engagement
in recovery. Such incentives should be
closely related to the provision of high
quality EPM care and advance a clinical
goal for an EPM beneficiary, and should
not serve as inducements for
beneficiaries to seek care from the EPM
participants or other specific suppliers
and providers. The incentives might
help an EPM participant reach their
quality and efficiency goals for EPM
episodes, while also benefitting
beneficiaries’ health and the Medicare
Trust Fund, if the EPM participant
improved the quality and efficiency of
episodes through care redesign that
resulted in EPM beneficiary reductions
in hospital readmissions, complications,
days in acute care, and mortality, while
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recovery continued uninterrupted or
accelerated.
Comment: Many commenters stressed
the need for waivers of existing fraud
and abuse laws, given CMS’ proposal to
allow financial arrangements between
EPM participants and other individuals
and entities that comply with the
requirements of the proposed rule. They
stated that such waivers are necessary
for aligning the financial incentives of
providers and other entities redesigning
care and coordinating episode care for
EPM beneficiaries to improve episode
quality and efficiency. The commenters
urged CMS and OIG to use the full
scope of their combined authority to
waive certain fraud and abuse laws that
the commenters believed may inhibit
care coordination in order to enable
EPM participants to form the financial
relationships necessary for success in
the models. They claimed that waivers
must be issued no later than
concurrently with publication of the
final rule to allow EPM participants
sufficient time to prepare for EPM
implementation. One commenter
emphasized that the requirement for
hospitals to participate in the EPM
should not take effect unless and until
hospitals have the needed, explicit
protections in place and adequate time
to form the necessary financial
arrangements.
Response: We understand the
commenters’ interest in the timely
publication of fraud and abuse waivers
for the EPM and revised waivers for the
CJR model. As we stated in the
proposed rule (81 FR 50931), any
waivers of the fraud and abuse laws for
the EPM or revisions to the existing CJR
waivers would be issued separately by
OIG (as to sections 1128A and 1128B of
the Act) and CMS (as to section 1877 of
the Act). No waivers of any fraud and
abuse authorities are being issued in
this final rule.
The substance and timing of any such
waivers is outside the scope of this
rulemaking. However, the Department is
mindful of the significant interest of
participants in knowing waiver
parameters sufficiently in advance of
entering into financial arrangements.
The Department’s goal is that any
waivers meet the legal standard under
section 1115A, align closely and
appropriately with the final rules, are
clear, and limit burden on participants
and others to the extent feasible while
also protecting the program and patients
from fraud and abuse. The Department
is considering carefully concerns
expressed by commenters about the
existing fraud and abuse waivers for the
CJR model and will keep those concerns
in mind when considering fraud and
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abuse waivers for the EPM, as well as
any adjustments to the existing CJR
waivers. As was done for the CJR model,
waivers for the EPM will be
promulgated by notice rather than
rulemaking, which will expedite
issuance. Any fraud and abuse waivers
issued in connection with the EPM or
revisions to the existing CJR waivers of
fraud and abuse laws will be posted on
the OIG Web site and at https://
www.cms.gov/Medicare/Fraud-andAbuse/PhysicianSelfReferral/Fraudand-Abuse-Waivers.html.
Comment: Several commenters
asserted that the fraud and abuse laws
should be revised to accommodate
APMs and other aspects of the modern
health care environment. In addition,
many commenters offered suggestions
regarding how any fraud and abuse
waivers should be drafted for the EPM
and episode payment models generally.
Other commenters advocated for the
creation of a new Stark exception that
would protect certain financial
arrangements in risk-bearing models.
One commenter requested that CMS
provide a mechanism for EPM
participants and CJR participant
hospitals to ask questions about fraud
and abuse law waivers.
Response: These comments are
outside the scope of this rulemaking,
but we have forwarded them to
appropriate staff within the Department
for consideration. We note that the
public may contact CMS with questions
related to compliance with the EPM and
CJR regulations by emailing epm@
cms.hhs.gov and cjr@cms.hhs.gov,
respectively.
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3. EPM Collaborators
As we explained in the proposed rule,
given the financial incentives of episode
payment under the EPM, an EPM
participant might want to engage in
financial arrangements with individuals
and entities making contributions to the
EPM participant’s episode performance
on spending or quality. Such
arrangements would allow the EPM
participant to share all or some of the
reconciliation payments they might be
eligible to receive from CMS, or the
EPM participant’s internal cost savings
that resulted from care for beneficiaries
during EPM episodes. Likewise, such
arrangements would allow the EPM
participant to share the responsibility
for the funds needed to repay Medicare
with individuals and entities engaged in
providing care to EPM beneficiaries, if
those individuals and entities had a role
in the EPM participant’s episode
spending or quality performance. We
proposed to use the term ‘‘EPM
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collaborator’’ to refer to these
individuals and entities.
Since each proposed EPM’s episode
duration would be 90 days following
discharge from the anchor or chained
anchor hospitalization and such
episodes would be broadly defined as
discussed in section III.C.3.b. of the
proposed rule (81 FR 50832 through
50834), many providers and suppliers
other than the EPM participant would
furnish related services to beneficiaries
during EPM episodes. Those providers
and suppliers might include SNFs,
HHAs, LTCHs, IRFs, physicians,
nonphysician practitioners, providers or
suppliers of outpatient therapy services,
PGPs, hospitals, and critical access
hospitals (CAHs). In addition, ACOs
might be actively involved in
coordinating the care of beneficiaries
during EPM episodes. The proposed
definition of EPM collaborator included
each of these categories of individuals
and entities as eligible to be an EPM
collaborator. The proposed list of types
of EPM collaborators was the same list
as CJR collaborators, but with the
addition of hospitals, CAHs, and ACOs.
We expected that hospitals and CAHs
that were not EPM participants might
frequently play roles in care delivered to
EPM beneficiaries during a chained
anchor hospitalization as discussed in
section III.C.4.a.(5) of the proposed rule
(81 FR 50836 through 50840) or
following discharge from an anchor or
chained anchor hospitalization that
initiated an EPM episode. For example,
an AMI model participant without
cardiac surgery or interventional
cardiology capacity might need to
transfer certain AMI model beneficiaries
after initial admission to transfer
hospitals or transfer CAHs for
revascularization through PCI or
through CABG. A transfer hospital
might, itself, be participating in the AMI
and CABG models (a CAH cannot be an
AMI or CABG model participant), but
the AMI model episode would be the
responsibility of the AMI model
participant that first admitted the
beneficiary. In addition, hospital or
CAH readmission during the proposed
EPM episodes would be common for
beneficiaries post-anchor or postchained anchor hospitalization
discharge for AMI, CABG, and SHFFT
model beneficiaries, and, because care
for these clinical conditions might
sometimes be provided at transfer
hospitals that initiated EPM episodes as
EPM participants, we expected that
readmissions during such episodes
might sometimes be to other hospitals or
CAHs that were not EPM participants
near beneficiaries’ home communities.
Thus, we believed it would be
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435
important to allow EPM participants to
enter into financial arrangements with
other hospitals and CAHs that cared for
EPM beneficiaries, in order to align the
financial incentives of such other
hospitals and CAHs with the EPM goals
of improving the quality and efficiency
of EPM episodes.
Many accountable care organizations
and other stakeholders had expressed
strong interest in being collaborators in
episode payment models generally,
including sharing potential financial
risks and rewards with model
participants. Multiple commenters on
the CJR Final Rule stated that robust
accountable care organizations have
proven track records of providing
Medicare providers and suppliers with
care redesign and care management
assistance for Medicare beneficiaries, as
well as managing the overall care of
accountable care organization-aligned
beneficiaries to improve the quality and
efficiency of care (80 FR 73417). They
reasoned that accountable care
organizations might be able to provide
CJR participant hospitals with care
coordination assistance at reduced cost
due to economies of scale and existing
accountable care organization resources,
as well as potentially assume a
percentage of downside risk, in order to
mitigate that risk to CJR participant
hospitals. In the CJR Final Rule (80 FR
73417), we did not adopt accountable
care organizations as CJR collaborators,
responding that we decided to limit the
testing of gainsharing relationships to
solely those between hospitals and
providers and suppliers enrolled in
Medicare because we expected enrolled
providers and suppliers to be most
directly and specifically engaged with
the CJR participant hospitals in care
redesign and episode care for CJR
beneficiaries who had surgeries at those
hospitals. We also noted that a number
of scenarios discussed by commenters to
support their request to allow
accountable care organizations to be CJR
collaborators could be achieved outside
of the context of gainsharing
relationships between the CJR
participant hospitals and those
organizations.
With the steady growth in the number
of accountable care organizations and
accountable care organization-aligned
beneficiaries, in the proposed rule we
noted that we had further considered
the potential for accountable care
organizations to be EPM collaborators.
The proposed EPMs would include
beneficiaries with cardiovascular
disease as well as beneficiaries with hip
fracture who commonly would be older
with multiple comorbidities, and
accountable care organizations have
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expertise in care coordination and
accountability for the quality and
expenditures for health care for
accountable care organization-aligned
beneficiaries over an annual period.
While we proposed to exclude certain
accountable care organization-aligned
beneficiaries from EPM episodes, we
noted that the challenges of attributing
savings and changes in the quality of
care for beneficiaries simultaneously in
EPM and total cost-of-care models or
programs, such as accountable care
organizations, remained under
consideration without full resolution, as
discussed further in section III.D.6. of
the proposed rule (81 FR 50869 through
50871). Local relationships between
providers, suppliers, and accountable
care organizations vary in the care of
beneficiaries, and it would be difficult
for CMS at this time to provide standard
program or model rules that would
fairly distribute savings among different
models and programs for overlapping
periods of beneficiary care, when
variable local arrangements would
determine which entity provides the
resources for coordinating and
managing a particular beneficiary’s care
over time. Finally, we noted that
accountable care organizations are
groups of physicians, hospitals, and
other health care providers and
suppliers that come together to furnish
coordinated, high quality care to their
aligned Medicare beneficiaries to ensure
that these beneficiaries, especially the
chronically ill, get the right care at the
right time, while avoiding unnecessary
duplication of services and preventing
medical errors. Accountable care
organizations’ goals of delivering high
quality care and spending health care
dollars more wisely are the same as
those of hospitals that would participate
in the EPM. Therefore, we believed it
would be especially important to further
encourage collaborative partnerships
between accountable care organizations
and EPM participants that maximize
their organizational efficiency and
effectiveness, given their shared goals.
In considering the accountable care
organizations that could be EPM
collaborators engaged in collaborative
relationships with EPM participants, we
limited our consideration to accountable
care organizations under Medicare
because the proposed EPM would be an
episode payment model for Medicare
FFS beneficiaries. We note that in
section III.D.6. of the proposed rule (81
FR 50869 through 50871), we proposed
to exclude from the proposed EPM
episodes beneficiaries who are aligned
to the Next Generation ACO model or
tracks of the Comprehensive ESRD Care
Model incorporating downside risk for
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financial losses. Downside risk for
financial losses and prospective
alignment of beneficiaries were
important criteria in selection of these
models and tracks of models for this
proposed exclusion. We also sought
comment in that section on extending
this exclusion proposal to Track 3 of the
Shared Savings Program. Because we
proposed to allow financial
arrangements under the EPM only with
those entities that were involved in the
delivery of care to EPM beneficiaries
with goals of improving the quality and
efficiency of EPM episodes, we did not
believe it would be appropriate to
permit Next Generation ACOs to be
EPM collaborators because their aligned
beneficiaries would be excluded from
the EPM. Similarly, because we
proposed that beneficiaries eligible for
Medicare on the basis of ESRD be
excluded from the EPM as discussed in
section III.C.4.a. of the proposed rule (81
FR 50834), we did not believe that
participants in the Comprehensive
ESRD Care initiative which
predominantly include beneficiaries
eligible for Medicare on the basis of
ESRD should be permitted to be EPM
collaborators. Finally, we noted that the
Pioneer ACO model ends in CY 2016, so
that model would not overlap with the
EPM which was proposed to begin on
July 1, 2017.
Thus, we proposed that ‘‘ACOs,’’
meaning those ACOs as defined at
§ 425.20 of regulations that are
participating in the Shared Savings
Program, be permitted to be EPM
collaborators. This proposal would
allow locally variable financial
arrangements that could account for the
way care in EPM episodes was
coordinated and managed in
communities, and ensure that entities
with appropriate skills and experience
were permitted to share the proposed
EPM’s risks and rewards with EPM
participants. Medicare has a close
relationship with such ACOs, which are
regulated by CMS, so we could verify
that these ACOs met current Shared
Savings Program requirements that
could make them suitable for a role as
EPM collaborators. Finally, in this way,
ACO participants and ACO providers/
suppliers might be engaged in EPM care
redesign directly through their ACO,
instead of bypassing the ACO to become
involved directly in the EPM through
the EPM participant. We limited our
proposal of entities that were not
providers or suppliers but that were
permitted to be EPM collaborators to
ACOs alone. We proposed to allow
financial arrangements under the EPM
only with those entities that were
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involved in the delivery of care to EPM
beneficiaries.
We set forth in proposed § 512.2 that
ACOs and the following types of
providers and suppliers may be EPM
collaborators:
• SNF.
• HHA.
• LTCH.
• IRF.
• Physician.
• Nonphysician practitioner.
• Provider or supplier of outpatient
therapy services.
• PGP.
• Hospital.
• CAH.
• ACO.
We sought comment on the proposed
definition of EPM collaborators. In
addition to general comment, we were
specifically interested in comment on
the proposal to include hospitals, CAHs,
and ACOs in the definition of EPM
collaborators. Furthermore, we sought
comment specifically on the
accountable care organizations that we
proposed to include in the definition of
ACO and which accountable care
organizations should be included and
excluded from the definition of ACOs
that might be EPM collaborators to best
advance the goals of the EPM and
program generally. Finally, we also
sought comment on the regulatory and
practical implications of establishing
that ACOs may be EPM collaborators
under the EPM, including without
limitation how the requirements under
the EPM would relate to how financial
arrangements within ACOs are currently
regulated under the Medicare Shared
Savings Program.
The following is a summary of the
comments received and our responses.
Comment: Several commenters
requested clarification about whether
certain groups of health care
professionals that do not include
physicians could be EPM collaborators.
The commenters requested that, in
addition to PGPs, groups of certified
registered nurse anesthetists (CRNAs),
advanced practice registered nurses
(APRNs), outpatient speech-language
pathologists, physical therapists, and
other qualified licensed healthcare
professionals who are not physicians, be
permitted to be EPM collaborators. One
commenter explained that these groups
are identified by a TIN.
A number of commenters pointed out
that while the proposed rule specifically
listed PGPs as eligible to be EPM
collaborators, CMS’ proposal did not
separately list groups of physical
therapists or other therapists as eligible
to be EPM collaborators. One
commenter asserted that allowing only
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individual therapists to be EPM
collaborators and excluding therapy
practice groups from entering into
sharing arrangements with EPM
participants is shortsighted because
rehabilitation therapy practices and
independent therapists are likely to be
significant contributors to SHFFT
episodes. The commenters requested
that CMS clarify the regulations to
explicitly permit groups of therapists to
enter into sharing arrangements with
EPM participants. One commenter
further proposed that once a therapy
practice group contracts with a hospital
as a collaborator, it should be up to the
practice group to ensure that financial
exchanges with the participant hospital
were attributed to the physical
therapists who directly furnished
services to EPM beneficiaries.
Response: We appreciate the interest
of the commenters in ensuring groups of
nonphysician practitioners and groups
of therapists have the same
opportunities to be EPM collaborators
that we proposed for PGPs, as well as
their interest in allowing financial
exchanges with their members who
furnished services to EPM beneficiaries.
Under our proposal, individual
nonphysician practitioners are
permitted to be EPM collaborators. We
also proposed that individual therapists
would be permitted to be collaborators
to the extent that they fell within the
collaborator category for provider or
supplier of outpatient therapy services.
As collaborators, these individuals
would be eligible to receive gainsharing
payments from EPM participants.
Moreover, our proposal defined a PGP
member to include a nonphysician
practitioner or therapist who is an
owner or employee of a PGP who has
reassigned his or her right to receive
Medicare payment to the PGP.
Accordingly, as PGP members, these
nonphysician practitioners and
therapists would be eligible for
distribution payments and downstream
distribution payments from a PGP. We
agree with the commenters that because
our proposals addressed the role of
PGPs as EPM collaborators and
collaboration agents without reference
to other types of groups, we left some
uncertainty about whether groups
without a physician owner or employee
would be eligible to be EPM
collaborators and whether such groups
would be permitted to enter into
distribution arrangements or
downstream distribution arrangements
with their members. We also agree with
the commenters that our proposal to
allow providers and suppliers of
outpatient therapy services to be EPM
collaborators is potentially unclear,
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because this term did not separately
identify therapists in private practice or
groups of therapists in private practice
on the list of EPM collaborators, as did
our proposal regarding physicians and
PGPs. We also appreciate the
commenters’ uncertainty associated
with the fact that we did not address
whether a collaborator that was a
therapy group practice would be
permitted to enter into distribution
arrangements or downstream
distribution arrangements with their
members, as we proposed for PGPs.
We do not believe it would be
appropriate to allow a group of licensed
health care professionals to be EPM
collaborators if that group consists
solely of individuals who are not among
the categories of individuals we
proposed to be EPM collaborators.
However, we believe that if a category
of individuals is eligible to be EPM
collaborators, then Medicare-enrolled
groups that include such individuals
should also be permitted to be
collaborators and that such groups
should be permitted to enter into
distribution arrangements or
downstream distribution arrangements
with their members. We clarify these
policies through this final rule.
Groups of nonphysician practitioners
that do not include a physician are not
included in the category of PGPs that we
proposed to include on the list of EPM
collaborators. However, we believe
these groups of nonphysician
practitioners should be permitted to be
EPM collaborators, just as we proposed
to allow both individual physicians and
nonphysician practitioners to be EPM
collaborators. We also believe these
groups of nonphysician practitioners
should be treated similarly to PGPs with
regarding their ability to engage in
distribution arrangements and
downstream distribution arrangements
with their members, consistent with our
treatment of nonphysician practitioners
who are PGP members. Therefore, we
are adding to the list of entities that are
eligible to be EPM collaborators a
nonphysician practitioner group
practice (NPPGP), defined as ‘‘an entity
that is enrolled in Medicare as a group
practice, includes at least one owner or
employee who is a nonphysician
practitioner, does not include a
physician owner or employee, and has
a valid and active TIN.’’ The
requirements for sharing arrangements,
distribution arrangements, and
downstream distribution arrangements
for NPPGPs and NPPGP members are
discussed in the sections of this final
rule that address our policies for these
arrangements.
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437
We further believe that our proposal
to include a provider or supplier of
outpatient therapy services on the list of
types of providers and suppliers that
can be EPM collaborators should be
modified to provide greater clarity about
the providers and suppliers of
outpatient therapy services that can be
EPM collaborators. The Medicare
Claims Processing Manual, Chapter 5,
Part B Outpatient Rehabilitation and
CORF/OPT Services, Section 10 lists the
following Medicare-enrolled providers
and suppliers that can submit claims for
outpatient therapy services: SNF;
outpatient hospital; CAH; HHA;
outpatient physical therapy provider
(OPT), otherwise known as
rehabilitation agency; comprehensive
outpatient rehabilitation facility (CORF);
physician; nonphysician practitioner;
and physical or occupational therapist
or speech-language pathologist in
private practice.128 We note that the list
of EPM collaborators already includes
hospitals, SNFs, CAHs, HHAs,
physicians, and nonphysician
practitioners so their inclusion as
collaborators under the proposed
definition of provider or supplier of
outpatient therapy services is
duplicative. Therefore, rather than
finalizing our proposed definition of
provider of outpatient therapy services
which would have included all
providers and suppliers of outpatient
therapy services, we believe it is clearer
to specify individually on the list of
EPM collaborators all the types of
Medicare-enrolled providers and
suppliers that can bill Medicare for
outpatient therapy services. Thus, we
are defining a new term therapist in
private practice as ‘‘a therapist that
either: complies with the special
provisions for services furnished by
physical therapists in private practice in
§ 410.60(c) of this chapter; or complies
with the special provisions for services
furnished by occupational therapists in
private practice in § 410.59(c) of this
chapter; or complies with the special
provisions for services furnished by
speech-language pathologists in private
practice in § 410.62(c) of this chapter.’’
We are adding therapist in private
practice to the list of EPM collaborators,
which ensures that all individual
suppliers of outpatient therapy services
are on the EPM collaborator list. In
addition, we are revising our definition
of provider of outpatient therapy
services to mean ‘‘an entity that is
enrolled in Medicare as a provider of
therapy services and furnishes one or
128 https://www.cms.gov/Regulations-andGuidance/Guidance/Manuals/downloads/
clm104c05.pdf.
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more of the following: outpatient
physical therapy services as defined in
§ 410.60 of this chapter; outpatient
occupational therapy services as defined
in § 410.59 of this chapter; outpatient
speech-language pathology services as
defined in § 410.62 of this chapter.’’
Under this revised definition, provider
of outpatient therapy services now
includes only those entities that enroll
in Medicare specifically as a provider of
outpatient physical therapy/
occupational therapy/speech-language
pathology services, and we are revising
the list of EPM collaborators to use this
defined term in place of ‘‘provider or
supplier of outpatient therapy services.’’
Finally, we are adding CORFs to the list
of EPM collaborators because it is the
only other type of provider that can
furnish outpatient therapy services that
is not included on the EPM collaborator
list under our new and revised terms.
Thus, with the addition of therapy
group practices as discussed specifically
later in this section, in total, these
changes to the definitions and
supplements to the list of EPM
collaborators clarify which individuals
and entities may be EPM collaborators
by separately specifying each type of
supplier and provider of outpatient
therapy services that is eligible to be an
EPM collaborator.
With respect to the specific interest of
commenters in therapy practice groups
being eligible to be EPM collaborators
that can share payments under EPM
financial arrangements with their
members, we agree with the
commenters that such groups should be
permitted to be EPM collaborators and
to enter into distribution arrangements
and downstream distribution
arrangements with their members,
consistent with our treatment of PGPs
and NPPGPs. Thus, we are defining
therapy group practice (TGP) as ‘‘an
entity that is enrolled in Medicare as a
therapy group in private practice,
includes at least one owner or employee
that is a therapist in private practice,
does not include an owner or employee
who is a physician or nonphysician
practitioner, and has a valid and active
TIN’’ and adding TGP to the list of EPM
collaborators. The requirements for
sharing arrangements, distribution
arrangements, and downstream
distribution arrangements for TGPs and
TGP members are discussed in the
sections of this final rule that address
our policies for these arrangements. We
are finalizing, with the modifications
discussed, the definition of EPM
collaborator in § 512.2 to mean an ACO
or one of the following Medicare-
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enrolled individuals or entities that
enters into a sharing arrangement:
(1) SNF.
(2) HHA.
(3) LTCH.
(4) IRF.
(5) Physician.
(6) Nonphysician practitioner.
(7) Therapist in private practice.
(8) CORF.
(9) Provider of outpatient therapy
services.
(10) PGP.
(11) Hospital.
(12) CAH.
(13) NPPGP.
(14) TGP.
Comment: A number of commenters
expressed support for CMS’ proposed
definition of ‘‘EPM collaborators,’’
including the proposed addition of
ACOs, hospitals, and CAHs to the types
of collaborators that were previously
adopted for the CJR model. The
commenters claimed that allowing
additional health care providers,
suppliers, and ACOs to be EPM
collaborators would further encourage
robust care coordination across EPM
episodes. Several commenters asserted
that by recognizing the expertise that
ACOs may offer EPM participants as
EPM collaborators with regard to
managing the cost and quality of care
that Medicare beneficiaries receive,
ACOs will be able to use their
substantial expertise and resources to
contribute to the EPM’s dual goals of
limiting spending and increasing
quality. One commenter further
commended CMS for making the list of
EPM collaborators exhaustive and not
including third party conveners, who
the commenter believes lack a
commitment to patients, local providers,
or their community.
In contrast, some commenters
expressed disappointment that the list
of EPM collaborators did not include
entities such as pharmaceutical
companies; medical device companies;
medical technology companies; social
services aging networks; and other third
parties, such as the types of convening
organizations participating in other
Innovation Center models. Several
commenters believe that were medical
device and pharmaceutical
manufacturers allowed to be EPM
collaborators, those manufacturers may
make meaningful contributions to the
success of the EPM by ensuring their
products are used appropriately;
aligning financial and other incentives
to improve patient outcomes;
demonstrating the value of their
products; and reducing costs. Other
commenters who favored adding
medical technology companies as EPM
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collaborators asserted that medical
technology companies can make a
significant, positive impact on care
redesign and cost containment as well
as provide integrated data analytic
infrastructure and services to optimize
care and to achieve quality goals. A few
commenters suggested that CMS should
expand the list of potential EPM
collaborators to include non-provider or
non-supplier entities that have a track
record of providing Medicare providers
and suppliers participating in other
models with support services such as
care redesign, data analytics, and
general program support, as well as
community-based organizations that are
well-equipped and efficient in
providing social and supportive services
that help beneficiaries stay out of the
hospital. Several commenters also
encouraged CMS to include all APM
entities as EPM collaborators, reasoning
that APM entities are similar to ACOs in
that they are a legal entity that is
separate from its participants.
Additionally, one commenter
recommended that Next Generation
ACOs be included in the definition of
ACOs that are on list on EPM
collaborators, so the Next Generation
ACO may act on behalf of its providers
to enter into financial arrangements
with EPM participants for beneficiaries
not assigned to the ACO. The
commenter explained that not including
Next Generation ACOs in the definition
of ACOs that CMS proposed could be
EPM collaborators will require ACO
participants and ACO providers/
suppliers of the Next Generation ACO to
enter in EPM sharing arrangements on
their own without the Next Generation
ACO to represent them.
Finally, one commenter shared its
perspective that CMS should not restrict
the definition of EPM collaborators
because such an approach discourages
the introduction of new entities and
individuals in the healthcare market.
The commenter requested that CMS
allow market forces to shape the
innovation of EPM participants and
their community partners in order to
determine the financial partnerships
that would be most beneficial to
achieving the overarching goals of the
EPM. The commenter asserted that
being too prescriptive regarding the
individuals and entities that can and
cannot enter into financial arrangements
under the EPM would not allow for new
organizations to develop in the market
that may have the potential to generate
substantial cost savings for EPM
participants.
Response: We appreciate the support
of the commenters for our proposed list
of the types of individuals and entities
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that can be EPM collaborators, including
our proposal to include hospitals,
CAHs, and ACOs that would expand the
list beyond the CJR collaborators
adopted in the CRJ Final Rule (80 FR
73418).
We note that some of the potential
contributions, such as integrating the
data analytic infrastructure and services
to optimize care to achieve quality
goals, that were suggested by
commenters as reasons to allow third
parties, such as pharmaceutical, medical
device, and medical technology
companies as well as other types of
convening organizations participating in
other Innovation Center models, to be
EPM collaborators can be achieved
outside of the context of sharing
arrangements through other
relationships between the EPM
participant and those entities. In
response to the specific requests that we
include APM entities on the list of EPM
collaborators, given that an APM entity,
as defined in § 414.1305, means an
entity that participates in an APM or
payment arrangement with a nonMedicare payer through a direct
agreement or through federal or state
law or regulation, we believe that
adding all APM entities to the list of
EPM collaborators would be overly
expansive and risk loosening the
clinical link between the EPM
collaborator, EPM participant, and EPM
beneficiary that we believe is important
for improving the quality and reducing
the cost of care under the EPM. With the
exception of ACOs, PGPs, NPPGPs, and
TGPs, we continue to believe that any
EPM collaborator that receives a
gainsharing payment must have
furnished a billable service included in
the episode to an EPM beneficiary and
that the payment arrangements for
gainsharing payments must be
substantially based on the quality of
care and the provision of EPM activities.
In the case of ACOs, PGP, NPPGPs, and
TGPs that are EPM collaborators, we
require that the entity itself must have
contributed to EPM activities and been
clinically involved in the care of EPM
beneficiaries in order to be eligible to
receive a gainsharing payment or be
required to make an alignment payment
and at this point we are not convinced
any APM entities could meet these
eligibility criteria, other than ACOs. We
also do not agree with the commenter
who recommended that we not restrict
the definition of EPM collaborators to
any specific individuals or entities. We
believe it is important for EPM
participants to engage EPM
collaborators that have a commitment to
their local communities, local providers,
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and Medicare beneficiaries in order to
create the greatest potential for
sustained improvements in quality and
reductions in cost under the EPM.
We appreciate the commenter’s
suggestion that Next Generation ACOs
be included in the definition of ACOs
that are on the list of EPM collaborators,
so the Next Generation ACO may act on
behalf of its ACO participants and ACO
providers/suppliers to establish sharing
arrangements with EPM participants for
beneficiaries not assigned to the ACO.
While we understand that the Next
Generation ACO would like to enter into
an EPM sharing arrangement as an EPM
collaborator on behalf of its providers
and suppliers, to be eligible to receive
a gainsharing payment or be required to
make an alignment payment under the
sharing arrangement the Next
Generation ACO itself must have
contributed to EPM activities and been
clinically involved in the care of EPM
beneficiaries through activities such as
providing care coordination services to
EPM beneficiaries during and/or after
inpatient admission; engaging with an
EPM participant in care redesign
strategies, and actually performing a
role in implementing such strategies,
that are designed to improve the quality
of care and reduce spending for EPM
episodes; or in coordination with
providers and suppliers (such as ACO
participants, ACO providers/suppliers,
the EPM participant, and post-acute care
providers) implementing strategies
designed to address and manage the
comorbidities of EPM beneficiaries. We
are unclear of the role the Next
Generation ACO itself would play in the
care of EPM beneficiaries that are not
assigned to the ACO, beyond serving as
a contracting agent for its ACO
participants and ACO providers/
suppliers. We further believe that such
an arrangement would require
distinguishing activities on behalf of
beneficiaries assigned to the ACO who
are excluded from EPM episodes and
beneficiaries not assigned to the ACO
who are included in EPM episodes, and
such distinctions could create confusion
for beneficiaries, providers, and
suppliers, as well as administrative
complexity for the Next Generation
ACO. Therefore, we do not believe it
would be appropriate to include Next
Generation ACOs in the definition of
ACOs that may be EPM collaborators.
Finally, we note that as discussed in
section III.D.6.c.(3) of this final rule, we
are additionally finalizing the exclusion
of beneficiaries from EPM episodes who
are prospectively assigned to a Shared
Savings Program ACO in Track 3.
Therefore, for consistency with our
policy for Next Generation ACOs whose
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439
assigned beneficiaries are also excluded
from EPM episodes, we are excluding
Shared Savings Program ACOs in Track
3 from the definition of ACOs that may
be EPM collaborators. Thus, we are
modifying our definition of ACO to read
‘‘ACO means an accountable care
organization, as defined at § 425.20 of
this chapter, that participates in the
Shared Savings Program and is not in
Track 3.’’ We emphasize that no EPM
policy precludes providers or suppliers
who are ACO participants or ACO
providers/suppliers in a Next
Generation ACO from entering into a
sharing arrangement with an EPM
participant on their own, provided they
are on the list of EPM collaborators.
In summary, at this time we will not
adopt a final policy that includes
additional entities or individuals that
are not providers or suppliers beyond
those we proposed to be EPM
collaborators. We selected acute care
hospitals as the financially responsible
entity for the EPM because we are
interested in evaluating the impact of
bundled payment and care redesign
across a broad spectrum of hospitals
with varying levels of infrastructure and
experience in entering into risk-based
payment arrangements. We believe that
it is most appropriate to identify a single
type of provider to bear financial
responsibility for making repayment to
CMS under the EPM. Given that
hospitals perform a central role in
coordinating episode-related care and
ensuring smooth transitions for
beneficiaries, this role factored in our
decision to select IPPS hospitals as the
financially responsible entity for this
model. Under this structure, we believe
that limiting the testing of gainsharing
relationships to solely those between
EPM participants, certain Shared
Savings Program ACOs, and providers
and suppliers enrolled in Medicare is
most appropriate because we expect
enrolled providers and suppliers to be
most directly and specifically engaged
with the EPM participants in care
redesign and EPM episode care for
beneficiaries. While we recognize that
Shared Savings Program ACOs are not
providers or suppliers, Medicare has a
close relationship with such ACOs,
which are regulated by CMS, so we can
verify that these ACOs meet current
Shared Savings Program requirements
that make them suitable for a role as
EPM collaborators. Further, by
including such ACOs on the list of EPM
collaborators, we are permitting locally
variable financial arrangements that
could account for the way care in EPM
episodes is coordinated and managed in
communities, and ensure that entities
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with appropriate skills and experience
are permitted to share the EPM’s risks
and rewards with EPM participants.
We are finalizing in § 512.2 the
definition of ACO, with modification to
mean an accountable care organization,
as defined at § 425.20 of this chapter,
that participates in the Shared Savings
Program and is not in Track 3.
Comment: One commenter requested
clarification about whether outpatient
speech-language pathologists are
considered providers of outpatient
therapy services and, therefore, eligible
to be EPM collaborators.
Response: We appreciate the
opportunity to clarify that speechlanguage pathologists are eligible to be
EPM collaborators if they are furnishing
outpatient services as Medicareenrolled speech-language pathologists
in private practice. As discussed
previously in this section, speechlanguage pathologists in private practice
are included under the new definition
of therapist in private practice when
they are therapists that comply with the
special provisions for services furnished
by speech-language pathologists in
private practice in § 410.62(c). In
addition, a group of speech-language
pathologists in private practice is
included under the new definition of
TGP when the group is entity that is
enrolled in Medicare as a therapy group
in private practice, includes at least one
owner or employee that is a therapist in
private practice, does not include an
owner or employee who is a physician
or nonphysician practitioner, and has a
valid and active TIN. Both therapists in
private practice and TGPs are included
on the final list of types of providers
and suppliers that may be EPM
collaborators so individual speechlanguage pathologists in private
practice, as well as speech-language
pathology groups in private practice, are
eligible to be EPM collaborators.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposals in § 512.2 for
the definition of EPM collaborator and
other terms used in that definition, with
modification to revise the definitions of
provider of outpatient therapy services;
and ACO; create new definitions for
CORF, therapist in private practice,
NPPGP, and TGP; and include
additional individuals and entities on
the list of EPM collaborators. EPM
collaborator means an ACO or one of the
following Medicare-enrolled individuals
or entities that enters into a sharing
arrangement:
(1) SNF.
(2) HHA.
(3) LTCH.
(4) IRF.
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(5) Physician.
(6) Nonphysician practitioner.
(7) Therapist in private practice.
(8) CORF.
(9) Provider of outpatient therapy
services.
(10) PGP.
(11) Hospital.
(12) CAH.
(13) NPPGP.
(14) TGP.
4. Sharing Arrangements Under the
EPM
a. General
Similar to the CJR model (80 FR
73430), we proposed that certain
financial arrangements between an EPM
participant and an EPM collaborator be
termed ‘‘sharing arrangements.’’ A
sharing arrangement would be a
financial arrangement to share only—(1)
EPM reconciliation payments; (2) the
EPM participant’s internal cost savings;
and (3) the EPM participant’s repayment
amount. Where a payment from an EPM
participant to an EPM collaborator was
made pursuant to a sharing
arrangement, we proposed to define that
payment as a ‘‘gainsharing payment.’’ A
gainsharing payment may be composed
only of—(1) EPM reconciliation
payments; (2) the EPM participant’s
internal cost savings; or (3) both. A
‘‘reconciliation payment’’ was proposed
to be defined as a payment made by
CMS to an EPM participant as
determined in accordance with
proposed § 512.305(d) and as discussed
in section III.D.5. of the proposed rule
(81 FR 50864 through 50867). ‘‘Internal
cost savings’’ would be the measurable,
actual, and verifiable cost savings
realized by the EPM participant
resulting from care redesign undertaken
by such participant in connection with
providing items and services to
beneficiaries within specific EPM
episodes. Internal cost savings would
not include savings realized by any
individual or entity that was not the
EPM participant. Where a payment from
an EPM collaborator to an EPM
participant was made pursuant to an
EPM sharing arrangement, we proposed
to define that payment as an ‘‘alignment
payment.’’ An alignment payment could
consist only of a portion of the
‘‘repayment amount,’’ which would be
the amount owed by an EPM participant
to CMS, as reflected on a reconciliation
report. An EPM participant would not
be permitted to make a gainsharing
payment or receive an alignment
payment except in accordance with a
sharing arrangement. We proposed that
a sharing arrangement must comply
with the provisions of proposed
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§ 512.500 and all other applicable laws
and regulations, including the
applicable fraud and abuse laws and all
applicable payment and coverage
requirements.
We proposed that the EPM participant
must develop, maintain, and use a set of
written policies for selecting individuals
and entities to be EPM collaborators,
and that the selection criteria must
include the quality of care delivered by
the potential EPM collaborator. The
selection criteria could not be based
directly or indirectly on the volume or
value of past or anticipated referrals or
business otherwise generated by,
between or among the EPM participant,
any EPM collaborator, any collaboration
agent, any downstream collaboration
agent, or any individual or entity
affiliated with an EPM participant, EPM
collaborator, collaboration agent, or
downstream collaboration agent. With
the exception of adding ‘‘past or
anticipated’’ to the selection criteria for
EPM collaborators, these proposed
criteria were similar to the existing
requirements of the CJR model (80 FR
73430). By adding this language, all
previous and future referrals between or
among the EPM participant, any EPM
collaborator, any collaboration agent,
any downstream collaboration agent, or
any individual or entity affiliated with
an EPM participant, EPM collaborator,
collaboration agent, or downstream
collaboration agent were encompassed.
We did not believe it would be
appropriate for sharing arrangements to
be based on criteria that include the
volume or value of past or anticipated
referrals because the sole purpose of
sharing arrangements would be to create
financial alignment between EPM
participants and EPM collaborators
toward the EPM goals of improving the
quality and efficiency of episode care.
Thus, we proposed to require EPM
participants to select EPM collaborators
based on criteria that include the quality
of care furnished by the potential EPM
collaborator to ensure that the selection
of EPM collaborators took into
consideration the likelihood of their
future performance in improving the
quality of episode care. In addition,
requiring that selection criteria include
quality of care furnished by the
potential EPM collaborator would
provide a safeguard against abuse.
Finally, we proposed that if an EPM
participant entered into a sharing
arrangement, its compliance program
must include oversight of sharing
arrangements and compliance with the
applicable requirements of the EPM.
Requiring oversight of sharing
arrangements to be include in the
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compliance program would provide a
program integrity safeguard.
The proposals for the general
provisions for sharing arrangements
under the EPM were included in
proposed § 512.500(a). We sought
comment about all of the provisions set
out in the preceding discussion,
including whether additional or
different safeguards would be needed to
ensure program integrity, protect against
abuse, and ensure that the goals of the
EPM were met.
The following is a summary of the
comments received and our responses.
Comment: While many commenters
expressed appreciation for CMS’
proposal that would allow EPM
participant choice regarding the
formation of specific financial
relationships with other individual and
entities as determined by the EPM
participant, several commenters
expressed concern that engaging in
sharing arrangements by EPM
participants is voluntary for hospitals.
One commenter stated that CMS’
proposal to leave the choice of sharing
reconciliation payments from episode
savings achieved under the EPM to the
responsible hospitals would have the
unintended consequences of further
consolidating control of care at the
hospital level rather than with the
community providers at the forefront of
providing patient-centered care and
could restrict beneficiary choice.
Another commenter stated that because
EPM participants are not required to
distribute their episode savings as
gainsharing payments, the proposed
model design and financial
arrangements would exclude post-acute
care providers from having a significant
role in the EPM. One commenter who
expressed appreciation for CMS’
proposal to allow ACOs to be EPM
collaborators nevertheless asserted that
under the current and proposed policies
for EPM financial arrangements, model
participants often have little or no
incentive to collaborate with ACOs, a
situation which threatens the continuity
of care for patients. The commenter
believes that participants in bundled
payment models have a significant
incentive to take advantage of an ACO’s
ongoing efforts to coordinate care over
the course of the full year (which
includes the EPM episode), which could
lead to episode savings achieved by the
ACO’s efforts, rather than hospitals’
efforts under the EPM. The commenter
urged CMS to require sharing
arrangements between EPM participants
and unrelated ACOs in the same market
or otherwise determine that all ACOassigned beneficiaries would be
excluded from EPM episodes. Finally,
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another commenter encouraged CMS, at
a minimum, to add stronger language to
encourage EPM participants to enter
into sharing arrangements if CMS
chooses to maintain the proposed policy
which is permissive rather than
directive.
Response: We appreciate the
perspectives of the commenters
regarding our proposal for financial
arrangements under the EPM that would
not require EPM participants to enter
into sharing arrangement with
collaborators under the model. As we
finalize in section III.B.3. of this final
rule for the EPM and as we finalized for
the CJR model in the CJR Final Rule (80
FR 73288), we have selected acute care
hospitals as the financially responsible
entity for the EPM because we are
interested in evaluating the impact of
bundled payments and care redesign
across a broad spectrum of hospitals
with varying levels of infrastructure and
experience in entering into risk-based
financial arrangements. Our expectation
that hospitals would perform a central
role in coordinating episode-related care
and ensuring smooth transitions for
beneficiaries hospitalized for clinical
conditions that are the focus of the EPM
factored into our identification of
hospitals as the financially responsible
entity for the model.
While we proposed that hospitals
would be the financially responsible
entity for episodes under the EPM as
they are under the CJR model, we agree
with the commenters that effective care
redesign for EPM episodes likely
requires meaningful collaboration
among acute care hospitals, CAHs, postacute care providers, ACOs, physicians,
and other providers and suppliers
within communities to achieve the
highest value care for Medicare
beneficiaries. We believe it may be
essential for key providers and suppliers
to be aligned and engaged, financially
and otherwise, with participant
hospitals, and that they have the
potential to share financial
responsibility with those hospitals. We
believe that close alignment and
engagement of certain providers,
suppliers, and ACOs with EPM
participants may be especially
important, given the clinical complexity
of many beneficiaries in EPM episodes
who are likely to have underlying
chronic condition and risk factors, such
as advanced age that led to the acute
event of AMI or hip fracture or
progressively worsening cardiac status
resulting in CABG that are the focus of
EPM episodes. Depending on a
hospital’s current degree of clinical
integration, new and different
contractual relationships among
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441
hospitals and other health care
providers and suppliers may be
important, although not necessarily
required, for EPM success in a
community. We do not believe,
however, that it would be appropriate to
require that EPM participants engage in
sharing arrangements, including with
any specific individuals or entities such
as ACOs, since, under the EPM, the
participant hospitals are solely
responsible to CMS for financial risk
under the models. While we are
providing EPM participants with
required parameters for any financial
arrangements with collaborators that
assist them in engaging other
individuals and entities in care redesign
toward the goals of improving EPM
episode quality and reducing cost, we
believe that model participants
providing care in their own
communities are best positioned to
determine whether sharing
arrangements would advance these
goals. We refer to section III.D.6.c.(3) of
this final rule for further discussion of
our final policies regarding overlap of
EPM beneficiaries with shared savings
models and programs.
We emphasize that, although we
allow sharing arrangements under the
EPM, beneficiaries in EPM episodes
retain their full rights to choose their
providers and suppliers. EPM
participants, providers, and suppliers
are reminded that patient steering is not
permissible and such entities and
individuals must continue to comply
with all applicable law and regulations.
EPM participants and their collaborators
that engage in sharing arrangements
may not impede the rights of the
beneficiary. Furthermore, we reiterate
that sharing arrangements must not
induce the EPM participant, EPM
collaborator, or any employees,
contractors, or subcontractors of the
EPM participant or EPM collaborator to
reduce or limit medically necessary
services to any Medicare beneficiary; or
restrict the ability of an EPM
collaborator to make decisions in the
best interests of its patients, including
the selection of devices, supplies, and
treatments.
Comment: A number of commenters
commended CMS for not requiring EPM
participants to collaborate with certain
groups of providers or suppliers,
thereby allowing market forces to feed
the creative innovation of model
participants and their community
partners to determine the financial
partnerships that would be most
beneficial to achieving the overarching
goals of the EPM. One commenter stated
that EPM participants should not be
required to offer risk-sharing
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arrangements to all post-acute care
providers in their markets. Several
commenters expressed support for CMS’
proposal to require EPM participants to
utilize quality criteria in the selection of
collaborators, which is consistent with
the goal of the EPM to improve the
quality of episode care while reducing
its cost.
Many commenters also agreed with
CMS’ intent that the selection
requirements should prevent EPM
participants from developing
methodologies for selecting
collaborators that take into account the
volume or value of past or anticipated
referrals between the parties. However,
one commenter advocated that CMS
permit EPM participants to consider a
potential EPM collaborator’s relevant
experience in collaborator selection.
The commenter seemed to be
recommending that CMS permit
collaborator selection criteria to
consider factors such as the amount of
procedures a physician has performed
that would be subject to payment under
an EPM episode or the amount of other
services a potential collaborator has
performed that would be considered
EPM activities. The commenter urged
CMS not to prohibit experience from
being a qualifying factor in the selection
of collaborators on the grounds that
such a policy would compromise the
model’s stated goal of increasing quality
while reducing cost. The commenter
believed it was only appropriate to
prohibit selection criteria that consider
the historical amount of procedures (or
other services that would constitute
EPM activities) that the potential
collaborator performed for beneficiaries
treated at the EPM participant.
Several commenters expressed
concern that allowing EPM participants
discretion over the selection of
collaborators for sharing arrangements
could limit collaborators to a small
group of preferred providers and lead to
narrow referral networks to control
costs, strategies that are not necessarily
in the best interest of beneficiaries. The
commenters encouraged CMS to modify
the proposal for allowing EPM
participants broad discretion to
determine how they identify and choose
EPM collaborators. The commenters
further urged CMS to adopt stronger
safeguards and to closely monitor
referral patterns to ensure that the EPM
is not diminishing patient choice or
disrupting existing provider-patient
relationships that are necessary for
ensuring patient-centered continuity of
care. A few commenters believed that
EPM participant discretion in choosing
collaborators should be limited and that
EPM participants should be required to
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make gainsharing payments to all
providers who care for EPM
beneficiaries. One commenter requested
that CMS require EPM participants to
allow any interested provider who
meets basic, minimum quality standards
and sees a minimum number of EPM
beneficiaries to be included on the list
of collaborators with sharing
arrangements. Another commenter
requested that EPM participants’ written
policies for the selection of collaborators
be made public to promote
transparency. One commenter
emphasized that without transparent
contracting and financial data
requirements, many independent PGPs
are hesitant to participate in sharing
arrangements for episode payment
models like the EPM managed by
hospitals.
A few commenters requested that
CMS make available certain information
to EPM participants or potential
collaborators such as physician groups
and post-acute care providers. With
respect to information for EPM
participants, the commenters
recommended that CMS create a tool
with a standardized methodology to
compare costs so model participants
could select the most cost-effective
partner in the care that is included in
the models for which they are
financially responsible. Other
commenters urged CMS to provide
information to potential EPM
collaborators about hospital
accountability for episodes under the
EPM, CJR model, and other CMS
bundled payment models, explaining
that it is currently challenging for
physicians and post-acute care
providers to determine what hospital
owns which episodes in order to seek
partnerships, especially when the
hospitals may be located in other
geographic areas. One commenter
further recommended that CMS provide
a path to identify the responsible entity
for episodes in order to alleviate the
administrative burden on post-acute
care providers that are tracking financial
risk and clinical responsibility for
episodes in bundled payment models.
Response: We appreciate the
commenters’ support for our proposed
requirements for EPM participants’
policies for the selection of their
collaborators. We proposed to allow
financial arrangements in the EPM to
incentivize higher quality care and
reductions in episode spending through
improved financial alignment between
providers and suppliers furnishing
services to beneficiaries during EPM
episodes, while protecting against
undue risk from beneficiary steering,
care stinting, and inappropriate
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reductions in access to care that could
otherwise result from the financial
incentives in an episode payment
model. The proposed requirements for
the selection criteria for collaborators
provide important safeguards for these
financial arrangements.
We are mindful of the commenter’s
concern that the goals of EPM may be
more difficult to achieve if EPM
participants are prohibited from
selecting collaborators based on their
relative experience in providing services
that would constitute EPM activities.
We proposed that the written policies
for selecting EPM collaborators must
contain criteria related to, and inclusive
of, the quality of care delivered by the
potential EPM collaborator. We also
proposed that the selection criteria
cannot be based directly or indirectly on
the volume or value of past or
anticipated referrals or other business.
Because sharing arrangements should be
for the sole purpose of aligning the
parties’ financial incentives toward the
EPM goal of improving the quality and
efficiency of care, we do not believe that
collaborators should be selected in a
manner that is based on referrals or the
generation of other business. We believe
that imposing experience qualifications
that are tied to referrals, rather than
quality, presents a significant program
integrity risk. Specifically, such criteria
could be a proxy for rewarding past
referrals or for encouraging the
initiation of an excessive number of
EPM episodes. Nevertheless, depending
on the circumstances, the consideration
of a potential collaborator’s experience
in performing services that would
constitute EPM activities may further
the quality and efficiency goals of the
EPM. For example, an ACO’s experience
in providing care coordination services
or implementing care redesign strategies
may be relevant in evaluating the
likelihood that a potential ACO
collaborator will have the requisite
expertise to contribute to the EPM
participant’s success in the model.
Similarly, we recognize that, in an effort
to ensure quality of care and successful
outcomes for certain procedures, many
hospitals require physicians to perform
a reasonable minimum number of
procedures as a condition of
maintaining medical staff privileges to
perform those procedures. Therefore, we
are modifying the selection criteria
provision in § 512.500(a)(3) to provide
that a selection criterion requiring a
potential EPM collaborator to have
performed a reasonable minimum
number of services that would qualify as
EPM activities will be deemed not to
violate the volume or value standard if
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the purpose of the criterion is to ensure
the quality of care furnished to EPM
beneficiaries. We believe this standard
appropriately balances the commenter’s
concerns and the relevant program
integrity risks.
We do not agree with the commenters
recommending that EPM participants be
required to engage as collaborators all
providers and suppliers caring for EPM
beneficiaries or any interested provider
meeting minimum standards for quality
and model beneficiary volume. As
discussed previously, there is no
requirement that EPM participants enter
into sharing arrangements under the
EPM, in order to allow EPM participants
who are financially responsible for EPM
episodes the flexibility to determine
whether sharing arrangements would
advance the model goals. Should they
choose to enter into financial
arrangements with collaborators, we
believe EPM participants are in the best
position to select the collaborators,
subject to the requirements we
proposed, who are most willing to
engage in the model participant’s care
redesign strategies and provide high
quality care. However, we continue to
believe it is appropriate to require EPM
participants to create a written set of
policies for selecting providers,
suppliers, and ACOs for sharing risks
and gains as EPM collaborators. We are
adopting numerous safeguards to
address patient steering and protect
beneficiary freedom of choice, including
the requirement that EPM beneficiaries
be informed that they retain freedom of
choice to choose providers and services;
the requirement that EPM participants
not restrict beneficiaries’ ability to
choose any Medicare-enrolled provider
or supplier, or any physician or
practitioner who has opted out of
Medicare; the caps on gainsharing
payments to physicians, nonphysician
practitioners, PGPs, and NPPGPs; the
requirement that the opportunity to
make or receive gainsharing payments
(or the opportunity to make or receive
alignment payments) may not be
conditioned on the volume or value of
past or anticipated referrals; the
requirement that gainsharing payments
be distributed to EPM collaborators
substantially based on the quality of
care and the provision of EPM activities;
and the requirement that opportunity to
make or receive distribution payments
or downstream distribution payments
not be conditioned directly or indirectly
on the volume or value of past or
anticipated referrals or business
otherwise generated by, between or
among the EPM participant, any EPM
collaborator, any collaboration agent,
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any downstream collaboration agent, or
any individual or entity affiliated with
an EPM participant, EPM collaborator,
collaboration agent, or downstream
collaboration agent. In light of these
safeguards, we believe that EPM
participants should be allowed to enter
into different sharing arrangements with
various EPM collaborators. While we
appreciate the reasons why some
commenters recommended that we
require EPM participants to enter into
financial relationships with certain
entities and individuals, we do not
agree that such a requirement is
necessary given these protections.
Furthermore, we believe these
safeguards are sufficient to protect
beneficiary choice and ensure that the
EPM does not disrupt existing providerpatient relationships.
We understand and agree with the
commenters who believe that
transparency in contracting under the
EPM is important, so that providers,
suppliers, and ACOs in communities
that provide episode care for EPM
beneficiaries are knowledgeable about
any collaborators working with the EPM
participant toward achieving the model
goals and understand how the model
participant selected those collaborators.
This transparency is all the more
significant in light of our decision not
to require that EPM participants engage
with any specific providers, suppliers,
or ACOs. To the extent the commenter
who mentioned PGP concerns about the
transparency of contracting and
financial data requirements for sharing
arrangements was referring to the
internal requirements of the EPM
participant, we do not believe that
sharing arrangements under the EPM are
different in this regard from any other
scenario in which a PGP contracts with
a hospital. To address the transparency
of the EPM participant’s selection
criteria for EPM collaborators that are
required in § 512.500(a)(3), we are
requiring EPM participants to make
publicly available on the EPM
participant’s Web site their policies for
selecting individuals and entities to be
EPM collaborators and to update this
information at least quarterly. The
public availability of the collaborator
selection policies complements the
requirement for EPM participants to
publicly post on their Web site accurate
current and historical lists of all EPM
collaborators, including EPM
collaborator names and addresses, and
to update such lists on at least a
quarterly basis. The policy for the lists
of EPM collaborators is discussed in
section III.I.4.d. of this final rule for the
EPM.
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443
With regard to providing standard
information to EPM participants that
would allow them to select the most
cost-effective providers and suppliers as
collaborators, as discussed in section
III.K.2 of this final rule for EPM
participants, upon EPM participant
request we are making available
beneficiary-identifiable claims data no
less frequently than on a quarterly basis
for EPM episodes, as applicable to the
participant. These data allow the EPM
participant to examine episodes where
model beneficiaries receive care by
specific providers or suppliers in order
to identify patterns in quality and cost
that may help them identify providers
and suppliers that meet the EPM
participant’s selection criteria for
collaborators. However, we will not
provide EPM participants with a tool
that uses a standard methodology to
analyze episode costs of care to allow
for specific comparisons among
potential collaborators. Instead, EPM
participants will need to develop their
own methodology to analyze the
features of historical episodes that are
relevant to their collaborator selection
criteria.
We appreciate the interest of potential
EPM collaborators in being able to
identify the bundled payment model
episodes and responsible hospitals for
beneficiaries for whom they provide
care in order to seek partnerships that
may contribute to improvements in the
quality of episode care and reductions
in cost. We will continue to make
available on the CMS Web site
information about bundled payment
models, model participants, and the
episodes that each model participant is
testing. We encourage potential EPM
collaborators to review this information
and to discuss the potential for
collaboration with model participants
both in their communities and where
they have historically provided postdischarge care following hospitalization
for the clinical conditions that are the
focus of the EPM. Given the
complexities of the provider and
beneficiary overlap policies among
different models and programs as
discussed in section III.D.6. of this final
rule, we are not able to provide any
other specific information about the
financially responsible entity for
beneficiaries who are hospitalized and
then receive related post-discharge care
during their recovery.
We are finalizing the selection criteria
for EPM collaborators in § 512.500(a)(3)
as modified. We are finalizing in
§ 512.500(d)(1)(ii)(A) the requirement
for public reporting and updating of the
current and historical lists of EPM
collaborators in § 512.500(d)(1)(ii)(A).
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We are adding the requirement in
§ 512.500(d)(1)(ii)(B) that the EPM
participant publicly post on the EPM
participant’s Web site the written
policies for selecting individuals and
entities to be EPM collaborators
required by § 512.500(a)(3). We are
eliminating as redundant the separate
verbiage in proposed § 512.500(d)(1)(ii)
to obligate the EPM participant to
maintain accurate current and historical
lists of all EPM collaborators because
this obligation is encompassed in the
obligations to publicly post and update
such lists as required in
§ 512.500(d)(1)(ii) as finalized.
Comment: Several commenters
expressed concern about the various
‘‘volume or value’’ standards that CMS
proposed to use in the regulations for
EPM and CJR financial arrangements.
The commenters pointed out that CMS’
proposal made clear that the criteria for
the selection of collaborators and the
determination of who shall be eligible to
make or receive alignment or
gainsharing payments cannot be based
directly or indirectly on the volume or
value of past or anticipated referrals or
business otherwise generated between
the parties, their various agents, and any
individuals or entities affiliated with
them or their agents. However, the
commenters observed that the proposal
did allow for the ‘‘amount of EPM
activities’’ to be taken into account in
the methodology for calculating
gainsharing payments. With respect to
the calculation of alignment payments,
the commenters observed that CMS
proposed that EPM participants may not
‘‘directly’’ take into account the volume
or value of past or anticipated referrals,
proposing this different ‘‘volume or
value’’ standard for these payments.
One commenter believes that the
varying standards are confusing and
will have little effect on the integrity of
the models, while EPM participants and
CJR participant hospitals will need to
seek substantial legal consultation to
avoid placing themselves at risk of
whistleblower lawsuits. The commenter
requested that CMS revisit the reasoning
behind the ‘‘volume or value’’ standard
in the proposed EPM and CJR model
which they believed was imported from
the Stark law, while also taking into
account the significant safeguards built
into the models and the goal of
provider-supplier alignment with EPM
and CJR participants through financial
arrangements. At minimum, the
commenter urged CMS to streamline
and clarify the provisions that include
the ‘‘volume and value’’ standard.
Another commenter was concerned
that EPM participants and CJR
participant hospitals participants will
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avoid entering into financial
arrangements due to the fear of liability
under the Stark law and requested that
CMS clarify specifically what does and
does not constitute a violation of the
‘‘volume or value’’ standard for sharing
and distribution arrangements. The
commenter urged CMS to provide EPM
participants and CJR participant
hospitals with assurance that
compliance with the CMS standard
would not result in liability under the
fraud and abuse laws. The commenters
asserted that this would give model
participants the confidence to enter into
arrangements that will enable them to
achieve the goals of the model.
Response: We appreciate the
commenters’ interest in streamlining
and clarifying the proposed standards
for various requirements of the EPM and
CJR financial arrangements that utilize a
specific standard related to ‘‘volume or
value.’’ We proposed volume or value
standards for three things: (1) The
selection criteria for EPM collaborators;
(2) the opportunity to make or receive
a payment (gainsharing, alignment,
distribution, or downstream distribution
payment); and (3) the alignment
payment methodology. Our proposal
was designed to ensure that the sole
purpose of any financial relationships in
the CJR model and the EPM is to align
the financial incentives of the
participants, collaborators, collaboration
agents, and downstream collaboration
agents so that the models can achieve
the goals of improved episode care
quality and efficiency. For the reasons
provided later in this section, we
believe that the proposed volume or
value standard is appropriate in all
three instances.
First, we proposed in § 512.500(a)(3)
that the selection criteria for EPM
collaborators cannot be based directly or
indirectly on the volume or value of
past or anticipated referrals or business
otherwise generated by, between or
among the EPM participant, any EPM
collaborator, any collaboration agent,
any downstream collaboration agent, or
any individual or entity affiliated with
an EPM participant, EPM collaborator,
collaboration agent, or downstream
collaboration agent (‘‘affiliated
individuals or entities’’). We do not
believe it would be appropriate to
permit EPM collaborators to be selected
based on the volume or value of their
referrals to any of the enumerated
parties. Without this prohibition, such
arrangements could be used to reward
collaborators for their referrals,
including referrals for business outside
the EPM.
Second, we proposed that the
opportunity to make or receive a
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gainsharing payment, alignment
payment, distribution payment, or
downstream distribution payment could
not be conditioned on the volume or
value of past or anticipated referrals or
business otherwise generated by,
between or among the EPM participant,
any EPM collaborator, any collaboration
agent, any downstream collaboration
agent, or any affiliated individual or
entity. As with the collaborator
selection criteria, we do not believe that
a payment opportunity should be used
to reward referrals. We note that in
proposed § 512.500(c)(7) (regarding the
opportunity to make or receive a
gainsharing payment or an alignment
payment), we did not explicitly state
that the payment opportunity could not
be conditioned ‘‘directly or indirectly’’
on the volume or value of referrals or
other business. We are revising the
regulation text at § 512.500(c)(7) to
include the words ‘‘directly or
indirectly’’ before the volume or value
standard. While we do not believe this
revision effects a substantive change, we
are mindful of the commenters’ requests
to clarify and streamline all the ‘‘volume
or value’’ provisions. This change
simply clarifies that the volume or value
standard is the same in all payment
opportunity provisions.
Finally, we proposed in
§ 512.500(c)(14) that the methodology
for determining alignment payments
must not ‘‘directly’’ account for the
volume or value of past or anticipated
referrals or business otherwise
generated by, between or among the
EPM participant, any EPM collaborator,
any collaboration agent, any
downstream collaboration agent, or any
affiliated individual or entity. We
deliberately avoided proposing that
alignment payments must not ‘‘directly
or indirectly’’ account for the volume or
value of referrals or other business.
Alignment payments represent a portion
of the EPM participant’s repayment
liability to CMS, which is determined in
part by summing actual EPM episode
payments that could include payments
for some items or services referred by
the EPM collaborator. Thus, our
proposal simply recognizes that
alignment payments might indirectly
account for the volume or value of an
EPM collaborator’s referrals. The
commenters did not specifically object
to the volume or value standard in
§ 512.500(c)(14), and we are finalizing
the provision as proposed.
We did not propose a ‘‘volume or
value’’ standard for the methodologies
used to determine the amount of any
gainsharing payment, distribution
payment, or downstream distribution
payment. As we discussed in the
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proposed rule (81 FR 50923, 50926, and
50027), we proposed that these
payments must be determined in
accordance with a methodology that is
substantially based on quality of care
and the provision of EPM activities. We
further proposed that the methodology
may take into account the amount of
EPM activities provided by one EPM
collaborator, collaboration agent, or
downstream collaboration agent relative
to other EPM collaborators,
collaboration agents, or downstream
collaboration agents, as applicable to the
type of payment. We proposed this
standard because we recognized that a
‘‘volume or value’’ standard could be
interpreted to prohibit a payment
methodology that would result in higher
compensation to individuals and
entities that performed more EPM
activities (which may result in referrals)
compared to others. In response to the
commenters who questioned the need
for different standards for gainsharing
payments and alignment payments, if
the methodology for determining
alignment payments was allowed to take
into the account the amount of EPM
activities provided by an EPM
445
collaborator relative to other EPM
collaborators, there would be a
significant risk that the financial
arrangement could directly account for
the volume or value of past or
anticipated referrals or business
generated by, between or among the
EPM participant, any EPM collaborator,
any collaboration agent, any
downstream collaboration agent, or any
affiliated individual or entity.
Table 46 summarizes the applicability
of ‘‘volume or value’’ standards being
finalized in this rule for EPM financial
arrangements.
TABLE 46—FINAL STANDARDS RELATED TO ‘‘VOLUME OR VALUE’’ FOR EPM FINANCIAL ARRANGEMENTS
Scope of volume/value prohibition
Collaborator selection
criteria.
Yes .................
Opportunity to make or
receive a payment.
Yes .................
Cannot be based directly or indirectly on past or
anticipated referrals or business otherwise
generated by, between or among:
i. EPM participant
ii. Collaborator
iii. Collaboration agent
iv. Downstream collaboration agent
v. Any individual or entity affiliated with (i)–(iv)
Same as for collaborator selection criteria ..........
Alignment Payment
Methodology.
Yes .................
Gainsharing Payment
Methodology.
No ..................
Distribution and Downstream Distribution
Payment Methodologies.
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Volume/value
prohibition?
No ..................
Cannot directly account for volume or value of
past or anticipated referrals or business otherwise generated by, between or among (i)–(v)
above.
N/A—methodology must be substantially based
on quality of care and the provision of EPM
activities; may consider relative amount of
EPM activities provided.
N/A—same methodology standard as for
gainsharing payments, except that amounts
distributed by a PGP to a PGP member can
also be determined in a manner that complies
with § 411.352(g) of the physician self-referral
regulations.
Comment: Many commenters raised
concerns about the burdens of writing
EPM sharing arrangements and the
overall complexity of the requirements
for financial arrangements. Several
commenters claimed that financial
arrangements are underutilized in the
BPCI initiative due to the complexity of
CMS’ requirements, the administrative
burden associated with understanding
and ensuring compliance with those
requirements, and the lack of clearly
articulated safe harbors from the fraud
and abuse laws implicated by the
arrangements. The commenters further
asserted that few potential collaborators
have sufficient volume of cases in
episodes for the financial benefits of
gainsharing to outweigh the
administrative burdens to develop and
maintain these arrangements.
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Another commenter stated that it is
infeasible for EPM participants to write
sharing arrangements with each party
where the EPM participant will transfer
beneficiaries with AMI. The commenter
recommended that CMS institute a
default sharing arrangement which
would come into force when there is no
specific sharing arrangement between
an EPM participant and another hospital
in order to protect receiving hospitals
from the effects of adverse patient
selection that would inflate the transfer
hospital’s costs.
One commenter stated that the
structure of CJR fraud and abuse waivers
have hindered gainsharing arrangements
because of CJR participant hospitals’
concerns that they may lose waiver
protection if they miss any one of the
program requirements, including those
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Citation
§ 512.500(a)(3).
§ 512.500(c)(7) (gainsharing or alignment payments).
§ 512.505(b)(4) (distribution payment).
§ 512.510(b)(4) (downstream distribution payment).
§ 512.500(c)(14).
§ 512.500(c)(5) (gainsharing payments).
§ 512.505(b)(5), (6) (distribution payments).
§ 512.510(b)(5), (6) (downstream distribution
payments).
that the commenter believes pose no
fraud and abuse risk to any federal
health care program. The commenter
asserted that the program requirements
for sharing arrangements do not
appropriately balance CMS’ program
integrity interest with need for
meaningful change.
Response: We appreciate the feedback
of the commenters, as well as the
information provided regarding the
potential challenges associated with
constructing and executing sharing
arrangements, both in the EPM and CJR
model and other CMS efforts such as the
BPCI initiative. We understand that
parties may want to consider a number
of factors when assessing whether to
enter into a sharing arrangement,
including the number of episodes in
which the collaborator will be engaged,
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the quality measures used to measure
performance, as well as purely
contractual matters governing payment,
appeals, and termination.
With respect to the overall complexity
of the requirements for financial
arrangements in the EPM, we note, as
we discussed in the proposed rule (80
FR 50917), that in response to feedback
from participant hospitals in the CJR
model, other stakeholders, and the
general public we have made an effort
to simplify the requirements in
comparison to what was adopted for the
CJR model by removing duplication of
requirements in similar provisions;
streamlining and reorganizing many of
the provisions for clarity and
consistency; and providing additional
flexibility. We believe that these efforts
have resulted in a set of requirements
that are more accessible to EPM
participants and involved parties.
Nevertheless, we note that an EPM
participant’s decision to enter into
sharing arrangements remains
voluntary—as it is for EPM
collaborators, collaboration agents, and
downstream collaboration agents—and
as stated in the proposed rule, we
expect that all parties will carefully
consider the impact of entering into
sharing arrangements in order to align
the financial incentives of providers and
suppliers with the EPM goals of
improving the quality and efficiency of
EPM episodes.
We note that we have proposed to
exclude the term ‘‘collaborator
agreement’’ from the EPM (and to
amend the CJR model to remove this
term). We believe that dispensing with
this term and the associated mandates
for the collaborator agreements removes
an unnecessary level of regulatory
complexity and offers useful flexibilities
to parties developing their sharing
arrangements and drafting the written
agreements to memorialize those
sharing arrangements.
A desire to allow for flexibility is the
same reason we decline to develop a
default template for written agreements
to memorialize sharing arrangements, as
requested by one commenter. Given the
variation and potential complexity of
financial arrangements between EPM
participants and collaborators, we
believe that a sharing arrangement
template is more likely to be
constrictive than helpful. We would
expect that any template developed by
the agency would include provisions to
account the diversity of sharing
arrangements that could be pursed and
therefore would likely include a number
of provisions that would be inapplicable
or unnecessary for the written
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agreements in many sharing
arrangements.
Regarding the specific concern of the
commenter about the feasibility of EPM
participants writing sharing
arrangements with each party where a
hospital will transfer beneficiaries with
AMI, as discussed in section III.C.4.a.(5)
of this final rule, we are finalizing a
modification to our proposed policy and
will cancel all AMI episodes when a
beneficiary initiates an AMI episode at
the initial treating hospital and then is
transferred to another hospital for
inpatient hospital care. We believe this
revision to the proposed AMI model
episode initiation and transfer
attribution policy addresses the
concerns of the commenter by
eliminating the circumstances that
would lead an initial treating hospital to
enter into sharing arrangements with
hospitals solely because such hospitals
are receiving beneficiaries in transfer
during AMI care because the initial
treating hospital will no longer be
responsible for an AMI episode when
the beneficiary is transferred.
We emphasize that all the
requirements in §§ 512.500, 512.505,
and 512.510 for sharing arrangements,
distribution arrangements, and
downstream distribution arrangements,
respectively, are EPM programmatic
requirements. As noted previously,
fraud and abuse waivers for the EPM are
outside the scope of this rulemaking.
Comment: One commenter urged
CMS to carefully consider the impact
state law, particularly in California,
would have on providers’ ability to
participate in the proposed EPM and
allow time for agreements to be
structured so hospitals are not put at
risk for violating state law and can
maintain their relationships with
physicians. The commenter asserted
that California’s corporate practice of
medicine prohibition makes financial
alignment between EPM participants
and certain collaborators particularly
complicated because the prohibition
mandates a strict separation of hospitals
and physicians. They concluded that in
developing sharing arrangements, EPM
participants would need to undertake
careful analysis of their compliance
with both federal and state law,
including the interaction of federal and
state law requirements.
Response: We appreciate the
information provided by the commenter
about the challenges that may arise for
EPM participants developing sharing
arrangements that comply with the
requirements of the EPM and applicable
state laws. We are mindful of the time
that EPM participants may need to
prepare and put into place the sharing
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arrangements that they believe are
necessary to align their financial
incentives with those of their
collaborators toward the goal of the EPM
to improve the quality of care while
reducing its cost. Given the first
performance year of the EPM begins on
July 1, 2017, EPM participants will have
knowledge of the federal requirements
for EPM financial arrangements several
months prior to their implementation in
the EPM, which we believe is sufficient
for the early planning about these
arrangements.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposals in § 512.500(a)
for the general requirements for EPM
sharing arrangements, with modification
to clarify that an EPM collaborator
selection criterion that considers
whether a potential collaborator has
performed a reasonable minimum
number of services that would qualify as
EPM activities will be deemed not to
violate the volume or value standard if
the purpose of the criterion is to ensure
the quality of care furnished to EPM
beneficiaries. EPM sharing arrangements
must comply with the following general
provisions:
• An EPM participant may enter into
a sharing arrangement with an EPM
collaborator to make a gainsharing
payment, or to receive an alignment
payment, or both. An EPM participant
must not make a gainsharing payment or
receive an alignment payment except in
accordance with a sharing arrangement.
• A sharing arrangement must
comply with the provisions of this
section and all other applicable laws
and regulations, including the
applicable fraud and abuse laws and all
applicable payment and coverage
requirements.
• The EPM participant must develop,
maintain, and use a set of written
policies for selecting individuals and
entities to be EPM collaborators. These
policies must contain criteria related to,
and inclusive of, the quality of care
delivered by the potential EPM
collaborator. The selection criteria
cannot be based directly or indirectly on
the volume or value of past or
anticipated referrals or business
otherwise generated by, between or
among the EPM participant, any EPM
collaborator, any collaboration agent,
any downstream collaboration agent, or
any individual or entity affiliated with
an EPM participant, EPM collaborator,
collaboration agent, or downstream
collaboration agent. A selection
criterion that considers whether a
potential EPM collaborator has
performed a reasonable minimum
number of services that would qualify as
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EPM activities will be deemed not to
violate the volume or value standard if
the purpose of the criterion is to ensure
the quality of care furnished to EPM
beneficiaries
• If an EPM participant enters into a
sharing arrangement, its compliance
program must include oversight of
sharing arrangements and compliance
with the applicable requirements of the
EPM.
b. Requirements
We proposed a number of specific
requirements for sharing arrangements
to help ensure that their sole purpose
was to create financial alignment
between EPM participants and EPM
collaborators toward the goals of the
EPM while providing program integrity
safeguards. We proposed that the
sharing arrangement must be in writing,
signed by the parties, and entered into
before care was furnished to EPM
beneficiaries under the sharing
arrangement. In addition, participation
in a sharing arrangement must be
voluntary and without penalty for
nonparticipation. It would be important
that providers, suppliers, and ACOs
with ACO participants and ACO
providers/suppliers rendering items and
services to EPM beneficiaries during
EPM episodes have the freedom to
provide medically necessary items and
services to EPM beneficiaries without
any requirement that they participate in
a sharing arrangement, in order to
safeguard beneficiary freedom of choice,
access to care, and quality of care.
Similarly, we believed that if a provider,
supplier, or ACO entered into a sharing
arrangement with an EPM participant,
that sharing arrangement must precede
the provision of care to the EPM
beneficiary under the sharing
arrangement. We expected the sharing
arrangement to set out the mutually
agreeable terms for the financial
arrangement between the parties to
guide and reward EPM care redesign for
future EPM episodes, rather than reflect
the quality and financial results of EPM
episodes that had already occurred and
where the financial outcome of the
sharing arrangement terms would be
known before signing.
We proposed that the sharing
arrangement must require the EPM
collaborator and its employees,
contractors, and subcontractors to
comply with certain requirements that
would be important for program
integrity under the arrangement. We
noted that the terms contractors and
subcontractors, respectively, included
collaboration agents and downstream
collaboration agents as defined later in
this section. The sharing arrangement
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must require all of these individuals and
entities to comply with the applicable
provisions of proposed Part 512,
including requirements regarding
beneficiary notifications, access to
records, record retention, and
participation in any evaluation,
monitoring, compliance, and
enforcement activities performed by
CMS or its designees, because these
individuals and entities all would play
a role in EPM care redesign and be part
of financial arrangements under the
EPM. The sharing arrangement must
also require all of these individuals and
entities to comply with the applicable
Medicare provider enrollment
requirement at § 424.500, including
having a valid and active TIN or NPI,
during the term of the sharing
arrangement. This would be to ensure
that the individuals and entities have
the required enrollment relationship
with CMS under the Medicare program,
although we noted that they would not
be responsible for complying with
requirements that did not apply to them.
Finally, the sharing arrangement must
require individuals and entities to
comply with all other applicable laws
and regulations.
We proposed that the sharing
arrangement must not pose a risk to
beneficiary access, beneficiary freedom
of choice, or quality of care so that
financial relationships between EPM
participants and EPM collaborators did
not negatively impact beneficiary
protections under the EPM. The sharing
arrangement must require the EPM
collaborator to have a compliance
program that included oversight of the
sharing arrangement and compliance
with the requirements of the EPM, just
as we would require EPM participants
to have a compliance program for this
purpose as a program integrity
safeguard. In the proposed rule, we
noted our understanding that some
stakeholders might have interpreted the
substantially similar requirement in the
CJR model as obligating CJR
collaborators to adopt specific
compliance programs components (for
example, an externally staffed hotline to
receive complaints) and the perceived
cost of adopting those components
might be a disincentive for certain
individuals and entities to be CJR
collaborators in the CJR model.
However, we noted that the CJR
compliance program requirement did
not mandate that a CJR collaborator’s
compliance program take a particular
form or include particular components.
OIG has repeatedly and consistently
emphasized that there is no ’’one size
fits all’’ compliance program (for
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447
example, refer to OIG compliance
program guidance for Individual and
Small Group Physician Practices, 65 FR
59434, 59434–52 (October 5, 2000)).
Like OIG, we noted our understanding
of the variances and complexities
within the industry and appreciated
differences in the size and resources of
different providers and suppliers,
particularly the financial constraints on
individual physicians and nonphysician
practitioners and small PGPs.
Accordingly, we did not believe that the
compliance program requirement for
CJR collaborators as properly
understood should be a disincentive for
individuals or small PGPs to become
CJR collaborators. Thus, we proposed to
adopt a substantially similar
requirement for the EPM. We sought
comment on the anticipated effect of the
proposed compliance program
requirement for EPM collaborators,
particularly with regard to individual
physicians and nonphysician
practitioners and small PGPs, and
whether alternative compliance program
requirements for all or a subset of EPM
collaborators should be adopted to
mitigate any effect of the proposal that
could make participation as an EPM
collaborator infeasible for any provider,
supplier, or other entity on the proposed
list of types of EPM collaborators.
We observed it would be necessary
that EPM participants have adequate
oversight over sharing arrangements to
ensure that all arrangements meet the
proposed requirements of this section
and provide program integrity
protections. Therefore, we proposed that
the board or other governing body of the
EPM participant have responsibility for
overseeing the EPM participant’s
participation in the EPM, its
arrangements with EPM collaborators,
its payment of gainsharing payments, its
receipt of alignment payments, and its
use of beneficiary incentives in the
EPM.
For purposes of financial
arrangements under the EPM, we
proposed to define activities related to
promoting accountability for the quality,
cost, and overall care for EPM
beneficiaries, including managing and
coordinating care; encouraging
investment in infrastructure and
redesigned care processes for high
quality and efficient service delivery;
the provision of items and services
during an EPM episode in a manner that
reduces costs and improves quality; or
carrying out any other obligation or duty
under the EPM as ‘‘EPM activities.’’ In
addition to the quality of care provided
during episodes, we believed the
activities that would fall under this
proposed definition would encompass
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the totality of activities upon which it
would be appropriate for certain
financial arrangements under the EPM
to be based in order to value the
contributions of providers, suppliers,
and other entities toward meeting the
EPM goals of improving the quality and
efficiency of episodes. We sought
comment on the proposed definition of
EPM activities as an inclusive and
comprehensive framework for capturing
direct care and care redesign for EPM
episodes that contributed to improving
the quality and efficiency of these
episodes. We proposed to use the term
EPM activities in identifying certain
obligations of parties in a sharing
arrangement that were described as
‘‘changes in care coordination or
delivery’’ in the CJR regulations
governing the contents of the written
agreement memorializing the sharing
arrangement. We noted that as
discussed in section V.J. of the proposed
rule (81 FR 50958), we proposed to
define and use the term CJR activities in
the CJR regulations just as we proposed
to define and use the term EPM
activities in the EPM regulations.
We proposed that the written
agreement memorializing a sharing
arrangement must specify a number of
parameters of the arrangement,
including the following:
• The purpose and scope of the
sharing arrangement.
• The identities and obligations of the
parties, including specified EPM
activities and other services to be
performed by the parties under the
sharing arrangement.
• The date of the sharing
arrangement.
• Management and staffing
information, including type of
personnel or contractors that will be
primarily responsible for carrying out
EPM activities.
• The financial or economic terms for
payment, including the following:
++ Eligibility criteria for a
gainsharing payment.
++ Eligibility criteria for an
alignment payment.
++ Frequency of gainsharing or
alignment payment.
++ Methodology and accounting
formula for determining the amount of
a gainsharing payment that is
substantially based on quality of care
and the provision of EPM activities.
++ Methodology and accounting
formula for determining the amount of
an alignment payment.
Finally, we proposed to require that
the terms of the sharing arrangement
must not induce the EPM participant,
EPM collaborator, or any employees,
contractors, or subcontractors of the
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EPM participant or EPM collaborator to
reduce or limit medically necessary
services to any Medicare beneficiary or
restrict the ability of an EPM
collaborator to make decisions in the
best interests of its patients, including
the selection of devices, supplies, and
treatments. These proposed
requirements were to ensure that the
quality of care for EPM beneficiaries
would not be negatively affected by
sharing arrangements under the EPM.
The proposals for the requirements for
sharing arrangements under the EPM
were included in proposed § 512.500(b).
We sought comment about all of the
proposed requirements set out in the
preceding discussion, including
whether additional or different
safeguards would be needed to ensure
program integrity, protect against abuse,
and ensure that the goals of the EPM
were met.
The following is a summary of the
comments received and our responses.
Comment: In general, the commenters
requested that CMS simplify the
requirements for sharing arrangements
and allow gainsharing to the fullest
extent possible consistent with the goals
of preventing fraud and abuse and
unfair business practices.
One commenter asserted that the
regulations lack a clear section laying
out each and every requirement to be
included in the written agreement
memorializing the sharing arrangement.
The commenter urged CMS to set forth
in the final EPM and CJR regulations a
comprehensive list of the requirements
for the written sharing arrangement
requirements.
Some commenters urged CMS to
eliminate proposed requirements for
financial arrangements that they believe
are overly inclusive or technical. They
singled out as unnecessary the
requirement that the written agreement
memorializing the sharing arrangement
include management and staffing
information. The commenters stated
that it should be sufficient to spell out
each party’s obligations and allow
greater latitude to determine how the
management and staffing aspects of
those obligations will be met. The
commenters also identified as overly
technical and confusing the requirement
that all gainsharing payments and any
alignment payments must be
administered by the EPM participant in
accordance with generally accepted
accounting principles. The commenters
asserted this requirement does not
lessen the fraud and abuse risk posed by
any sharing arrangement.
Response: We appreciate commenters’
feedback on the requirements for
sharing arrangements. With the specific
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exceptions noted later in this section,
we continue to believe that the
requirements with respect to financial
arrangements in the EPM set forth in the
proposed rule are necessary for program
integrity purposes and to prevent the
distribution and receipt of payments for
reasons outside the goals of the EPM
and we finalize those requirements here.
We direct the commenters suggesting
that the regulations lack a clear section
laying out each and every requirement
to be included in the written agreement
memorializing the sharing arrangement
to § 512.500(b) of the regulation text,
with particular emphasis on
§ 512.500(b)(7). This subsection sets
forth the requirements for the written
agreement memorializing the sharing
arrangement. In addition to providing a
list of specifications for the written
agreement memorializing a sharing
arrangement, § 512.500(b) is intended to
offer flexibility to the parties to draft
written agreements in a format most
useful for them. We note that while
EPM participants may conclude that
additional provisions in their written
agreements are the most appropriate
tool to hold their EPM collaborators
accountable for compliance with other
programmatic requirements, we are not
mandating that EPM participants adopt
that approach.
As noted previously, we have
endeavored to streamline the
requirements for financial arrangements
under the EPM in areas where we
believe the program integrity risk is low.
As also noted previously, the removal of
the collaborator agreement
requirement—a term present in the CJR
Final Rule, not included in this final
rule—represents a result of that effort. In
addition, we agree with the commenters
who recommended that we eliminate
the requirement that the written
agreement memorializing the sharing
arrangement include management and
staffing information, including the type
of personnel or contractors that will be
primarily responsible for carrying out
EPM activities. Upon further
consideration, we believe this
requirement for the written agreement is
unnecessary as a program safeguard.
While we generally expect that EPM
participants entering into sharing
arrangements will have an EPM care
redesign plan that includes management
and staffing information, including the
types of personnel or contractors that
will be primarily be responsible for
carrying out EPM activities, we
understand that maintaining up-to-date
management and staffing information as
part of the written agreement for the
sharing arrangement could be
administratively burdensome to EPM
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participants and EPM collaborators and
reduce their flexibility to accommodate
changes in personnel or in their plans
for care redesign in response to their
cost and quality performance under the
EPM. Therefore, we are removing the
proposed requirement in
§ 512.500(b)(7)(iv) that the written
agreement include management and
staffing information. However, we
decline to remove provisions from the
set of requirements for financial
arrangements where we believe such
changes would increase the risk for
fraud and abuse or would be
inconsistent with the goals of the model.
We disagree with the commenters who
suggested that we should remove the
requirement that gainsharing payments
and alignment payments be
administered by the EPM participant in
accordance with generally accepted
accounting principles (GAAP). For
purposes of program integrity,
compliance, and monitoring, there is a
benefit to all participants across the
EPM applying a standard set of
accounting principles to these types of
payments. Thus, we decline to accept
the commenters’ suggestion to remove
this requirement.
Comment: One commenter expressed
concern about CMS’ proposal to no
longer use the term ‘‘collaborator
agreement’’ in the CJR model and to not
use this term in the EPM, although the
commenter supported CMS’ proposed
definition of a sharing arrangement and
the related requirements. They claimed
that not all collaborator agreements
would be sharing arrangements. For
example, the commenter explained that
hospitals that are EPM participants
could have agreements with their
employed physicians that cascade the
programmatic requirements of the EPM,
but do not necessarily alter the
physicians’ underlying compensation or
include the potential for gainsharing
payments. They urged CMS to retain the
term collaborator agreement, rather than
adopt the proposed change to sharing
arrangement, as the term collaborator
agreement would include both the
agreements that cascade programmatic
requirements as well as those that also
create explicit financial arrangements.
The commenter added that this
distinction is important because CMS
proposed to make a financial
arrangement a prerequisite to being
placed on the list of Affiliated
Practitioners for the determination of
Eligible Clinicians who could be
considered QPs based on services
furnished under the EPM and CJR
model. However, MACRA states that the
‘‘entity’’ must bear more than nominal
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risk to qualify for an APM incentive
payment, not the clinician. By altering
the terms used in the EPM and CJR
model to eliminate the term collaborator
agreement, the commenter concluded
that CMS was suggesting that a shift of
risk is required for a clinician to be on
the list of Affiliated Practitioners and
thus qualify for a bonus, which they
believe is inconsistent with the statute.
The commenter recommended that CMS
retain the term collaborator agreement
and clarify that the agreements do not
need to include financial arrangements
for the clinicians to be placed on the
Affiliated Practitioners list for the
determination of Eligible Clinicians for
QP determinations.
Response: We appreciate the
information provided by the commenter
on the agreements that hospitals may
develop with their employed physicians
and their support for the proposed
requirements for sharing arrangements.
However, the commenter appears to
misunderstand the existing CJR
provisions regarding collaborator
agreements. As finalized in the CJR
Final Rule (80 FR 73541), a collaborator
agreement means a written, signed
agreement between a CJR collaborator
and a participant hospital that meets the
requirements of § 510.500(c). Among
other requirements, § 510.500(c)
mandates that each collaborator
agreement ‘‘must contain a description
of the sharing arrangement between the
participant hospital and the CJR
collaborator regarding gainsharing
payments and alignment payments.’’ (81
FR 73553). Therefore, an agreement
between a CJR participant hospital and
its employed physicians to require
physicians to meet the programmatic
requirements of the CJR model that does
not also include the potential for
gainsharing payments or alignment
payments is not a collaborator
agreement. Thus, the commenter’s
assumption that maintaining the CJR
requirements for collaborator
agreements and adopting those
requirements for the EPM as a
mechanism to include clinicians
without sharing arrangements on the
Affiliated Practitioners lists for these
models is incorrect. As noted
previously, in developing the proposed
rule, we concluded that we could
streamline the CJR requirements and
adopted less burdensome requirements
for the EPM by eliminating the concept
of collaborator agreement and the
separate requirements associated with
these agreements. The example
provided by the commenter does not
meet the definition of a CJR collaborator
agreement. We continue to believe that
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449
it is appropriate under the EPM and CJR
model to focus on the requirements for
a sharing arrangement, without
imposing additional regulatory burdens
associated with a collaborator
agreement.
For discussion of the identity of the
clinicians that are reported on the
Affiliated Practitioner List for the EPM
and CJR model and the opportunity for
clinicians without financial
arrangements under the EPM and CJR
model to be included on those lists, we
refer to sections III.A.2.c. and V.O.3. of
this final rule, respectively.
Comment: A number of commenters
commended CMS for its proposal that
EPM sharing arrangements remain
voluntary and without penalty for
nonparticipation. One commenter
added that this is especially important
for those professionals that are nonpatient facing providers who do not
select their patients and whose contact,
relationship, and services furnished to a
beneficiary may occur during a short
part of the episode.
Response: We agree with the
commenters who supported the
voluntary nature of sharing
arrangements, and we continue to
believe that it is essential that sharing
arrangements be voluntary and without
penalty for nonparticipation. We are not
requiring EPM participants to offer
sharing arrangements to all providers
and suppliers caring for EPM
beneficiaries. Likewise, EPM
participants are prohibited from
coercing or requiring individuals or
entities to enter into a sharing
arrangement. EPM participants may not
penalize or discriminate against
physicians, nonphysician practitioners,
and other providers, suppliers, or ACOs
on the grounds that they are not EPM
collaborators. For example, EPM
participants may not condition the
ability of individuals or entities to
receive future referrals from the EPM
participant on the basis of EPM
collaborator status or on criteria that are
outside of the goals of the EPM
We are finalizing in § 512.500(b)(2)
that participation in sharing
arrangements be voluntary and without
penalty for nonparticipation.
Comment: Several commenters
expressed concerns about the level of
control given to EPM participants over
the amount of gainsharing payments
and their allocation, urging CMS to
modify its proposal to require greater
input from collaborators on the
methodology for sharing payments and
to provide additional safeguards to
ensure continued beneficiary choice of
providers and fairness to providers.
Specifically, they recommended that
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providers who furnished services to
EPM beneficiaries should be part of
decision-making regarding the amount
and allocation of gainsharing payments.
The commenters suggested that
providers furnishing a minimum
percentage of EPM services should be
required to be part of the EPM
participant governance structure that
develops written policies for
collaborators and the sharing
arrangement methodologies. The
commenters urged CMS to establish a
maximum amount of reconciliation
payments that hospitals may keep and
a minimum amount of gainsharing
payments that must be paid to each
collaborator. They concluded that these
modifications would strengthen
beneficiary choice and promote fairness.
Response: We appreciate the interest
of the commenters in engagement of
providers furnishing care to EPM
beneficiaries in decision-making
regarding gainsharing payment
methodologies. As we discuss in our
responses to other comments, as the
financially responsible entities for EPM
episodes, we believe that EPM
participants should have as much
flexibility as possible, subject to
adequate program integrity safeguards,
in decisions about financial
arrangements, including whether or not
to enter into them; the selection of
collaborators; and the methodologies for
determining the amounts of gainsharing
payments and alignment payments. We
do not believe it would be appropriate
to specify certain membership of the
board or other governing body that we
proposed to require an EPM participant
to charge with responsibility for the
EPM participant’s participation in the
EPM; its arrangements with EPM
collaborators; its payment of gainsharing
payments; its receipt of alignment
payments; and its use of beneficiary
incentives in the EPM. We expect that
EPM participants will establish a board
or other governing body with sufficient
expertise to provide responsible
oversight of those activities.
We have included safeguards in this
final rule to protect beneficiary freedom
of choice, to require that the potential
for financial gain under EPM financial
arrangements be based on activities for
EPM beneficiaries that are focused on
the goals of the EPM to improve quality
and reduce the cost of care, and to limit
the potential for undue financial gain by
certain providers under the EPM. These
safeguards include the requirement that
EPM beneficiaries be informed that they
retain freedom of choice to choose
providers and services; the requirement
that EPM participants not restrict
beneficiaries’ ability to choose any
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Medicare-enrolled provider or supplier,
or any physician or practitioner who has
opted out of Medicare; the cap on
gainsharing payments to physicians,
nonphysician practitioners, PGPs, and
NPPGPs; the requirement that EPM
collaborator selection must be based on
written policies that contain criteria
related to, and inclusive of, the quality
of care delivered by the potential EPM
collaborator and cannot be based
directly or indirectly on the volume or
value of past or anticipated referrals; the
requirements that the opportunity to
make or receive gainsharing payments,
alignment payments, distribution
payments, and downstream distribution
payments may not be conditioned
directly or indirectly on the volume or
value of past or anticipated referrals or
business otherwise generated by,
between or among the EPM participant,
any EPM collaborator, any collaboration
agent, any downstream collaboration
agent, or any individual or entity
affiliated with an EPM participant, EPM
collaborator, collaboration agent, or
downstream collaboration agent; and
the requirements that the amount of any
gainsharing payments and, with limited
exceptions, any distribution payments
and downstream distribution payments
be determined in accordance with a
methodology that is substantially based
on the quality of care and the provision
of EPM activities. We believe these
safeguards are sufficient to protect
beneficiary choice and ensure that
providers, suppliers, and ACOs that are
EPM collaborators, collaboration agents,
or downstream collaboration agents
receive payments that are based on
quality of care and activities specifically
related to promoting accountability for
the quality, cost, and overall care for
EPM beneficiaries, including managing
and coordinating care; encouraging
investment in infrastructure; enabling
technologies, and redesigned care
processes for high quality and efficient
service delivery; the provision of items
and services during an EPM episode in
a manner that reduces costs and
improves quality; or carrying out any
other obligation or duty under the EPM.
Comment: One commenter
recommended that CMS enable
individuals and entities, such as small
PGPs, to participate in the EPM as
collaborators without requiring major
investments in infrastructure and
electronic health records. The
commenter urged CMS to provide
appropriate resources and support to
enable small practices to participate.
They further requested that CMS
monitor activities involving distribution
of payment to guard against unfair
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business practices and to promote a fair
and equitable distribution of
gainsharing payments to all providers
who are involved as collaborators.
Finally, the commenter urged CMS to
mandate distribution of gainsharing
payments to EPM collaborators in a
timely fashion.
Response: It is our intent that the
models offer opportunities for providers
and suppliers of all sizes to be EPM
collaborators, provided they meet the
criteria in this final rule. We note that
the EPM does not include requirements
for certain infrastructure or use of
electronic health records. While we
currently do not plan to provide specific
resources targeted to providers,
suppliers, and ACOs engaged in sharing
arrangements with EPM participants, we
will broadly disseminate to the public
information that may be useful to model
collaborators throughout
implementation of the EPM.
In response to the commenters’ desire
to ensure that gainsharing payments are
distributed fairly and equitably to EPM
collaborators, as noted previously, we
believe that the provisions of this final
rule adequately address this point. We
appreciate the commenter’s concern
about the potential for unfair business
practices, but the regulation of such
practices is outside the scope of our
authority. Accordingly, we will not add
a prohibition against unfair business
practices. However, we believe that
many of the program integrity
provisions for sharing arrangements will
also serve to deter unfair business
practices, and we will be monitoring
compliance with these requirements.
Regarding the timely distribution of
gainsharing payments, we require that
gainsharing payments be distributed on
an annual basis. As discussed
previously, we are not requiring EPM
participants to enter into sharing
arrangements with all providers and
suppliers caring for EPM beneficiaries,
but where an EPM participant does
enter into one or more sharing
arrangements, the model participant
must not distribute any gainsharing
payments more than once per year. We
believe that this requirement ensures
that gainsharing payments are timed to
sufficiently maintain an EPM
collaborator’s commitment to lowering
costs and improving quality of care. To
the extent the commenter was
requesting that CMS prohibit late
payment of amounts owed to EPM
collaborators, we believe that the
consequences for breach of contract
offer sufficient protection.
Comment: Many commenters
expressed strong support for CMS’
proposal to adopt the terms EPM
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activities and CJR activities to describe
activities in support of the goals of the
models, as well as CMS’ proposed
approach of utilizing these definitions
as the comprehensive framework for
capturing both direct patient care and
care redesign for EPM and CJR episodes.
Several commenters also supported
CMS’ proposal that the methodology for
determining gainsharing payments may
take into account the amount of EPM or
CJR activities provided by an EPM or
CJR collaborator relative to other EPM or
CJR collaborators, and the application of
this same standard to distribution
payments and downstream distribution
payments. One commenter commended
CMS for recognizing that risk-sharing
between EPM participants and CJR
participant hospital and their
collaborators should involve more
elasticity by accounting for the effects of
the collaborator’s overall participation
and involvement. Another commenter
claimed that this approach would
provide EPM participants and CJR
participant hospitals greater flexibility
to incentivize care redesign by allowing
more actively involved physicians who
participate in care redesign to receive
higher gainsharing payments as
compared to physicians that may only
care for a few model beneficiaries and
may not be actively involved in care
redesign. One commenter recommended
that CMS should add to the definitions
of EPM activities and CJR activities a
consideration of the long-term patient
experience and outcomes to ensure that
these definitions do not undermine
consideration of decisions that
potentially impact long-term value
beyond the episode.
Response: We appreciate the
commenters’ support for our proposal to
adopt the terms EPM activities and CJR
activities and to use these as a
framework for capturing items and
services furnished directly to
beneficiaries in the EPM and CJR model
and care redesign efforts for EPM
episodes and CJR episodes. We also
appreciate the commenters’ support for
our proposal that the methodology for
determining gainsharing payments may
take into account the amount of EPM
activities or CJR activities provided by
an EPM collaborator or CJR collaborator
relative to other EPM collaborators or
CJR collaborators, and the use of this
same standard for distribution payments
and downstream distribution payments.
We agree with the commenters that this
standard provides important flexibility
for EPM participants and CJR
participant hospitals to more effectively
align the financial incentives of
providers, suppliers, and ACO with the
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goals of the EPM and CJR model to
improve the quality of care and reduce
the cost of episode care by allowing
financial arrangements to account for
the level of the collaborator,
collaboration agent, or downstream
collaboration agent’s overall
participation and involvement in
beneficiary care and care redesign.
While we appreciate the interest of
the commenter who sought to ensure
that care redesign under the EPM and
CJR model does not lead to care
pathways that may negatively impact
long-term patient experience and
outcomes, we do not believe it would be
appropriate to add consideration of
long-term patient experience and
outcomes to the definition of EPM
activities and CJR activities. The goals of
the EPM and CJR model are focused on
the quality and efficiency of episode
care and, therefore, we believe that the
definition of EPM activities and CJR
activities that are part of the basis for
payments under financial arrangements
in the EPM and CJR model should
include only those activities related to
the immediate goals of the EPM and CJR
model. However, as discussed in section
IV. of this final rule, the evaluation of
the EPM, like the evaluation of the CJR
model (80 FR 73528 through 73530),
will examine the impact of the EPM on
outcomes and quality, including during
the period following the end of episodes
and on measures of relevant long-term
quality.
We are finalizing in § 512.2 the
definition of EPM activities and use that
term throughout the regulations for EPM
financial arrangements.
Comment: A commenter requested
that CMS provide additional guidance
on the compliance program required for
EPM collaborators. The commenter
expressed appreciation for the
discussion in the proposed rule that a
collaborator’s compliance program need
not take any one particular form and
further, that there is no ‘‘one size fits
all’’ compliance program. However, the
commenter stated that the requirement
that an EPM collaborator include
oversight of not only the sharing
arrangement, but compliance with the
requirements of the entire EPM, is a
large undertaking for any one
collaborator, let alone a collaborator
who is a solo practitioner. The
commenter urged CMS to consider the
practical implications of this
compliance program requirement in the
event an EPM participant contracts with
a physician individually, and that
physician is also a member of a PGP that
is not an EPM collaborator.
Response: We appreciate the interest
of the commenter in the implication of
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451
the proposed requirement for an EPM
collaborator to have a compliance
program, particularly for collaborators
who are individuals. In our proposed
requirements for sharing arrangements,
we proposed in § 512.500(b)(4) that the
sharing arrangement must require the
EPM collaborator to have a compliance
program that includes oversight of the
sharing arrangement and compliance
with the requirements of the EPM. Any
individual or entity that wants the
benefits of becoming a collaborator must
also accept the responsibility to ensure
that its collaboration complies with the
requirements of the EPM. The proposal
requires that each collaborator
implement mechanisms to promote
compliance, while giving each
collaborator the discretion to determine
which mechanisms are appropriate for
that individual or entity. Our intent is
to require the EPM collaborator’s
compliance program to monitor its own
conduct and relationships only, in
contrast with policing independent,
third parties with whom it does not
have any direct relationship. The goal is
for the EPM collaborator’s compliance
efforts to look not just at its financial
relationship with the EPM participant
but at the collaborator’s overall
compliance with the requirements of the
model (for example, collaborator
performance of clinical care under the
model; the propriety of any distribution
arrangements). Moreover, we believe
that the requirement for a collaborator to
have a compliance program should not
be understood as requiring each
collaborator to independently maintain
a separate compliance program, but
rather that every collaborator must be
covered by a compliance program that
includes the required oversight. For
example, it may not be practical for each
member of a PGP to separately maintain
his or her own compliance program.
However, the EPM requirement could
still be met if the PGP has a compliance
program that covers the PGP member
and that includes oversight of the PGP
member’s sharing arrangement and the
PGP member’s compliance with the
requirements of the model.
Therefore, while we continue to
believe that it is appropriate to require
all EPM collaborators, including
individual practitioners, to be covered
by a compliance program that includes
oversight of the sharing arrangement, we
are clarifying that the collaborator’s
obligations may be met if the
collaborator either has or is covered by
a compliance program that includes the
appropriate oversight of the
collaborator, and that the requirements
of the EPM that are relevant for the EPM
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collaborator’s compliance program are
those requirements of the EPM that
apply to its role as an EPM collaborator,
including any distribution
arrangements, rather than all
requirements of the entire model.
We are finalizing in § 512.500(b)(4)
that the EPM collaborator must have or
be covered by a compliance program
that includes oversight of the sharing
arrangement and compliance with the
requirements of the EPM that apply to
its role as an EPM collaborator,
including any distribution
arrangements.
Comment: Several commenters
requested clarification about the timing
for entering into sharing arrangements,
distribution arrangements, or
downstream distribution arrangements
with respect to EPM episodes in view of
CMS’ proposals that the three types of
arrangements must be in writing and
signed by the parties, and entered into
before care is furnished to EPM
beneficiaries under the applicable
arrangement. One commenter further
inquired about whether a sharing
arrangement needs to be signed prior to
an episode beginning in order for an
EPM collaborator to receive a
gainsharing payment for savings
associated with the episode or whether
it is also possible for a collaborator to
receive a gainsharing payment for
savings associated with the episode if
the sharing arrangement is signed prior
to an episode ending.
Response: We appreciate the need to
understand when ‘‘care is furnished to
EPM beneficiaries under the applicable
arrangement’’ in order to ensure that
execution of the written agreements is
timely. A sharing arrangement,
distribution arrangement, or
downstream distribution arrangement
requires that the amount of a
gainsharing payment, distribution
payment, or downstream distribution
payment to an EPM collaborator,
collaboration agent, or downstream
collaboration agent, respectively be
determined in accordance with a
methodology that is substantially based
on the quality of care and the provision
of EPM activities, which by definition
must be for EPM beneficiaries during
EPM episodes. EPM activities include,
but are not limited to, billable items and
services furnished to EPM beneficiaries
during EPM episodes. Therefore, ‘‘care
is furnished to EPM beneficiaries under
the applicable arrangement’’ when the
individual or entity in the financial
arrangement (or designee to the extent
permitted by regulation) first provides
EPM activities that may be considered
in the methodology for determining the
amount of the applicable payment.
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Accordingly, the written agreement
memorializing the sharing arrangement,
distribution arrangement, or
downstream distribution arrangement
must have been signed by the parties
and entered into before the date the first
EPM activities that may be considered
in the methodology for determining the
applicable payment amount are
provided.
We note that once a sharing
arrangement is signed by an EPM
collaborator in a performance year, there
is no restriction for that performance
year on the timing of the specific
episodes that result in savings that can
be paid to the EPM collaborator as a
gainsharing payment. According to our
requirements in § 512.500(b)(2), to be
eligible to receive a gainsharing
payment, an EPM collaborator must
meet quality of care criteria for the
performance year for which the EPM
participant accrued the internal cost
savings or earned the reconciliation
payment that comprises the gainsharing
payment, as well as meet the other
criteria specific to the type of
collaborator, namely directly furnished
an item or service to an EPM beneficiary
during an EPM episode; billed for an
item or service that was rendered by one
or more PGP member, NPPGP member,
or TGP member respectively to an EPM
beneficiary during an EPM episode,
contributed to EPM activities, and been
clinically involved in the care of EPM
beneficiaries; or had an ACO provider/
supplier that directly furnished, or an
ACO participant that billed for, an item
or service that was rendered to an EPM
beneficiary during an EPM episode,
contributed to EPM activities, and been
clinically involved in the care of EPM
beneficiaries during the same
performance year for which the EPM
participant accrued the internal cost
savings or earned the reconciliation
payment that comprises the gainsharing
payment.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposals in § 512.500(b)
for the requirements for EPM sharing
arrangements, with modification to
specify that the EPM collaborator must
have or be covered by a compliance
program which must include oversight
of the sharing arrangement and
compliance with the requirements of the
EPM that apply to its role as an EPM
collaborator, including any distribution
arrangements. We are also modifying
our proposal as discussed previously
and removing the requirement that the
written agreement memorializing a
sharing arrangement include
management and staffing information, a
change which results in renumbering
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proposed § 512.500(b)(7)(v) (requiring
the financial or economic terms for
payment be specified in the written
agreement about the sharing
arrangement) to § 512.500(b)(7)(iv). EPM
sharing arrangements must meet the
following general requirements:
• A sharing arrangement must be in
writing and signed by the parties, and
entered into before care is furnished to
EPM beneficiaries under the sharing
arrangement.
• Participation in a sharing
arrangement must be voluntary and
without penalty for nonparticipation.
• The sharing arrangement must
require the EPM collaborator and its
employees, contractors (including
collaboration agents), and
subcontractors (including downstream
collaboration agents) to comply with the
following:
++ The applicable provisions of this
part (including requirements regarding
beneficiary notifications, access to
records, record retention, and
participation in any evaluation,
monitoring, compliance, and
enforcement activities performed by
CMS or its designees);
++ All applicable Medicare provider
enrollment requirements at § 424.500 of
this chapter, including having a valid
and active TIN or NPI, during the term
of the sharing arrangement; and
++ All other applicable laws and
regulations.
• The sharing arrangement must
require the EPM collaborator to have or
be covered by a compliance program
that includes oversight of the sharing
arrangement and compliance with the
requirements of the EPM that apply to
its role as an EPM collaborator,
including any distribution
arrangements.
• The sharing arrangement must not
pose a risk to beneficiary access,
beneficiary freedom of choice, or quality
of care.
• The board or other governing body
of the EPM participant must have
responsibility for overseeing the EPM
participant’s participation in the EPM,
its arrangements with EPM
collaborators, its payment of gainsharing
payments, its receipt of alignment
payments, and its use of beneficiary
incentives in the EPM.
• The written agreement
memorializing a sharing arrangement
must specify the following:
++ The purpose and scope of the
sharing arrangement.
++ The identities and obligations of
the parties, including specified EPM
activities and other services to be
performed by the parties under the
sharing arrangement;
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++ The date of the sharing
arrangement.
++ The financial or economic terms
for payment, including the following:
—Eligibility criteria for a gainsharing
payment.
—Eligibility criteria for an alignment
payment.
—Frequency of gainsharing or
alignment payment.
—Methodology and accounting formula
for determining the amount of a
gainsharing payment that is
substantially based on quality of care
and the provision of EPM activities.
—Methodology and accounting formula
for determining the amount of an
alignment payment.
• The sharing arrangement must
not—
++ Induce the EPM participant, EPM
collaborator, or any employees,
contractors, or subcontractors of the
EPM participant or EPM collaborator to
reduce or limit medically necessary
services to any Medicare beneficiary; or
++ Restrict the ability of an EPM
collaborator to make decisions in the
best interests of its patients, including
the selection of devices, supplies, and
treatments.
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c. Gainsharing Payment, Alignment
Payment, and Internal Cost Savings
Conditions and Restrictions
We proposed a number of conditions
and limitations for gainsharing
payments, alignment payments, and
internal cost savings as program
integrity protections for the payments to
and from EPM collaborators. We
proposed to require that gainsharing
payments be derived solely from
reconciliation payments, internal costs
savings, or both; that they be distributed
on an annual basis, not more than once
per calendar year; that they not be a
loan, advance payment, or payment for
referrals or other business; and that they
be clearly identified as a gainsharing
payment at the time they are paid.
In the proposed rule, we discussed
our belief that gainsharing payment
eligibility for EPM collaborators should
be conditioned on two requirements—
(1) meeting quality of care criteria; and
(2) rendering items and services to EPM
beneficiaries during EPM episodes—as
safeguards to ensure that eligibility for
gainsharing payments would be solely
based on aligning financial incentives
for EPM collaborators with the EPM
goals of improving EPM episode quality
and efficiency. With respect to the first
requirement, we proposed that to be
eligible to receive a gainsharing
payment, an EPM collaborator must
meet quality of care criteria for the
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performance year for which the EPM
participant accrued the internal cost
savings or earned the reconciliation
payment that comprised the gainsharing
payment. The quality of care criteria
that would be established by the EPM
participant must be directly related to
EPM episodes. With regard to the
second requirement, which is also
applicable to being required to make an
alignment payment, we proposed
different criteria depending on the type
of collaborator involved. We proposed
that to be eligible to receive a
gainsharing payment, an EPM
collaborator other than a PGP or an ACO
must have directly furnished a billable
item or service to an EPM beneficiary
during an EPM episode that occurred in
the same performance year for which
the EPM participant accrued the
internal cost savings or earned the
reconciliation payment that comprised
the gainsharing payment or was
assessed a repayment amount. For
purposes of this requirement, we
considered a collaborator that is a
hospital, CAH, or post-acute care
provider to have ‘‘directly furnished’’ a
billable service if one of these entities
billed for an item or service for an EPM
beneficiary during an EPM episode that
occurred in the same performance year
for which the EPM participant accrued
the internal cost savings or earned the
reconciliation payment that comprised
the gainsharing payment or was
assessed a repayment amount. We
explained that the phrase ‘‘performance
year for which the EPM participant
accrued the internal cost savings or
earned the reconciliation payment that
comprised the gainsharing payment or
was assessed a repayment amount’’ did
not mean the year in which the
gainsharing payment was made. These
proposed requirements would ensure
that there is a required relationship
between eligibility for a gainsharing
payment and the quality of direct care
for EPM beneficiaries during EPM
episodes for these EPM collaborators.
We believed the provision of direct care
was essential to the implementation of
effective care redesign, and the
requirement would provide a safeguard
against payments to EPM collaborators
other than a PGP or an ACO that were
unrelated to direct care for EPM
beneficiaries during EPM episodes.
We proposed to establish variations
on this requirement for PGPs and ACOs
because these entities do not themselves
directly furnish billable services. We
proposed that for a PGP to be eligible to
receive a gainsharing payment or
required to make an alignment payment,
the PGP must have billed for an item or
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453
service that was rendered by one or
more members of the PGP to an EPM
beneficiary during an EPM episode that
occurred during the same performance
year for which the EPM participant
accrued the internal cost savings or
earned the reconciliation payment that
comprised the gainsharing payment or
was assessed a repayment amount. We
proposed that for an ACO to be eligible
to receive a gainsharing payment or
required to make an alignment payment,
the ACO must have had an ACO
provider/supplier that directly
furnished, or an ACO participant that
billed for, an item or service that was
rendered to an EPM beneficiary during
an EPM episode that occurred during
the same performance year for which
the EPM participant accrued the
internal cost savings or earned the
reconciliation payment that comprised
the gainsharing payment or was
assessed a repayment amount. With
respect to ACOs, we proposed that an
‘‘ACO participant’’ and ‘‘ACO provider/
supplier’’ have the meaning set forth in
§ 425.20 of regulations. Thus, these
proposed variations on the requirements
for other collaborator types also
required a linkage between the EPM
collaborator that is the PGP or ACO and
the provision of items and services to
EPM beneficiaries during EPM episodes
by PGP members or ACO participants or
ACO providers/suppliers, respectively.
Moreover, we further proposed that
because PGPs and ACOs do not directly
furnish items and services to
beneficiaries, in order to be eligible to
receive a gainsharing payment or be
required to make an alignment payment,
the PGP or ACO must have contributed
to EPM activities and been clinically
involved in the care of EPM
beneficiaries during the same
performance year for which the EPM
participant accrued the internal cost
savings or earned the reconciliation
payment that comprised the gainsharing
payment or was assessed a repayment
amount. For example, a PGP or ACO
might have been clinically involved in
the care of EPM beneficiaries by
providing care coordination services to
EPM beneficiaries during and/or after
inpatient admission; engaging with an
EPM participant in care redesign
strategies, and actually performing a
role in implementing such strategies
that were designed to improve the
quality of care for EPM episodes and
reduce EPM episode spending; or in
coordination with providers and
suppliers (such as members of the PGP,
ACO participants, ACO providers/
suppliers, the EPM participant, and
post-acute care providers),
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implementing strategies designed to
address and manage the comorbidities
of EPM beneficiaries.
Because internal cost savings might be
shared through gainsharing payments
with EPM collaborators, we proposed
certain requirements for their
calculation as a program integrity
safeguard. First, the methodology for
accruing, calculating and verifying
internal cost savings must be
transparent, measurable, and verifiable
in accordance with generally accepted
accounting principles (GAAP) and
Government Auditing Standards (The
Yellow Book). Second, because we
believed it would be necessary that the
internal cost savings reflect care
redesign under the EPM in order to be
eligible to be shared through
gainsharing payments, the methodology
used to calculate internal cost savings
must reflect the actual, internal cost
savings achieved by the EPM participant
through the documented
implementation of EPM activities
identified by the EPM participant and
must exclude any savings realized by
any individual or entity that was not the
EPM participant and ‘‘paper’’ savings
from accounting conventions or past
investment in fixed costs. In the
proposed rule, we noted that, unlike the
current CJR model policy where we
require that sharing arrangements
document the methodology for accruing,
calculating, and verifying the internal
cost savings generated by the participant
hospital based on the care redesign
elements specifically associated with
the particular collaborator (80 FR
73431), we did not propose to require in
the EPM that the calculation of internal
cost savings be tied to the activities of
any specific EPM collaborator. Rather,
we believed it would be appropriate for
EPM participants to calculate internal
cost savings based on the
implementation of EPM activities and
then provide gainsharing payments to
EPM collaborators that might include
internal cost savings, reconciliation
payments, or both based on a
methodology that met the requirements
described later in this section. We
proposed this same change to the
internal cost savings calculation
requirements for the CJR model in
section V.J. of the proposed rule (81 FR
50961).
We proposed to limit the total amount
of gainsharing payments for a
performance year to EPM collaborators
that were physicians, nonphysician
practitioners, or PGPs. For EPM
collaborators that were physicians or
nonphysician practitioners, that
proposed limit was 50 percent of the
Medicare-approved amounts under the
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PFS for items and services furnished by
that physician or nonphysician
practitioner to the EPM participant’s
EPM beneficiaries during EPM episodes
that occurred during the same
performance year for which the EPM
participant accrued the internal cost
savings or earned the reconciliation
payment that comprised the gainsharing
payment being made. For EPM
collaborators that were PGPs, the
proposed limit was 50 percent of the
Medicare-approved amounts under the
PFS for items and services billed by the
PGP and furnished to the EPM
participant’s EPM beneficiaries by
members of the PGP during EPM
episodes that occurred during the same
performance year for which the EPM
participant accrued the internal cost
savings or earned the reconciliation
payment that comprised the gainsharing
payment being made. These proposed
limits were consistent with those in the
CJR model (80 FR 73430).
We proposed that the amount of any
gainsharing payments must be
determined in accordance with a
methodology that was substantially
based on quality of care and the
provision of EPM activities. The
methodology could take into account
the amount of such EPM activities
provided by an EPM collaborator
relative to other EPM collaborators.
While we emphasized in the proposed
rule that financial arrangements may not
be conditioned directly or indirectly on
the volume or value of past or
anticipated referrals or business
otherwise generated by, between or
among the EPM participant, any EPM
collaborator, any collaboration agent,
any downstream collaboration agent, or
any individual or entity affiliated with
an EPM participant, EPM collaborator,
collaboration agent, or downstream
collaboration agent so that their sole
purpose was to align the financial
incentives of the EPM participant and
EPM collaborators toward the EPM goals
of improved EPM episode care quality
and efficiency, we believed that
accounting for the relative amount of
EPM activities by EPM collaborators in
the determination of gainsharing
payments did not undermine this
objective. Rather, the proposed
requirement would allow flexibility in
the determination of gainsharing
payments where the amount of an EPM
collaborator’s provision of EPM
activities (including direct care) to EPM
beneficiaries during EPM episodes
might contribute to both the internal
cost savings and EPM participant’s
reconciliation payment that might be
available for making a gainsharing
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payment. Greater contributions of EPM
activities by one EPM collaborator
versus another EPM collaborator that
resulted in greater differences in the
funds available for gainsharing
payments could be appropriately valued
in the methodology used to make
gainsharing payments to those EPM
collaborators in order to reflect these
differences in EPM activities among
EPM collaborators. For example, a
physician who was an EPM collaborator
who treated 100 EPM beneficiaries
during EPM episodes that resulted in
high quality, less costly care could
receive a larger gainsharing payment
than a physician who was an EPM
collaborator who treated 10 EPM
beneficiaries during episodes that
similarly resulted in high quality, less
costly care.
However, we did not believe it would
be appropriate to allow the selection of
EPM collaborators or the opportunity to
make or receive a gainsharing payment
or an alignment payment to take into the
account the amount of EPM activities
provided by a potential or actual EPM
collaborator relative to other potential or
actual EPM collaborators because these
financial relationships were not to be
based directly or indirectly on the
volume or value of past or anticipated
referrals or business otherwise
generated by, between or among the
EPM participant, any EPM collaborator,
any collaboration agent, any
downstream collaboration agent, or any
individual or entity affiliated with an
EPM participant, EPM collaborator,
collaboration agent, or downstream
collaboration agent. Specifically, with
respect to the selection of EPM
collaborators or the opportunity to make
or receive a gainsharing payment or an
alignment payment, we did not believe
that the amount of EPM activities
provided by a potential or actual EPM
collaborator relative to other potential or
actual EPM collaborators could be taken
into consideration by the EPM
participant without a significant risk
that the financial arrangement in those
instances could be based directly or
indirectly on the volume or value of
past or anticipated referrals or business
generated by, between or among the
parties. Similarly, if the methodology
for determining alignment payments
was allowed to take into the account the
amount of EPM activities provided by
an EPM collaborator relative to other
EPM collaborators there would be a
significant risk that the financial
arrangement could directly account for
the volume or value of past or
anticipated referrals or business
generated by, between or among the
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parties and, therefore, we proposed that
the methodology for determining
alignment payments could not directly
take into account the volume or value of
past or anticipated referrals or business
generated by, between or among the
parties.
We proposed a change to this same
standard for gainsharing payments
under the CJR model as discussed in
section V.J. of the proposed rule (81 FR
50961 through 50962). We sought
comment on this proposal for
gainsharing payments, where the
methodology may take into account the
amount of EPM activities provided by
an EPM collaborator relative to other
EPM collaborators. We were particularly
interested in comments about whether
this standard would provide sufficient
additional flexibility in the gainsharing
payment methodology to allow the
financial reward of EPM collaborators
commensurate with their level of effort
that achieved improvements in EPM
episode quality and efficiency. In
addition, we were interested in
comments on whether additional
safeguards or a different standard was
needed to allow for greater flexibility to
provide certain performance-based
payments consistent with the goals of
program integrity, protecting against
abuse and ensuring the goals of the EPM
were met.
We proposed that for a performance
year, the aggregate amount of all
gainsharing payments that were derived
from a reconciliation payment must not
exceed the amount of the reconciliation
payment the EPM participant received
from CMS. In accordance with the prior
discussion, no entity or individual,
whether a party to a sharing
arrangement or not, may condition the
opportunity to make or receive
gainsharing payments or to make or
receive alignment payments on the
volume or value of past or anticipated
referrals or business otherwise
generated by, between or among the
EPM participant, any EPM collaborator,
any collaboration agent, any
downstream collaboration agent, or any
individual or entity affiliated with an
EPM participant, EPM collaborator,
collaboration agent, or downstream
collaboration agent. We proposed that
an EPM participant must not make a
gainsharing payment to an EPM
collaborator that was subject to any
action for noncompliance with this part
or the fraud and abuse laws, or for the
provision of substandard care in EPM
episodes or other integrity problems.
Finally, we proposed that the sharing
arrangement must require the EPM
participant to recoup any gainsharing
payment that contained funds derived
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from a CMS overpayment on a
reconciliation report or was based on
the submission of false or fraudulent
data. These requirements would provide
program integrity safeguards for
gainsharing under sharing
arrangements.
With respect to alignment payments,
we proposed that alignment payments
from an EPM collaborator to an EPM
participant may be made at any interval
that was agreed upon by both parties.
They must not be issued, distributed, or
paid prior to the calculation by CMS of
a repayment amount reflected in a
reconciliation report; loans, advance
payments, or payments for referrals or
other business; or assessed by an EPM
participant if it did not owe a repayment
amount. The EPM participant must not
receive any amounts under a sharing
arrangement from an EPM collaborator
that were not alignment payments.
We also proposed certain limitations
on alignment payments that were
consistent with the CJR model (80 FR
73430). For a performance year, we
proposed that the aggregate amount of
all alignment payments received by the
EPM participant must not exceed 50
percent of the EPM participant’s
repayment amount. Given that the EPM
participant would be responsible for
developing and coordinating care
redesign strategies in response to its
EPM participation, we believed it was
important that the participant retain a
significant portion of its responsibility
for repayment to CMS. For example,
upon receipt of a reconciliation report
indicating that the EPM participant
owed $100 to CMS, the EPM participant
would be permitted to receive no more
than $50 in alignment payments, in the
aggregate, from its EPM collaborators. In
addition, we proposed that the aggregate
amount of all alignment payments from
an EPM collaborator to the EPM
participant may not be greater than 25
percent of the EPM participant’s
repayment amount for an EPM
collaborator that was not an ACO and 50
percent of the EPM participant’s
repayment amount for an EPM
collaborator that was an ACO. We
proposed to allow a higher percentage of
the EPM participant’s repayment
amount to be paid by an ACO than by
EPM collaborators that were not ACOs
in recognition that some ACOs are
sizable organizations with significant
financial and other resources. In
addition, their expertise in managing
the cost and quality of care for Medicare
beneficiaries over a period of time may
make some ACOs uniquely capable of
sharing a higher percentage of downside
risk under the EPM with the EPM
participant under a sharing arrangement
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455
between the ACO and EPM participant
that met all requirements for such
arrangements, including that
participation in the sharing arrangement
must be voluntary and without penalty
for nonparticipation as discussed
previously. We sought comment on our
proposed aggregate and individual EPM
collaborator limitations on alignment
payments, and particularly on the
proposed limitation that would apply to
ACOs that are EPM collaborators.
The following examples in the
proposed rule illustrated the effects of
the proposed limitations on alignment
payments. In one scenario, upon receipt
of a reconciliation report indicating that
the EPM participant owed $100 to CMS,
the EPM participant would be permitted
to receive no more than $25 in an
alignment payment from a single entity
or individual that was one of the EPM
participant’s EPM collaborators that was
not an ACO. In the second scenario
where an ACO was an EPM collaborator,
upon receipt of that same reconciliation
report, the EPM participant would be
permitted to receive no more than $50
in an alignment payment from the ACO.
Finally, in accordance with the prior
discussion, the methodology for
determining alignment payments must
not directly account for the volume or
value of past or anticipated referrals or
business otherwise generated by,
between or among the EPM participant,
any EPM collaborator, any collaboration
agent, any downstream collaboration
agent, or any individual or entity
affiliated with an EPM participant, EPM
collaborator, collaboration agent, or
downstream collaboration agent.
We proposed that all gainsharing
payments and any alignment payments
must be administered by the EPM
participant in accordance with GAAP
and Government Auditing Standards
(The Yellow Book). Additionally, we
proposed that all gainsharing payments
and alignment payments must be made
by check, electronic funds transfer, or
another traceable cash transaction. We
noted that while the CJR model required
gainsharing payments and alignment
payments to be made by electronic
funds transfer (EFT) (80 FR 73431), we
proposed a different requirement for the
EPM to provide additional flexibility for
entities making gainsharing payments
and alignment payments. We made this
proposal to mitigate the administrative
burden that the EFT requirement would
place on the financial arrangements
between certain EPM participants and
EPM collaborators, especially individual
physicians and nonphysician
practitioners and small PGPs, which
could discourage participation of those
suppliers as EPM collaborators. We
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proposed a change to adopt this same
standard under the CJR model as
discussed in section V.J. of the proposed
rule (81 FR 50962). We sought comment
on the effect of this proposal on
reducing the administrative barriers to
individual physician and nonphysician
practitioner and small PGP participation
in the EPM as EPM collaborators.
The proposals for the conditions and
restrictions on gainsharing payments,
alignment payments, and internal cost
savings under the EPM were included in
proposed § 512.500(c). We sought
comment about all of the conditions and
restrictions set out in the preceding
discussion, including the feasibility of
implementing the proposed safeguards
in the context of the current regulatory
framework applicable to ACOs and
whether additional or different
safeguards would be needed to ensure
program integrity, protect against abuse,
and ensure that the goals of the EPM
were met.
The following is a summary of the
comments received and our responses.
Comment: Some commenters opposed
CMS’ proposal that gainsharing
payments be distributed on annual
basis, but not more than once per year.
The commenters believe this periodicity
is too restrictive and creates an
unintended advantage for BPCI
participants who distribute gainsharing
payments monthly and quarterly. While
one commenter acknowledged that CMS
responded to this same concern in the
CJR Final Rule based primarily on
operational considerations regarding the
frequency of the reconciliation process,
the commenter does not believe that
such challenges should be resolved at
the expense of an effective gainsharing
program for EPM participants and CJR
participant hospitals. The commenter
pointed out that current CJR participant
hospitals choosing to make gainsharing
payments containing NPRA are
prohibited from making any gainsharing
payment until after the annual
reconciliation process, which may take
up to 18 months from the start of a
performance year. They claimed that
this lengthy process is stifling
meaningful change and ultimately
reducing quality and cost savings
because the potential rewards for CJR
collaborators are so far removed from
the care for beneficiaries during CJR
episodes. The commenter requested that
quarterly gainsharing payments be
permitted under the EPM and CJR
model. As an alternative, the commenter
recommended that CMS consider
adopting a modified gainsharing
payment schedule, limiting gainsharing
payments to no more than once per
performance year for the initial
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performance year and then thereafter
allow for quarterly gainsharing
payments. They believe this alternative
could alleviate some of the operational
concerns, while allowing EPM
participants and CJR participant
hospitals the flexibility to create a more
impactful, long-term gainsharing
strategy.
Response: We appreciate that some
commenters are interested in aligning
the periodicity for gainsharing payments
under the EPM and CJR model with the
periodicity of similar payments
permitted in the BPCI models. However,
we believe the differences in periodicity
are warranted in light of the substantive
difference between BPCI and the EPM
and CJR model. Under the BPCI
initiative, the frequency of gainsharing
of internal cost savings is not specified,
while quarterly gainsharing of
reconciliation payments is permitted in
association with the BPCI quarterly
reconciliation process. BPCI
participants are also required to submit
their gainsharing methodologies in an
implementation plan for review and
acceptance by CMS prior to their use. In
contrast, as finalized for the CJR model
(80 FR 73386) and as discussed and
finalized for the EPM in section III.D.5.
of this final rule, the reconciliation
process for the EPM and CJR model will
be conducted annually, and specific
gainsharing methodologies are not
required to be submitted to CMS,
although the EPM and CJR gainsharing
methodologies must meet all the
requirements finalized in this final rule.
We note again that gainsharing
payments may only consist of
reconciliation payments and internal
cost savings, although, as discussed in
more detail later in this section, we
expect a majority of gainsharing
payments to not include internal cost
savings, and thus would contain only
dollars from reconciliation payments.
Given that gainsharing of reconciliation
payments cannot be carried out until
after reconciliation is performed and the
funds available are known to the model
participant, we cannot change the
permissible frequency of gainsharing
payments derived from reconciliation
payments to allow a closer temporal
linkage between the gainsharing
payment and the performance period for
which the EPM participant or CJR
participant hospital earned the
reconciliation payment without carrying
out the reconciliation process more
frequently. Under our annual
reconciliation process, there is a delay
of 6 to18 month between the time EPM
episode care occurs and savings are
represented in a reconciliation payment
from which gainsharing payments can
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be made. We do not believe the
commenters are requesting that
quarterly reconciliation payments be
permissible after the reconciliation
payment is made under an annual
reconciliation process, which would
only lead to an even longer delay
between the EPM episode care that
occurred and the gainsharing payment
that ultimately was made. Thus, the
only way to allow more frequent
gainsharing payments than annually,
and to shorten the time lag between
EPM episode care and gainsharing
payments derived from reconciliation
payments, would be to carry out the
reconciliation process on a more
frequent basis, such as quarterly.
However, for the reasons discussed in
section III.D.5. of this final rule, we will
not conduct the reconciliation process
more frequently than annually for any
performance years of the EPM,
including for any performance year after
the first year of the EPM.
While an EPM participant’s
calculation of internal cost savings
could occur more frequently than
annually, because internal cost savings
do not rely on determinations by CMS,
to allow more frequent gainsharing of
internal cost savings would increase the
documentation burden on EPM
participants. Based on the comments
received, we believe the commenters’
primary interest is in being able to make
more frequent gainsharing payments
derived from reconciliation payments,
rather than those derived from internal
cost savings. Additionally, based on the
implementation plans submitted by
BPCI Awardees and anecdotal
information from CJR participant
hospitals, we expect that few EPM
participants will choose to distribute
gainsharing payments derived from
internal cost savings. Therefore, while
we will consider whether a change may
be warranted in the future to allow more
frequent gainsharing of internal cost
savings under the EPM and CJR model
as we gain implementation experience
with the models, we are not making a
change now to allow gainsharing
payments to be made more frequently
than annually because we do not expect
the increased complexity of such a
policy would be useful to EPM
participants and CJR participant
hospitals.
Given that the BPCI initiative is
scheduled to end late in CY 2018 and
no longer is adding participants, we do
not believe the different EPM and CJR
gainsharing payment periodicity
policies in comparison with those of the
BPCI initiative provide any meaningful
advantage to BPCI Awardees for those
EPM participants and CJR participant
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hospitals seeking to enter into sharing
arrangements with EPM collaborators
and CJR collaborators. While we
appreciate the potential financial
reward for EPM collaborators and CJR
collaborators may be initially 6 to 18
months removed from their
contributions of EPM activities and CJR
activities to beneficiaries in the EPM
and CJR model, we expect that many
collaborators will have sustained
engagement in the EPM and CJR model
and will understand that assessing the
cost and quality outcomes of care
redesign for episodes requires a
substantial period of time for relevant,
reliable performance information to
become available. For EPM collaborators
and CJR collaborators that do have
sustained engagement in the model(s),
gainsharing payments to those
collaborators could potentially be
distributed as early as two quarters
following the end of the performance
year. We also expect that some EPM
participants and CJR participant
hospitals who request beneficiaryidentifiable data as discussed in section
III.D.K.2. of this final rule will be
monitoring episode spending
performance throughout the EPM and
CJR performance years. Thus, model
participants may be able to provide their
collaborators with interim information
regarding their estimates of episode
spending performance and the
implications for gainsharing payments
that may ultimately be available to help
sustain collaborator engagement
throughout the performance years.
We are finalizing in § 512.500(c)(1)(ii)
the annual distribution of gainsharing
payments (not more than once per
calendar year).
Comment: A number of commenters
urged CMS to allow EPM participants to
financially reward collaborators through
gainsharing payments on the basis of the
individual collaborator’s performance as
CMS proposed. One commenter in favor
of this approach interpreted CMS’
proposal as requiring payment of
gainsharing payments to post-acute care
providers based on the pool of postacute care providers with which the
EPM participant had a sharing
arrangement rather than based on
individual collaborator performance.
Another commenter requested that CMS
advise EPM participants to treat
advanced practice nurses and
physicians equally in their gainsharing
methodologies. In general, many
commenters urged CMS to ensure
reconciliation payments are distributed
in a fair and equitable manner to
collaborators.
MedPAC expressed support for the
proposed gainsharing safeguards in the
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EPM. In addition, they recommended
that gainsharing payments to individual
physicians and nonphysician
practitioners who are part of the same
sharing arrangement should not be
allowed to vary based on whether these
practitioners were involved in high- or
low cost-episodes. MedPAC claimed
this requirement would reduce
practitioners’ incentive to treat
primarily low-cost patients and steer
high-cost patients to other physicians or
nonphysician practitioners at the EPM
participant. To operationalize this
policy, MedPAC suggested that if a
gainsharing arrangement results in
hospital internal cost savings or savings
on episode spending, the total
gainsharing payment under that sharing
arrangement should be divided evenly
among all the episodes that are part to
the arrangement. In other words, the
per-episode gainsharing payment
amount should be equal for all
practitioners in the arrangement,
although practitioners who are
responsible for more episodes could
receive higher total payments, yet they
would receive the same per-episode
gainsharing payment as all physicians
and nonphysician practitioners who are
part of the same sharing arrangement.
MedPAC further urged CMS to adopt
safeguards similar to those they
recommended for gainsharing between
EPM participants and physicians for
sharing arrangements between hospitals
and post-acute care providers. They
recommended that EPM participants not
be required to offer risk-sharing
arrangements to all post-acute care
providers in their markets and that
model participants should be able to
discontinue their risk-sharing
arrangements with post-acute care
providers that do not contribute to
lowering episode spending. MedPAC
further suggested that the risk or reward
should be calculated for all post-acute
care providers in the arrangement, not
on a patient-specific or post-acute care
provider-specific basis. They stated that
pooling the savings on episode spending
and quality performance of the postacute care providers would create
incentives for them to cooperate to
jointly lower EPM episode spending.
Under this approach, the risk-sharing
arrangement between an EPM
participant and its post-acute care
provider collaborators would be based
on the change in per-episode spending
in the performance period, resulting in
the same per-episode gainsharing
payment for all post-acute care
providers in the arrangement.
Response: We appreciate the interest
of the commenters in ensuring that
reconciliation payments are distributed
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457
in a fair and equitable manner to
collaborators, including different types
of individual providers and post-acute
care providers. We further appreciate
the support of the commenters for our
proposal to allow EPM participants to
use a methodology for determining a
gainsharing payment that is
substantially based on quality of care
and the provision of EPM activities for
each collaborator, without requiring
standardization of the methodologies
across any groups of collaborators.
Thus, our proposal would allow each
sharing arrangement to be based on the
contributions of the specific
collaborator. With regard to the
commenter who interpreted our
proposal as requiring gainsharing
payment based on a pool of post-acute
care providers with which the EPM
participant enters into sharing
arrangements, rather than based on
individual collaborator performance, we
note that we did not propose any
pooling of funds for making gainsharing
payment to groups of collaborators
under the EPM.
While we understand the potential
benefits of a policy standardizing
sharing arrangements to protect against
selection of low-cost patients and the
resulting patient steering, as well as to
provide an incentive for providers of the
same type to cooperate to jointly
improve quality and reduce episode
spending, we believe that EPM
participants may have legitimate
reasons to enter into a sharing
arrangement with a particular provider,
supplier, or ACO that differs from the
EPM participant’s arrangements with
other similar providers, suppliers, or
ACO. For example, it is possible there
may be instances in which a particular
SNF that has greater capacity to monitor
the cardiac status of beneficiaries or has
resources that an EPM participant
believes will especially benefit
beneficiaries with cognitive
impairments who are recovering from
hip fracture surgery. In these instances,
it may be prudent for an EPM
participant to enter into a different
sharing arrangement with that SNF, as
opposed to other SNFs. Furthermore,
EPM participants may have legitimate
reasons to enter into different sharing
arrangements with EPM collaborators
that agree to take on a portion of the
EPM participant’s downside risk, such
as one particular ACO, compared to
sharing arrangements with other EPM
participants, including other ACOs that
do not take on such downside risk. The
EPM policies that hold EPM
participants responsible for episode
quality and cost performance will
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encourage EPM participants to seek
EPM collaborators that are especially
supportive of these goals. As discussed
earlier in our response to comments on
EPM participant policies for selecting
collaborators, we have included robust
safeguards in this final rule to address
concerns about patient steering and
protect beneficiary freedom of choice.
We believe the MedPAC
recommendation to require the same
per-episode payments for collaborators
of the same type (physicians and postacute care providers) would likely limit
physician and post-acute care provider
commitment to the goals of the EPM,
resulting in less chance of model
success. Our experience in other models
that incorporate gainsharing has
indicated that the financially
responsible entity may have legitimate
reasons to construct different sharing
arrangements with different physicians,
depending on factors such as the
involvement of the physician in the
entity’s care redesign efforts, adoption
of leadership roles requiring direction
and instruction of other physicians, and
the number and magnitude of
disruptions in the physician’s existing
practice patterns. Similarly, the
responsible entity may have legitimate
reasons to construct different sharing
arrangements with different post-acute
care providers, such as the higher care
capacity of a SNF that allows the SNF
to accept an EPM beneficiary earlier
than typical post-surgery or greater
capacity of one HHA versus other to
closely coordinate care for frail
beneficiaries discharged directly to
home following a hospitalization.
We stress that there is no requirement
that EPM participants enter into sharing
arrangements with any providers,
suppliers, or ACOs. Accordingly, EPM
participants are not required to enter
into sharing arrangements with all postacute care providers in their markets.
There also are no requirements for EPM
participants to continue any specific
sharing arrangements, so EPM
participants would be able to
discontinue sharing arrangements if
they believe those arrangements are not
contributing to meeting the EPM goals,
subject to any contract termination
provisions in their contracts with EPM
collaborators.
We are finalizing in § 512.500(c)(5)
that the amount of any gainsharing
payments must be determined in
accordance with a methodology that is
substantially based on the quality of
care and the provision of EPM activities.
The methodology may take into account
the amount of such EPM activities
provided by an EPM collaborator
relative to other EPM collaborators.
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Comment: One commenter urged
CMS to amend the proposed regulation
in § 512.500(c)(6) which states, ‘‘For a
performance year, the aggregate amount
of all gainsharing payments that are
derived from a reconciliation payment
must not exceed the amount of the
reconciliation payment the EPM
participant receives from CMS.’’ The
commenter asserted that this text is
unclear regarding whether the
gainsharing amount can also include
internal cost savings. The commenter
believes the proposed text is confusing
because it either suggests that the total
dollars available for gainsharing are
limited to the total reconciliation
payment amount, which is inconsistent
with the definition of gainsharing, or it
suggests that the proportion of the
gainsharing that is from the
reconciliation payment cannot be more
than that payment, which by definition
is true.
Response: We appreciate the
commenter’s suggestion that we clarify
whether a gainsharing payment may
include internal cost savings; however,
we believe that the commenter’s
suggested change to the proposed
provision in § 512.500(c)(6) is
inadvisable. The purpose of this
requirement is to ensure that the total
amount of all gainsharing payments
made to collaborators and derived from
the reconciliation payment the EPM
participant receives from CMS does not
exceed the amount of that reconciliation
payment. The commenter is correct that
as specified in § 512.500(c)(1)(i),
gainsharing payments, if any, must be
derived solely from reconciliation
payments, or internal cost savings, or
both. We believe it would be confusing
to revise § 512.500(c)(6) as the
commenter suggested to add that the
gainsharing amount can include internal
cost savings, as that is specified
elsewhere in regulation and is not
necessary for this requirement specific
to gainsharing payments derived from a
reconciliation payment. However, we
believe that reordering of the terms in
the provision eliminates any confusion
about the requirement. Therefore, we
are modifying § 512.500(c)(6) to state,
‘‘For a performance year, the aggregate
amount of all gainsharing payments that
are derived from a reconciliation
payment the EPM participant receives
from CMS must not exceed the amount
of that reconciliation payment.’’
We are finalizing in § 512.500(c)(6)
the limit on the aggregate amount of all
gainsharing payments that are derived
from a reconciliation payment with the
modifications discussed.
Comment: While several commenters,
including MedPAC, supported CMS’
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proposal to cap the amount of
gainsharing payments to physicians,
nonphysician practitioners, and PGPs,
most commenters either recommended
that CMS eliminate the caps for PGPs;
eliminate the caps altogether for PGPs,
physicians, and nonphysician
practitioners; or apply the caps on a
different basis than CMS’ proposal of 50
percent of the Medicare-approved
amounts under the PFS for items and
services furnished by the physician or
nonphysician practitioner to the EPM
participant’s EPM beneficiaries during
the EPM episodes that occurred during
the same performance year for which
the EPM participant accrued the
internal cost savings or earned the
reconciliation payment that comprises
the gainsharing payment being
distributed.
One commenter who objected to the
proposed caps on physicians stated that
physicians are singled out for different
treatment than other provider and
supplier types because the commenter
believed physicians were the only type
of EPM collaborator with a cap, and
contended that the cap dampens the
ability of gainsharing to support
physician behavior change by relegating
payments to a nominal amount. Another
commenter claimed that the proposed
EPM financial arrangements may not be
sufficiently flexible for the breadth of
agreements EPM participants may wish
to set up with PGPs, noting that the
proposed gainsharing cap of 50 percent
was based on services furnished by
individual physicians in the PGP to
EPM beneficiaries as opposed to the
BPCI initiative where the commenter
believes the cap is set at 50 percent for
the entire physician group. They
claimed that under CMS’ proposal, there
is no way for a PGP to stabilize risk
among higher- and lower-performing
physicians and, therefore, the group
risk-sharing potential will be less than
50 percent in total.
A number of commenters
recommended changes to the proposed
methodology for setting the cap on
physician, nonphysician practitioner,
and PGP gainsharing payments. One
commenter asserted that due to the
importance of primary care management
in preventing readmissions, it is likely
that the potential value of care
management services provided during
the post-discharge period is
significantly greater than the total PFS
payments a physician will receive for
these services. The commenter urged
CMS to increase the proposed 50
percent cap to reflect the value provided
by these primary care physicians’
services. Several other commenters
requested that if the cap was not
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dropped altogether, the cap should be
set at 50 percent of episode savings
rather than Part B billings, reasoning
that limiting the cap based on the
Medicare-approved amounts paid under
the PFS negatively impacts EPM
participants’ flexibility in determining
the amount of savings to share, as well
as targets physicians individually. The
commenters reasoned that physicians
are the key to driving improved quality
and efficiency due to their direct
relationships with patients, access to the
patient’s current health status, and
ability to recommend the appropriate
level of post-acute care services, and
that the proposed cap would eliminate
meaningful financial incentives for
physicians to fully engage in the EPM.
Several commenters further added that
because CMS has entrusted hospitals
with the responsibility to oversee and
implement EPM care redesign, CMS
should grant hospitals greater flexibility
in designing their respective gainsharing
programs and determining the amount
of episode savings to share with their
EPM collaborators.
Other commenters interpreted CMS’
proposal as allowing EPM participants
to share up to 50 percent of savings
achieved via Part B services with
physicians and recommended that the
cap be revised to include savings from
both Part A and Part B services in
gainsharing payments. The commenters
asserted that accounting for unplanned
care necessitating Part B services is
critical, and that to improve patient
outcomes, unplanned clinically
appropriate care must be accounted for
which potentially results in more
physician involvement than originally
anticipated. They concluded that
significant reductions in Part A
spending may be achieved through
reducing the lengths-of-stay and
unnecessary readmissions during EPM
episodes, but those savings are unlikely
to be accomplished without active
physician participation and, therefore,
physicians should be eligible to share in
those Part A savings.
Response: We acknowledge the many
different perspectives of the
commenters on the proposed cap on
gainsharing payments to physicians,
nonphysician practitioners, and PGPs in
the EPM. We reiterate that we proposed
to limit the total amount of gainsharing
payments for a performance year to EPM
collaborators, collaboration agents, or
downstream collaboration agents that
are physicians, nonphysician
practitioners, or PGPs. For physicians
and nonphysician practitioners the
proposed limit was 50 percent of the
Medicare-approved amounts under the
PFS for items and services furnished by
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that physician or nonphysician
practitioner to the EPM participant’s
EPM beneficiaries during EPM episodes
that occurred during the same
performance year for which the EPM
participant accrued the internal cost
savings or earned the reconciliation
payment that is included in the
payment being made to the physician or
nonphysician practitioner. For PGPs,
the proposed limit on gainsharing
payments was 50 percent of the
Medicare-approved amounts under the
PFS for items and services billed by the
PGP and furnished to the EPM
participant’s EPM beneficiaries by
members of the PGP during EPM
episodes that occurred during the same
performance year for which the EPM
participant accrued the internal cost
savings or earned the reconciliation
payment that is included in the
payment being made to the PGP. We
note that the proposed EPM gainsharing
caps for PGP members operate in the
same way as the caps on PGP member
gainsharing in the BPCI initiative. In
both instances, the cap is set at 50
percent of the total Medicare-approved
amounts under the PFS for services
furnished by the physician or
nonphysician practitioner PGP member
to model beneficiaries during the
applicable time period. Accordingly, it
is not correct that the proposal for
gainsharing caps under the EPM
provides less flexibility than under the
BPCI initiative.
We do not agree with commenters
that the proposed caps on payments
under EPM financial arrangements to
physicians, nonphysician practitioners,
and PGPs should be eliminated because
we proposed these caps for a specific
purpose. The purpose of the cap is to
serve as a safeguard against the potential
risks of stinting, steering, and denial of
medically necessary care due to
financial arrangements specifically
allowed under the EPM by providing an
upper limit on the potential additional
funds a physician, nonphysician
practitioner, or PGP can receive for their
engagement with EPM participants in
caring for EPM beneficiaries beyond the
FFS payments that those suppliers are
also paid and that are included in the
actual episode spending calculation for
the episodes.
We do not believe it would be
appropriate to identify certain types of
physicians, such as those providing
primary care management services, for
higher caps under the EPM because we
believe EPM participants should have
the flexibility to enter into sharing
arrangements with those EPM
collaborators that help them execute
their care redesign plans, which we
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expect to vary from EPM participant to
EPM participant. We further note that
the proposed caps were based on the
Medicare-approved amounts under the
PFS paid to physicians and
nonphysician practitioners for care
furnished to EPM beneficiaries, and not
based on Part B episode savings as some
commenters interpreted the proposal.
Therefore, we do not agree with
concerns of some commenters that Part
B spending could increase even if total
episode spending decreased and,
therefore, could affect the potential for
physician gainsharing payments
because we do not specify where the
episode savings included in a
reconciliation payment must come from
(Part A or Part B) in order for part of the
reconciliation payment to be paid to a
physician, nonphysician practitioner, or
PGP as a gainsharing payment. While
we appreciate the information provided
by the commenters regarding the
valuable role physicians may play in
reducing Part A spending, we do not
believe it would be appropriate to cap
physician, nonphysician practitioner,
and PGP gainsharing payments at 50
percent of total episode savings beyond
the quality-adjusted target price.
Historical EPM episodes include
average episode spending ranging from
approximately $23,000 to $47,000, with
Part B spending (predominantly PFS)
accounting for 7 percent to 14 percent
of the total.129 Thus, depending on
actual episode savings experienced by
the EPM participant, we believe the
proposed cap at 50 percent of Part B
billings would generally allow a
physician, nonphysician practitioner, or
PGP to receive a gainsharing payment
that is comprised of a reconciliation
payment that includes Part A savings.
Further, setting the gainsharing cap
based on Part B billings for physicians,
nonphysician practitioners, and PGPs
helps to maintain a connection between
their gainsharing payments and their
payments under the PFS for items and
services furnished to EPM beneficiaries
so as not to create a disproportionate
opportunity and associated program
integrity risk for physicians,
nonphysician practitioners, and PGPs to
dramatically increase their payments on
behalf of Medicare beneficiaries based
on their participation in EPM financial
arrangements.
We emphasize that we have applied
the 50 percent cap on gainsharing
payments to physicians, nonphysician
129 Episodes for AMI, CABG, and SHFFT
beneficiaries initiated by all U.S. IPPS hospitals not
in Maryland and constructed using standardized
Medicare FFS Parts A and B claims, as proposed in
the proposed rule that began in CYs 2012 2014.
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practitioners, and PGPs in the CJR
model as well as the BPCI initiative, and
participants have not voiced significant
complaints that this financial limitation
has hampered their ability to engage
physicians, nonphysician practitioners,
and PGPs in care redesign to improve
episode quality and reduce costs. We
acknowledge the important role
physicians play in providing quality,
efficient health care to beneficiaries, but
we believe that allowing a physician,
nonphysician practitioner, and PGP to
be paid up to 50 percent more for
engagement with the episode care of
EPM beneficiaries than the payments
they are paid for furnishing direct
services to those beneficiaries under the
PFS provides EPM participants with
substantial flexibility to develop and
implement meaningful financial
arrangements that align the financial
interests of physicians, nonphysician
practitioners, and PGPs with the quality
and cost goals of the EPM participant
under the EPM.
We note that as discussed previously
in this section, we are adding NPPGPs
to the list of EPM collaborators.
Consistent with our cap on gainsharing
payments to PGPs, as well as our cap on
gainsharing payments to physicians and
nonphysician practitioners, we are
adding NPPGPs to § 512.500(4)(ii) where
we specify the cap on gainsharing
payments to PGPs so that those caps are
also applied to gainsharing payments to
NPPGPs.
We are finalizing in §§ 512.500(4)(i)
and 512.500(4)(ii) the caps on the total
amount of gainsharing payments for a
performance year paid to physicians,
nonphysician practitioners, PGPs, and
NPPGs.
We note that our proposals were not
clear or consistent regarding whether
caps applied to individual therapists or
TGPs. We did not propose to cap
gainsharing payments to EPM
collaborators that are providers or
suppliers of outpatient therapy services,
which include individual therapists and
therapy group practices, and we did not
propose to cap the distribution
payments to therapists who are
members of a PGP under proposed
§ 512.505(8)(i). However, we proposed
that therapists who are members of a
PGP and receive downstream
collaboration payments would have
their payments capped under proposed
§ 512.510(b)(7) as members of the PGP.
As discussed in section III.I.3. of this
final rule, we have created new terms
and revised certain proposed terms for
this final rule to separately define
therapist in private practice and TGP
and the revised definition of EPM
collaborator now separately identifies
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therapists in private practice and TGPs
as eligible to be collaborators. While
capping gainsharing payments to
therapists and TGPs would be most
consistent with our treatment of
gainsharing payments to other
individual clinicians and their practice
groups and it would be possible to
apply such caps in view of the new
definitions of therapist in private
practice and TGP adopted in this final
rule, we do not believe it would be
appropriate to adopt gainsharing caps
for therapists in private practice or TGPs
because we did not solicit comment on
caps for any providers or suppliers of
outpatient therapy services, including
therapists in private practice and TGPs.
However, our reasoning for the caps on
gainsharing payments to physicians,
nonphysician practitioners, PGPs, and
NPPGs could similarly apply to
therapists and TGPs. Namely, a cap on
therapists and TGPs could serve as a
safeguard against the potential risks of
stinting, steering, and denial of
medically necessary care due to
financial arrangements specifically
allowed under the EPM by providing an
upper limit on the potential additional
funds the clinician or group can receive
for their engagement with EPM
participants in caring for EPM
beneficiaries beyond the FFS payments
that those suppliers are also paid and
that are included in the actual episode
spending calculation for the episodes.
Therefore, while we are not adopting
gainsharing caps for therapists in
private practice and TGPs in this final
rule and we are revising proposed
§ 512.510(b)(7) which is final
§ 512.510(b)(8) to remove the cap as
applied to therapists who are PGP
members, we will monitor payments
under financial arrangements to these
individuals and entities and may
consider proposing caps in the future if
we have program integrity concerns
during EPM implementation.
We are finalizing the in
§ 512.500(c)(4) the cap on the aggregate
amount of gainsharing payments for a
performance year paid to physicians,
nonphysician practitioners, and PGPs,
with modification to also apply the cap
to NPPGPs.
Comment: Some commenters urged
CMS to eliminate the proposed caps on
alignment payments at the entity level,
specifically mentioning ACOs, PGPs,
and post-acute care providers in their
discussion. One commenter was
concerned that under CMS’ proposal a
single EPM collaborator other than an
ACO could possibly be accountable for
up to 25 percent of an EPM participant’s
repayment amount, highlighting that
such an amount could post serious
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financial jeopardy to the EPM
collaborator’s existence. To mitigate this
risk, the commenter recommended that
all the EPM collaborators other than
ACOs in aggregate would pay no more
than 25 percent of the EPM participant’s
repayment amount or, alternatively
would pay proportionally based upon
the Medicare-approved amounts the
EPM collaborator was paid for items and
services furnished to EPM beneficiaries.
Response: We appreciate the
commenters’ recommendation to
eliminate caps on alignment payments
by entities that are EPM collaborators.
We note that we proposed for a
performance year, the aggregate amount
of all alignment payments received by
the EPM participant must not exceed 50
percent of the EPM participant’s
repayment amount. In regards to the 50
percent cap on the aggregate amount of
alignment payments, the commenters
did not provide specific justification for
eliminating this cap on alignment
payments provided to EPM participants.
As such, given that the EPM participant
is responsible for developing and
coordinating care redesign strategies in
response to its EPM participation, we
believe it is important that the EPM
participant retain a significant portion
of its responsibility for repayment to
CMS. Therefore, we are maintaining the
cap on the aggregate amount of all
alignment payments at 50 percent of the
EPM participant’s repayment amount,
ensuring that EPM participants retain a
minimum of 50 percent of the
repayment amount as their
responsibility.
In addition, we proposed that the
aggregate amount of all alignment
payments from an EPM collaborator
other than an ACO to the EPM
participant may not be greater 25
percent of the EPM participant’s
repayment amount. In response to the
commenter’s concern about the
potential for an EPM collaborator that is
not an ACO to experience serious
financial jeopardy due to this amount,
we emphasize that there is no
requirement that any provider, supplier,
or ACO enter into a sharing arrangement
as an EPM collaborator, including a
sharing arrangement that requires them
to make an alignment payment. We also
emphasize that the 25 percent cap on
alignment payments represents the
upper threshold for risk sharing that a
single EPM collaborator may assume,
and that the parties may agree to lower
amounts. Furthermore, participation in
sharing arrangements must be voluntary
and without penalty for
nonparticipation. Thus, we cap the
aggregate amount of all alignment
payments from an EPM collaborator
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other than an ACO at 25 percent of the
EPM participant’s repayment amount as
a broad safeguard for EPM collaborators
and EPM participants from excessive
financial risk or undue influence from
the EPM participant’s contractual
relationship with a single EPM
collaborator. However, this cap is not a
substitute for the deliberation of both
the EPM participant and EPM
collaborator before entering into a
sharing arrangement that would require
the EPM collaborator to make an
alignment payment to the EPM
participant if the EPM participant has a
repayment amount due to Medicare. We
believe that the EPM collaborator is
best-positioned to make financial
decisions on its own behalf and to bear
the consequence of those decisions, and
that flexibility in sharing arrangements
between different parties is important.
Therefore, we see no need to provide a
more protective cap on the
accountability for a single EPM
collaborator by aggregating the
accountability of all EPM collaborators
or requiring that the EPM collaborator
only assume accountability for paying a
portion of the EPM participant’s
repayment amount that is proportionate
to the EPM episode spending on items
and services furnished by that EPM
collaborator. Therefore, we are
maintaining the cap on the aggregate
amount of all alignment payments from
an EPM collaborator other than an ACO
to the EPM participant at 25 percent of
the EPM participant’s repayment
amount.
We are finalizing in §§ 512.500(c)(12)
and 512.500(c)(13) the cap on the
aggregate amount of all alignment
payments received by the EPM
participant and the cap on alignment
payments that may be made by EPM
collaborators to the EPM participant.
Comment: One commenter opposed
CMS’ proposal to cap the aggregate
amount of all alignment payments from
an EPM collaborator that is an ACO to
an EPM participant at 50 percent of the
EPM participant’s repayment amount,
arguing that setting such a limit
interferes the negotiations between an
EPM participant and its collaborators.
The commenter asserted that ACOs
should be able to use their substantial
expertise and resources to contribute to
the EPM’s dual goals of limiting
spending and increasing quality. They
urged CMS to permit an EPM
participant and its collaborators to
jointly agree on the terms and
conditions of a sharing arrangement,
including specifics around gainsharing
or repayment percentages, because it is
unnecessary to place limits on
repayment amounts as long as they do
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not collectively exceed the amount the
EPM participant would have to repay.
Another commenter pointed out that the
risk threshold for an EPM consisting of
beneficiaries discharged from several
MS–DRGs is substantially less than that
of two-sided risk ACO models,
approximately $500,000 versus
$2,000,000 for a small ACO,
respectively. They suggested that CMS
consider the risk alignment of ACOs and
the EPM as an opportunity for ACOs to
phase-in downside risk incrementally
and at a substantially lower entry point
of dollars than current two-sided ACO
options. The commenter believes that
adopting such an approach would
encourage ACOs to take on more
downside risk.
Response: We appreciate the
commenter’s recommendation to
eliminate the proposed cap on
alignment payments made by an EPM
collaborator that is an ACO to an EPM
participant. We agree with the
commenter about the expertise that
ACOs may offer EPM participants with
regard to managing the cost and quality
of care Medicare beneficiaries receive.
We proposed that the aggregate amount
of all alignment payments from an EPM
collaborator to the EPM participant may
not be greater than 25 percent of the
EPM participant’s repayment amount
for an EPM collaborator that is not an
ACO and 50 percent of the EPM
participant’s repayment amount for an
EPM collaborator that is an ACO. We
proposed to allow a higher percentage of
the EPM participant’s repayment
amount to be paid by an ACO than by
EPM collaborators that are not ACOs in
recognition that some ACOs are sizable
organizations with significant financial
and other resources that can may benefit
EPM episode spending and quality
performance.
We have constructed a framework for
EPM financial arrangements that we
believe leaves EPM participants and
EPM collaborators relatively
unconstrained to develop sharing
arrangements in a manner they see fit
based on the contributions of different
parties to the goals of the EPM, provided
that all the requirements for financial
arrangements included in this final rule
are met. We did not propose that EPM
participants would need to use a
particular methodology for determining
alignment payments that are made by
either an EPM collaborator that is an
ACO or an EPM collaborator that is not
an ACO. However, as discussed in the
response to the previous comment,
given that the EPM participant is
responsible for developing and
coordinating care redesign strategies in
response to its EPM participation, we
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461
believe it is important that the EPM
participant retain a significant portion
of its responsibility for repayment to
CMS. The EPM was not designed to test
the phase-in of ACO downside risk or
specifically encourage ACOs to take on
more downside risk, but rather to test
the EPM where acute care hospitals are
the financially accountable entity to
CMS for episode quality and cost
performance, with sufficient flexibility
to share their upside and downside risk
with EPM collaborators based on the
financial alignment needs arising from
EPM episode care redesign.
Therefore, we are maintaining the cap
on the aggregate amount of all alignment
payments at 50 percent of the EPM
participant’s repayment amount, while
allowing an ACO to assume
responsibility for the remaining 50
percent of the repayment amount
through an alignment payment to be
made to the EPM participant. While we
appreciate the commenter’s view that
we should let the market determine the
best arrangements for the parties
without constrain, in the early
performance years of the first required
episode payment models and in our first
experience with ACOs as model
collaborators, we believe the alignment
payment limit allows sufficient
flexibility for the development of
market-based arrangements between
EPM participants and ACOs, while
providing assurance of the EPM
participant’s active involvement in
developing and implementing EPM care
redesign strategies.
Comment: One commenter urged
CMS to apply a cap on gainsharing
payments to all EPM collaborators,
arguing that because CMS proposed
caps only on gainsharing payments to
physicians, nonphysician practitioners,
and PGPs that EPM participants may
conclude that sharing arrangements
with other types of providers, such as
post-acute care providers, is not
encouraged by CMS. The commenter
further contended that CMS’ proposal to
cap gainsharing payments for physician,
nonphysician practitioners, and PGPs at
a certain percentage of the amount
billed to Medicare is ill-advised given
that the goal of the EPM is to reduce
costs to Medicare by better managing
services and reducing unnecessary
services. They recommended that CMS
adopt a gainsharing cap policy that
specifies that no one type of collaborator
(for example, physicians) nor individual
provider or organization can receive
more than 50 percent of the available
gainsharing amount in order to ensure
that all EPM collaborators may be
eligible for a gainsharing payment
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should they meet the requirements of
their sharing arrangement.
Response: We do not agree with the
commenter that the lack of a proposed
cap on gainsharing payments to
providers, suppliers, and ACOs other
than physicians, nonphysician
practitioners, and PGPs in our proposal
implies that these other individuals and
entities are not worthy of consideration
by EPM participants as potential EPM
collaborators. We note that we proposed
to add ACOs, hospitals, and CAHs, none
of whom have gainsharing caps, to the
list of types of providers and suppliers
that may be EPM collaborators, thereby
expanding the list initially adopted for
the CJR model.
The purpose of the final cap on
gainsharing payments for physicians,
nonphysician practitioners, PGPs, and
NPPGs (as adopted in this final rule) is
to serve as a safeguard against the
potential risks of stinting, steering, and
denial of medically necessary care due
to financial arrangements specifically
allowed under the EPM by providing an
upper limit on the potential additional
funds a physician, nonphysician
practitioner, PGP, or NPPGP can receive
for their engagement with EPM
participants in caring for beneficiaries
in the EPM beyond the FFS payments
that those suppliers are also paid and
that are included in the actual episode
spending calculation for the episodes.
With the exception of physicians,
nonphysician practitioners, PGPs, and
NPPGPs, we do not limit the amount of
gainsharing payments to other eligible
EPM collaborators. As discussed earlier
in this section, as the financially
responsible entities for EPM episodes,
we believe that EPM participants should
have as much flexibility as possible,
subject to adequate program integrity
safeguards, in decisions about financial
arrangements, including whether or not
to enter into them; the selection of
collaborators; and the methodologies for
determining the amounts of gainsharing
payments and alignment payments.
Therefore, we do not believe it would be
appropriate to limit the gainsharing
payment of an EPM participant to any
EPM collaborator or single type of EPM
collaborator based on the available
gainsharing amount in order to ensure
that all EPM collaborators receive a
portion of the gainsharing amount that
is available.
Comment: One commenter claimed
that CMS’ proposal applies some
unnecessary limits to when an EPM
collaborator can receive a gainsharing
payment. The commenter reasoned that
if the goal of the EPM is to redesign
care, then the possibility should be
considered that an EPM collaborator
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may furnish a service that is not
‘‘billable’’ under Medicare FFS today
and yet could play an important role in
changing the outcomes and cost under
an EPM episode. They recommended
that CMS not limit the eligibility for
receiving gainsharing payments to just
services that are billable but instead
allow the EPM collaborator to receive
some payment after the fact for a service
or item that contributed positively to the
EPM episode. To accomplish this
change, the commenter specifically
suggested that CMS delete ‘‘billable’’ in
proposed § 512.500(c)(2)(ii) where CMS
proposed to require that to be eligible to
receive a gainsharing payment or to be
required to make an alignment payment,
an EPM collaborator other than a PGP or
an ACO must have directly furnished a
billable item or service to an EPM
beneficiary during an EPM episode that
occurred in the same performance year
for which the EPM participant accrued
the internal cost savings or earned the
reconciliation payment that comprises
the gainsharing payment or was
assessed a repayment amount. They
believe it is unlikely that this change
would be abused as it is not in the EPM
participant’s best interest to issue a
gainsharing payment to an EPM
collaborator that offered them no benefit
in the EPM.
The commenter further recommended
that the proposed gainsharing eligibility
criteria for ACOs, specifically that their
involvement in an EPM beneficiary’s
care was either: 1) related to the
provision of care coordination services
and/or 2) related to engaging in care
redesign strategies and helping to
implement those strategies, be added to
the gainsharing eligibility requirement
for other EPM collaborators that are not
ACOs or PGPs in § 512.500(c)(2)(ii).
They believe that providers and
suppliers should also be eligible for
gainsharing if they engage in those
tasks. The commenter concluded that
making both of their recommended
changes to § 512.500(c)(2)(ii) would
contribute to comparable gainsharing
opportunities being available for EPM
collaborators carrying out the same
activities to advance the goals of the
EPM.
Response: We appreciate the
commenter’s detailed suggestions about
changes to the proposed gainsharing
eligibility criteria for EPM collaborators
that are not PGPs or ACOs to ensure
comparable gainsharing opportunities
for different types of EPM collaborators.
First, we want to clarify that while our
proposal would require an EPM
collaborator other than a PGP or an ACO
to have directly furnished a billable
item or service to an EPM beneficiary
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during an EPM episode that occurred in
the same performance year for which
the EPM participant accrued the
internal cost savings or earned the
reconciliation payment that comprises
the gainsharing payment to be eligible to
receive a gainsharing payment, there is
no requirement that the gainsharing
payment methodology rely only upon
billable items and services. As proposed
in § 512.500(c)(5), the amount of any
gainsharing payments must be
determined in accordance with a
methodology that is substantially based
on the quality of care and the provision
of EPM activities. We proposed that
EPM activities means activities related
to promoting accountability for the
overall quality, cost, and overall care for
EPM beneficiaries, including managing
and coordinating care; encouraging
investment in infrastructure, enabling
technologies, and redesigned care
processes for high quality and efficient
service delivery; the provision of items
and services that reduce costs and
improves quality, or carrying out any
other obligation of duty under the EPM.
Thus, all EPM collaborators may receive
a gainsharing payment determined by a
methodology that takes into account
their contribution of items and services
that are not billable but which
contributed to changes in EPM episode
outcomes and cost, an outcome which is
consistent with the commenter’s
recommendation.
For those EPM collaborators who can
directly furnish items and services to
Medicare beneficiaries, which are all
EPM collaborators that are not ACOs,
PGPs, NPPGPs, or TGPs, we believe a
connection to the actual care of EPM
beneficiaries is essential so that the
financial incentives of providers
furnishing billable items and services to
EPM beneficiaries are aligned with
those of EPM participants to improve
the quality of care and reduce the costs
of episode. It is difficult to contemplate
how model success can be achieved
without significant care redesign that
involves billable items and services
furnished by the providers and
suppliers actually caring for EPM
beneficiaries. The requirement that EPM
collaborators other than ACOs, PGPs,
NPPGPs, and TGPs directly furnish
billable items or services to EPM
beneficiaries to be eligible for
gainsharing payments ensures a nexus
between the financial incentives and
actual care to EPM beneficiaries. This
requirement also provides a program
integrity safeguard against the free flow
of gainsharing payments to an EPM
collaborator who does not furnish items
or services to EPM beneficiaries as a
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means of impacting the referral patterns
of the EPM collaborator to particular
hospitals. Thus, we do not believe that
adopting the recommendation of the
commenter that we use the criteria for
ACOs, that do not directly furnish items
or services to beneficiaries, to define the
clinical involvement of EPM
collaborators that are not ACOs PGPs,
NPPGPs, or TGPs in the care of EPM
beneficiaries that is required for
gainsharing eligibility is necessary or
appropriate. It is only in the case of
ACOs, PGPs, NPPGPs, and TGPs that do
not directly furnish items or services to
EPM beneficiaries that we needed to
develop another definition for the
clinical involvement that is a
requirement for gainsharing payment
eligibility. We expect that EPM
collaborators that are not ACOs, PGPs,
NPPGPs, or TGPs will commonly
provide care coordination services to
EPM beneficiaries, engage in care
redesign strategies, and perform a role
in implementing such strategies, just as
we expect similar activities for ACOs,
PGPs, NPPGPs, and TGPs that are EPM
collaborators. We further note that an
EPM participant can factor these types
of activities into the methodology that
determines the amount of the
gainsharing payment for EPM
collaborators. However, for the reasons
described previously, we will not allow
EPM collaborators that are not ACOs,
PGPs, NPPGPs, or TGPs to be eligible for
gainsharing payments if they have not
directly furnished a billable item or
service to an EPM beneficiary during an
EPM episode during the applicable time
period. We believe that the gainsharing
payment eligibility policies provide the
potential for comparable gainsharing
opportunities for all types of EPM
collaborators, while taking into
consideration the reality that
individuals and entities with different
potential for providing billable services
to EPM beneficiaries may be EPM
collaborators.
We are finalizing in § 512.500(c)(2)(ii)
that to be eligible to receive a
gainsharing payment or to be required to
make an alignment payment, an EPM
collaborator that is not an ACO, PGP,
NPPGP, or TGP must have directly
furnished a billable item or service to an
EPM beneficiary during an EPM
episode.
Comment: Several commenters
expressed concern about the proposed
restrictions on paper savings in the
methodology used to calculate the EPM
participant’s internal cost savings from
which the participant may make
gainsharing payments to EPM
collaborators. The commenters claimed
that very few hospital accounting
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systems can clearly separate ‘‘paper’’
savings from ‘‘real’’ savings. They
claimed that introducing systems to
account for savings will require time
and resources that may restrict ability of
many EPM participants to meet the
proposed requirements, yet ‘‘paper’’
savings may yield real benefits for
patients. As an example, one commenter
pointed out that ‘‘paper’’ savings due to
reductions in nursing time may permit
that time to be dedicated to other
patients improving coverage and
benefiting the quality of care.
Response: We appreciate the
information provided by the
commenters on the types of internal cost
savings that EPM participants might
achieve based on care redesign under
the EPM. We note that we proposed in
§ 512.500(c)(3)(ii) that the methodology
used to calculate internal cost savings
must reflect the actual, internal cost
savings achieved by the EPM participant
through the documented
implementation of EPM activities
identified by the EPM participant, and
in § 512.500(c)(3)(ii)(B) proposed that
the methodology must exclude ‘‘paper’’
savings from accounting conventions or
past investment in fixed costs.
In considering the EPM participant’s
methodology for calculating internal
cost savings achieved based on their
implementation of EPM activities, EPM
participants should consider all of these
requirements and others we proposed
for internal cost savings in their totality.
We believe that any methodology that
meets the proposed requirements for the
methodology to calculate internal cost
savings would require some system to
account for savings. Moreover, we do
not believe it would be appropriate to
allow gainsharing payments derived
from an EPM participant’s internal cost
savings that cannot be specifically
accounted for due to the program
integrity risk that such payments may
pose. We appreciate that accounting for
the savings resulting from the
implementation of EPM activities by the
EPM participant could require
accounting systems of different
complexities based on the specific types
of internal cost savings that the EPM
participant wants to capture for
purposes of making gainsharing
payments. For example, internal cost
savings due to physician collaboration
to achieve device standardization in
EPM episodes that results in the EPM
participant being able to purchase the
device at a lower price reflecting
volume discounts may be relatively
easily accounted for by comparing
device purchase invoices during the
EPM performance year to those during
the immediately prior period. On the
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other hand, reductions in nursing time
for EPM beneficiaries due to a shorter
hospital stay that results from
streamlined discharge planning may
require more complex systems to track
and compare nursing time and its
associated hospital cost for EPM
beneficiaries during the EPM
performance period to those during the
immediately prior period. Thus, while
we recognize the challenges identified
by the commenters in tracking real
savings associated with EPM care
redesign, given that we proposed to
allow EPM participants to select their
own methodologies for calculating
internal cost savings (provided that such
methodologies meet the requirements in
this final rule to be included in
gainsharing payments to EPM
collaborators), we believe that we have
provided sufficient flexibility to allow
each EPM participant the ability to
develop a methodology for calculating
internal cost savings that aligns with its
technical capacity to track those
savings. We note that the purpose of this
prohibition on paper savings is to bar
the distribution of gainsharing payments
comprised of funds that did not derive
from real savings, as well as bar
payments made for purposes other than
the provision of EPM activities by EPM
collaborators that results in reduced
episode spending or increased quality.
As such, we believe the proposed
requirements prohibiting EPM
participants from sharing internal cost
savings that results merely from paper
savings—rather than real savings arising
from the successful implementation of
care redesign strategies by the EPM
participant—are necessary as a program
integrity safeguard, and so we are
declining to accept the commenters’
suggestion.
We are finalizing in
§ 512.500(c)(3)(ii)(B) that the
methodology used to calculate internal
cost savings must exclude paper savings
from accounting conventions or past
investment in fixed costs.
Comment: One commenter requested
clarification regarding CMS’ proposal
that an EPM participant must not make
a gainsharing payment to an EPM
collaborator that is subject to any action
for noncompliance with the EPM
requirements or fraud and abuse laws,
or for the provision of substandard care
in EPM episodes or other integrity
problems. The commenter expressed
concerns regarding the absence of a
bright line standard EPM participants
could use to ensure compliance with
this standard. The commenter expressed
particular concern about how a
participant could determine if a
collaborator was subject to an action for
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the ‘‘provision of substandard care in
EPM episodes or other integrity
problems.’’ The commenter further
recommended that CMS should apply a
reasonable knowledge standard to
compliance with this provision.
Response: We appreciate the
commenter’s interest in additional
clarification regarding how a participant
can ensure it complies with this
payment restriction. We believe that we
can provide additional clarity to the
standard for not making a gainsharing
payment by establishing that this
provision only restricts an EPM
participant’s ability to make a
gainsharing payment if CMS notifies the
EPM participant of the action that
would trigger the payment restriction.
Specifically, we are modifying the
provision to state, ‘‘An EPM participant
must not make a gainsharing payment to
an EPM collaborator if CMS has notified
the EPM participant that such
collaborator is subject to any action for
noncompliance with this part or the
fraud and abuse laws, or for the
provision of substandard care in EPM
episodes or has other integrity
problems.’’ This change should
eliminate any uncertainty by the EPM
participant about circumstances in
which an EPM collaborator must not be
paid a gainsharing payment, while also
providing a sufficient safeguard against
gainsharing with individuals and
entities that present risk of patient harm
or program abuse. Therefore, we are
revising § 512.500(c)(8) accordingly.
We believe that adopting the
alternative approach recommended by
the commenter and using a reasonable
knowledge standard would make
enforcing this prohibition of distributing
gainsharing payments to EPM
collaborators under certain
circumstances highly challenging, if not
impossible. We believe the notification
approach discussed previously allows
for the ‘‘bright line’’ that the commenter
was seeking, while maintaining the
agency’s ability to prevent gainsharing
payments to an EPM collaborator that
has program integrity concerns.
We are finalizing in § 512.500(c)(8)
that an EPM participant must not make
a gainsharing payment to an EPM
collaborator if CMS has notified the
EPM participant that such collaborator
is subject to any action for
noncompliance with this part or the
fraud and abuse laws, or for the
provision of substandard care in EPM
episodes or has other integrity
problems.
Comment: Several commenters
requested that CMS extend financial
arrangements permitted under the EPM
and CJR model to scenarios that extend
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beyond EPM episodes. The commenters
believe that these requests would
require fraud and abuse law waivers.
One commenter encouraged CMS to
allow for gainsharing on commercial
and Medicaid episode payment
arrangements that are similar to the CJR
model or proposed under the EPM to
increase the volume of cases on which
hospitals can share gains with
collaborators. Another commenter urged
CMS to allow EPM participants and CJR
participant hospitals to provide care
management tools and services to
beneficiaries and providers prior the
start of the episode, consistent with
activities contemplated by the Medicare
Shared Savings Program, ACO
participation waiver. While
acknowledging that CMS is not inclined
to start the episode prior to the date of
the admission for the anchor
hospitalization, the commenter
explained that pre-episode services have
been proven to not only improve patient
outcomes and satisfaction but also to
result in the delivery of more efficient
and higher quality care. The commenter
provided examples of pre-episode
services they requested be allowed
under the EPM and CJR model:
comprehensive patient evaluation to
assess a beneficiary’s overall condition
and chronic comorbid conditions’
patient education videos and materials;
discharge planning review and
counseling; home safety reviews; and
patient and caregiver education. Finally,
another commenter requested that EPM
participants and CJR participant
hospitals be able to provide other
providers, including post-acute care
providers and PGPs in their
communities with whom they
collaborate, necessary telehealth
equipment, health IT support, and items
and services necessary to achieve the
type of care integration necessary for the
EPM and CJR model without fear of
liability under anti-kickback, physician
self-referral, and beneficiary
inducement prohibitions.
Response: We appreciate the
descriptions provides by the
commenters of additional care redesign
strategies beyond care for EPM and CJR
beneficiaries that could ultimately
contribute to improvements in the
quality of care and reductions in the
cost of EPM and CJR episodes. While we
understand that being able to share cost
savings based on a larger volume of
cases that includes patients in similar
episode payment arrangements under
Medicaid and commercial insurers
could provide EPM participants and CJR
participant hospitals more funds for
aligning the financial incentives of their
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collaborators with the goals of the
episode payment arrangements, we will
not regulate arrangements for
beneficiaries outside of those in EPM
and CJR episodes in this rulemaking
because it would be inappropriate to do
so.
We are finalizing the initiation of
EPM episodes with admission for the
anchor hospitalization as discussed in
sections III.4.a.(2) through (4) of this
final rule, just as we finalized that same
policy for the CJR model (80 FR 73318).
We note that all AMI and SHFFT
beneficiaries, as well as a significant
percentage of CABG and CJR
beneficiaries, would be admitted
emergently to the EPM participant or
CJR participant hospital, making preepisode services not possible for these
beneficiaries even if we were to permit
them under the models. We did not
propose to allow sharing arrangements
for pre-episode services under the EPM
and CJR model because we believe there
are significant program integrity risks of
patient steering and adverse patient
selection for admissions for elective
surgery, such as some CABG surgery
and LEJR, that would be difficult to
overcome if EPM participants and CJR
participant hospitals were permitted to
furnish pre-episode services beyond
those allowed under current laws and
regulations, including the fraud and
abuse laws.
Similarly, we did not propose
parameters for the provision of
equipment and other items and services
by EPM participants and CJR participant
hospitals to their collaborators to aid in
care integration beyond those that are
permissible under current laws and
regulations, including the fraud and
abuse laws. We believe that it would be
very challenging to establish sufficient
safeguards to protect beneficiary
freedom of choice and guard against
patient steering in such EPM and CJR
model scenarios where EPM
participants and CJR participant
hospitals provided resources to
collaborators that were not specifically
based on the quality of care and the
provision of EPM activities or CJR
activities for beneficiaries in EPM
episodes or CJR episodes by that
collaborator.
Comment: One commenter
recommended that disclosure of sharing
arrangements be required by the EPM
participant to receive a reconciliation
payment, so that CMS can confirm that
hospitals have contracts in place with
all the involved clinicians and postacute care providers. The commenter
further urged CMS to also require full
disclosure of the total amount of all
gainsharing payments and how much is
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being distributed to each provider or
supplier who furnished care to an EPM
beneficiary, in order to ensure that
payments for care delivery are as
transparent as possible. Another
commenter requested that CMS collect
documents related to the calculation,
distribution, receipt, or recoupment of
gainsharing payments, alignment
payments, distribution payments, and
downstream distribution payments and
other savings-related payments and the
distribution to collaborating physicians
and other healthcare professionals. The
commenter believes that CMS could
utilize these data for future efforts and
to ensure program integrity, as well as
to help examine the extent to which
savings are equitably being shared by
EPM participants with collaborating
physicians and other healthcare
professionals
Response: As discussed previously in
this section, we do not require EPM
participants to enter into sharing
arrangements, and we do not require
that those sharing arrangements include
any specific groups of providers,
suppliers, or ACOs. Thus, we do not
need to confirm the sharing
arrangements that are in place with
specific EPM collaborators prior to
making a reconciliation payment to an
EPM participant. However, we do
require that EPM participants report the
historical and current lists of
collaborators on a Web page on the EPM
participant’s Web site of EPM
collaborators as discussed in section
III.I.4.d. of this final rule, which
provides transparency regarding the
identities of collaborators with EPM
participants. In addition, CMS has the
ability to request this information from
EPM participants under the provisions
regarding access to records and
retention for the EPM.
We appreciate the requests that CMS
consider routinely collecting specific
information on the calculation,
distribution, receipt, or recoupment of
gainsharing payments, alignment
payments, distribution payments, and
downstream distribution payments and
other savings-related payments and the
distribution to collaborators. While EPM
participants are required to provide this
information to CMS upon request under
the access to records and retention
provisions for the EPM and CMS will
exercise this authority where
appropriate, we believe the routine
submission of this information would
create a substantial and unnecessary
administrative burden on EPM
participants given the large number of
potential EPM collaborators and the
expected varied nature of their
respective arrangements with EPM
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participants. We also are mindful of the
challenges associated with creating a
universal collection tool that would
account for all the various iterations of
financial arrangements into which EPM
participants and their collaborators may
enter into.
We agree with the commenters that
transparency is important to ensure
program integrity and to assist with
evaluation of the model. We have tried,
where possible, to ensure transparency
regarding sharing, distribution, and
downstream distribution arrangements
without imposing undue administrative
burden on the individuals and entities
that enter into such arrangements.
Because documenting financial
arrangements is consistent with general
business practices, we believe that our
documentation requirements impose
minimal additional administrative
burden on EPM participants, their
collaborators, collaboration agents, and
downstream collaboration agents. The
regulations require contemporaneous
documentation of all arrangements and
the written agreements must be in
writing and signed by the parties,
contain the date of the agreement, and
be entered into before care is furnished
to EPM beneficiaries under the
arrangement. The written agreement for
sharing arrangements also must specify
the purpose and scope of the sharing
arrangement, the identities and
obligations of the parties, management
and staffing information, and the
financial or economic terms for
payment. We believe that the goals of
transparency and program integrity can
be achieved by requiring EPM
participants, EPM collaborators,
collaboration agents, downstream
collaboration agents, and any other
individual and entities performing EPM
activities maintain documentation for at
least 10 years following the last day of
the EPM participant’s participation in
the EPM and allowing CMS, OIG, HHS,
and the Comptroller General or their
designees access to such records. The
evaluation for the EPM intends to
examine factors associated with
variations in success under the EPM and
the likelihood of experiencing
unintended consequences. Factors of
interest include variations in how
gainsharing, distribution, and
downstream distribution payments are
implemented between the parties. At
this time, it is intended that such
information on payments will be
collected through mechanisms such as
provider surveys, interviews and in case
studies.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposals in § 512.500(c)
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465
for EPM gainsharing payment,
alignment payment, and internal cost
savings conditions and restrictions, with
modifications. In addition to the
modifications previously discussed in
this section, we are specifying that like
PGPs, to be eligible to receive a
gainsharing payment or to be required to
make an alignment payment, a NPPGP
or TGP must have billed for an item or
service that was rendered by one or
more NPPGP member or TGP member
respectively to an EPM beneficiary
during an EPM episode that occurred
during the same performance year for
which the EPM participant accrued the
internal cost savings or earned the
reconciliation payment that comprises
the gainsharing payment or was
assessed a repayment amount. In
addition, like PGPs, the NPPGP or TGP
must have contributed to EPM activities
and been clinically involved in the care
of EPM beneficiaries during the same
performance year for which the EPM
participant accrued the internal cost
savings or earned the reconciliation
payment that comprises the gainsharing
payment or was assessed a repayment
amount. Gainsharing payments,
alignment payments, and internal cost
savings must meet the following
conditions and restrictions:
• Gainsharing payments, if any,
must—
++ Be derived solely from
reconciliation payments, or internal cost
savings, or both;
++ Be distributed on an annual basis
(not more than once per calendar year);
++ Not be a loan, advance payment,
or payment for referrals or other
business; and
++ Be clearly identified as a
gainsharing payment at the time it is
paid.
++ To be eligible to receive a
gainsharing payment, an EPM
collaborator must meet quality of care
criteria for the performance year for
which the EPM participant accrued the
internal cost savings or earned the
reconciliation payment that comprises
the gainsharing payment. The quality of
care criteria must be established by the
EPM participant and directly related to
EPM episodes.
++ To be eligible to receive a
gainsharing payment, or to be required
to make an alignment payment, an EPM
collaborator other than an ACO, PGP,
NPPGP, or TGP must have directly
furnished a billable item or service to an
EPM beneficiary during an EPM episode
that occurred in the same performance
year for which the EPM participant
accrued the internal cost savings or
earned the reconciliation payment that
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comprises the gainsharing payment or
was assessed a repayment amount.
++ To be eligible to receive a
gainsharing payment, or to be required
to make an alignment payment, an EPM
collaborator that is a PGP, NPPGP, or
TGP must meet the following criteria:
—The PGP, NPPGP, or TGP must have
billed for an item or service that was
rendered by one or more PGP
member, NPPGP member, or TGP
member respectively to an EPM
beneficiary during an EPM episode
that occurred during the same
performance year for which the EPM
participant accrued the internal cost
savings or earned the reconciliation
payment that comprises the
gainsharing payment or was assessed
a repayment amount; and
—The PGP, NPPGP, or TGP must have
contributed to EPM activities and
been clinically involved in the care of
EPM beneficiaries during the same
performance year for which the EPM
participant accrued the internal cost
savings or earned the reconciliation
payment that comprises the
gainsharing payment or was assessed
a repayment amount. For example, a
PGP, NPPGP, or TGP might have been
clinically involved in the care of EPM
beneficiaries by—
∧∧ Providing care coordination
services to EPM beneficiaries during
and/or after inpatient admission;
∧∧ Engaging with an EPM participant
in care redesign strategies, and actually
performing a role in implementing such
strategies, that are designed to improve
the quality of care for EPM episodes and
reduce EPM episode spending; or
∧∧ In coordination with other
providers and suppliers (such as PGP
members, NPPGP members, or TGP
members; the EPM participant; and
post-acute care providers),
implementing strategies designed to
address and manage the comorbidities
of EPM beneficiaries.
++ To be eligible to receive a
gainsharing payment, or to be required
to make an alignment payment, an EPM
collaborator that is an ACO must meet
the following criteria:
—The ACO must have had an ACO
provider/supplier that directly
furnished, or an ACO participant that
billed for, an item or service that was
rendered to an EPM beneficiary
during an EPM episode that occurred
during the same performance year for
which the EPM participant accrued
the internal cost savings or earned the
reconciliation payment that comprises
the gainsharing payment or was
assessed a repayment amount; and
—The ACO must have contributed to
EPM activities and been clinically
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involved in the care of EPM
beneficiaries during the same
performance year for which the EPM
participant accrued the internal cost
savings or earned the reconciliation
payment that comprises the
gainsharing payment or was assessed
a repayment amount. For example, an
ACO might be have been clinically
involved in the care of EPM
beneficiaries by—
∧∧ Providing care coordination
services to EPM beneficiaries during
and/or after inpatient admission;
∧∧ Engaging with an EPM participant
in care redesign strategies, and actually
performing a role in implementing such
strategies, that are designed to improve
the quality of care and reduce spending
for EPM episodes; or
∧∧ In coordination with providers
and suppliers (such as ACO
participants, ACO providers/suppliers,
the EPM participant, and post-acute care
providers), implementing strategies
designed to address and manage the
comorbidities of EPM beneficiaries.
++ The methodology for accruing,
calculating and verifying internal cost
savings must be transparent,
measurable, and verifiable in
accordance with generally accepted
accounting principles (GAAP) and
Government Auditing Standards (The
Yellow Book).
++ The methodology used to
calculate internal cost savings must
reflect the actual, internal cost savings
achieved by the EPM participant
through the documented
implementation of EPM activities
identified by the EPM participant and
must exclude:
—Any savings realized by any
individual or entity that is not the
EPM participant; and
++ ‘‘Paper’’ savings from accounting
conventions or past investment in fixed
costs.
• The total amount of a gainsharing
payment for a performance year paid to
certain individuals and entities that are
EPM collaborators must not exceed the
following:
++ In the case of an EPM collaborator
who is a physician or nonphysician
practitioner, 50 percent of the Medicareapproved amounts under the PFS for
items and services furnished by that
physician or nonphysician practitioner
to the EPM participant’s EPM
beneficiaries during EPM episodes that
occurred during the same performance
year for which the EPM participant
accrued the internal cost savings or
earned the reconciliation payment that
comprises the gainsharing payment
being made.
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++ In the case of an EPM collaborator
that is a PGP or NPPGP, 50 percent of
the Medicare-approved amounts under
the PFS for items and services billed by
that PGP or NPPGP and furnished to the
EPM participant’s EPM beneficiaries by
the PGP members or NPPGP members
respectively during EPM episodes that
occurred during the same performance
year for which the EPM participant
accrued the internal cost savings or
earned the reconciliation payment that
comprises the gainsharing payment
being made.
• The amount of any gainsharing
payments must be determined in
accordance with a methodology that is
substantially based on quality of care
and the provision of EPM activities. The
methodology may take into account the
amount of such EPM activities provided
by an EPM collaborator relative to other
EPM collaborators.
• For a performance year, the
aggregate amount of all gainsharing
payments that are derived from a
reconciliation payment the EPM
participant receives from CMS must not
exceed the amount of that reconciliation
payment.
• No entity or individual, whether a
party to a sharing arrangement or not,
may condition the opportunity to make
or receive gainsharing payments or to
make or receive alignment payments
directly or indirectly on the volume or
value of past or anticipated referrals or
business otherwise generated by,
between or among the EPM participant,
any EPM collaborator, any collaboration
agent, any downstream collaboration
agent, or any individual or entity
affiliated with an EPM participant, EPM
collaborator, collaboration agent, or
downstream collaboration agent.
• An EPM participant must not make
a gainsharing payment to an EPM
collaborator if CMS has notified the
EPM participant that such collaborator
is subject to any action for
noncompliance with this part or the
fraud and abuse laws, or for the
provision of substandard care to EPM
beneficiaries or other integrity
problems.
• The sharing arrangement must
require the EPM participant to recoup
any gainsharing payment that contained
funds derived from a CMS overpayment
on a reconciliation report or was based
on the submission of false or fraudulent
data.
• Alignment payments from an EPM
collaborator to an EPM participant may
be made at any interval that is agreed
upon by both parties, and must not be—
++ Issued, distributed, or paid prior
to the calculation by CMS of a
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repayment amount reflected in a
reconciliation report;
++ Loans, advance payments, or
payments for referrals or other business;
or
++ Assessed by an EPM participant if
it does not owe a repayment amount.
• The EPM participant must not
receive any amounts under a sharing
arrangement from an EPM collaborator
that are not alignment payments.
For a performance year, the aggregate
amount of all alignment payments
received by the EPM participant must
not exceed 50 percent of the EPM
participant’s repayment amount.
• The aggregate amount of all
alignment payments from an EPM
collaborator to the EPM participant may
not be greater than—
++ With respect to an EPM
collaborator other than an ACO, 25
percent of the EPM participant’s
repayment amount; or
++ With respect to an EPM
collaborator that is an ACO, 50 percent
of the EPM participant’s repayment
amount.
• The amount of any alignment
payments must be determined in
accordance with a methodology that
does not directly account for the volume
or value of past or anticipated referrals
or business otherwise generated by,
between or among the EPM participant,
any EPM collaborator, any collaboration
agent, any downstream collaboration
agent, or any individual or entity
affiliated with an EPM participant, EPM
collaborator, collaboration agent, or
downstream collaboration agent.
• All gainsharing payments and any
alignment payments must be
administered by the EPM participant in
accordance with generally accepted
accounting principles (GAAP) and
Government Auditing Standards (The
Yellow Book).
• All gainsharing payments and
alignment payments must be made by
check, electronic funds transfer, or
another traceable cash transaction.
d. Documentation Requirements
To ensure the integrity of the sharing
arrangements, we proposed that EPM
participants must meet a variety of
documentation requirements for these
arrangements. Specifically, we proposed
that the EPM participant must—
• Document the sharing arrangement
contemporaneously with the
establishment of the arrangement;
• Maintain accurate current and
historical lists of all EPM collaborators,
including EPM collaborator names and
addresses; update such lists on at least
a quarterly basis; and publicly report the
current and historical lists of EPM
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collaborators on a Web page on the EPM
participant’s Web site; and
• Maintain and require each EPM
collaborator to maintain
contemporaneous documentation with
respect to the payment or receipt of any
gainsharing payment or alignment
payment that includes at a minimum
the—
++ Nature of the payment
(gainsharing payment or alignment
payment);
++ Identity of the parties making and
receiving the payment;
++ Date of the payment;
++ Amount of the payment;
++ Date and amount of any
recoupment of all or a portion of an
EPM collaborator’s gainsharing
payment; and
++ Explanation for each recoupment,
such as whether the EPM collaborator
received a gainsharing payment that
contained funds derived from a CMS
overpayment on a reconciliation report,
or was based on the submission of false
or fraudulent data.
In addition, we proposed that the
EPM participant must keep records for
all of the following:
• Its process for determining and
verifying its potential and current EPM
collaborators’ eligibility to participate in
Medicare.
• Its plan to track internal cost
savings.
• Information on the accounting
systems used to track internal cost
savings;
• A description of current health
information technology, including
systems to track reconciliation
payments and internal cost savings; and
• Its plan to track gainsharing
payments and alignment payments.
Finally, we proposed that the EPM
participant must retain and provide
access to, and must require each EPM
collaborator to retain and provide access
to, the required documentation in
accordance with proposed § 512.110.
The proposals for the requirements for
documentation of sharing arrangements
under the EPM were included in
proposed § 512.500(d). We sought
comment about all of the requirements
set out in the preceding discussion,
including whether additional or
different safeguards would be needed to
ensure program integrity, protect against
abuse, and ensure that the goals of the
EPM were met.
We received no specific comments on
the proposed documentation
requirements for EPM sharing
arrangements other than the comment
discussed previously requesting further
documentation related to the criteria for
selection of EPM collaborators.
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467
Final Decision: We are finalizing the
proposals in § 512.500(d) for EPM
documentation requirements, with the
modification previously discussed to
require the EPM participant to publicly
post the written policies for selecting
EPM collaborators on a Web page on the
EPM participant’s Web site and the
reorganization to consolidate and
streamline the documentation
requirements related to public posting.
EPM sharing arrangements must meet
the following documentation
requirements:
• The EPM participant must do all of
the following:
++ Document the sharing
arrangement contemporaneously with
the establishment of the arrangement.
++ Publicly post (and update on at
least a quarterly basis) on a Web page
on the EPM participant’s Web site:
++ Accurate current and historical
lists of all EPM collaborators, including
EPM collaborator names and addresses.
++ Written policies for selecting
individuals and entities to be EPM
collaborators required by
§ 512.500(a)(3).
++ Maintain and require each EPM
collaborator to maintain
contemporaneous documentation with
respect to the payment or receipt of any
gainsharing payment or alignment
payment that includes at a minimum all
of the following:
—Nature of the payment (gainsharing
payment or alignment payment).
—Identity of the parties making and
receiving the payment.
—Date of the payment.
—Amount of the payment.
—Date and amount of any recoupment
of all or a portion of an EPM
collaborator’s gainsharing payment.
—Explanation for each recoupment,
such as whether the EPM collaborator
received a gainsharing payment that
contained funds derived from a CMS
overpayment on a reconciliation
report, or was based on the
submission of false or fraudulent data.
• The EPM participant must keep
records of the following:
++ Its process for determining and
verifying its potential and current EPM
collaborators’ eligibility to participate in
Medicare.
++ Its plan to track internal cost
savings.
++ Information on the accounting
systems used to track internal cost
savings.
++ A description of current health
information technology, including
systems to track reconciliation
payments and internal cost savings.
++ Its plan to track gainsharing
payments and alignment payments.
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• The EPM participant must retain
and provide access to, and must require
each EPM collaborator to retain and
provide access to, the required
documentation in accordance with
§ 512.110.
5. Distribution Arrangements Under the
EPM
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a. General
Similar to the CJR model, we
proposed that certain financial
arrangements between EPM
collaborators and other individuals or
entities called ‘‘collaboration agents’’ be
termed ‘‘distribution arrangements.’’ A
distribution arrangement would be a
financial arrangement between an EPM
collaborator that was an ACO or PGP
and a collaboration agent for the sole
purpose of sharing a gainsharing
payment received by the ACO or PGP.
We proposed that a collaboration agent
would be an individual or entity that
was not an EPM collaborator and that
was either a PGP member that had
entered into a distribution arrangement
with the same PGP in which he or she
was an owner or employee or an ACO
participant or ACO provider/supplier
that had entered into a distribution
arrangement with the same ACO in
which it was participating. Where a
payment from an EPM collaborator to a
collaboration agent was made pursuant
to an EPM distribution arrangement, we
proposed to define that payment as a
‘‘distribution payment.’’ A collaboration
agent could only make a distribution
payment in accordance with a
distribution arrangement which
complied with the provisions of
proposed § 512.505 and all other
applicable laws and regulations,
including the fraud and abuse laws.
The proposals for the general
provisions for distribution arrangements
under the EPM were included in
proposed § 512.505(a). We sought
comment about all of the provisions set
out in the preceding discussion,
including whether additional or
different safeguards would be needed to
ensure program integrity, protect against
abuse, and ensure that the goals of the
EPM were met.
We received no specific comments on
the proposed general provisions for
distribution arrangements under the
EPM.
Final Decision: We are finalizing the
proposals in § 512.505(a) for the general
requirements for EPM distribution
arrangements, with modification to
allow NPPGPs or TGPs to enter into
distribution arrangements with NPPGP
members or TGP members respectively.
Similar to PGPs when they are EPM
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collaborators, we believe it is
appropriate to allow NPPGPs or TGPs to
enter into distribution arrangements
with NPPGP members or TGP members
respectively for the sole purpose of
sharing a gainsharing payment received
by the NPPGP or TGP. Distribution
arrangements under the EPM must
comply with the following general
provisions:
• An ACO, PGP, NPPGP, or TGP that
has entered into a sharing arrangement
with an EPM participant may distribute
all or a portion of any gainsharing
payment it receives from the EPM
participant only in accordance with a
distribution arrangement.
• All distribution arrangements must
comply with the provisions of this
section and all other applicable laws
and regulations, including the fraud and
abuse laws.
b. Requirements
We proposed a number of specific
requirements for distribution
arrangements as a program integrity
safeguard to help ensure that their sole
purpose was to create financial
alignment between EPM collaborators
and collaboration agents toward the
goals of the EPM to improve the quality
and efficiency of EPM episodes. These
requirements largely paralleled those
proposed in § 512.500(b) and (c) for
sharing arrangements and gainsharing
payments based on similar reasoning for
these two types of arrangements and
payments. We proposed that all
distribution arrangements must be in
writing and signed by the parties,
contain the date of the agreement, and
be entered into before care was
furnished to EPM beneficiaries under
the distribution arrangement.
Furthermore, we proposed that
participation must be voluntary and
without penalty for nonparticipation,
and the distribution arrangement must
require the collaboration agent to
comply with all applicable laws and
regulations.
Like our proposal for gainsharing
payments, we proposed that the
opportunity to make or receive a
distribution payment must not be
conditioned directly or indirectly on the
volume or value of past or anticipated
referrals or business otherwise
generated by, between or among the
EPM participant, any EPM collaborator,
any collaboration agent, any
downstream collaboration agent, or any
individual or entity affiliated with an
EPM participant, EPM collaborator,
collaboration agent, or downstream
collaboration agent. We proposed more
flexible standards for the determination
of the amount of distribution payments
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from ACOs and PGPs for the same
reasons we proposed this standard for
the determination of gainsharing
payments. Specifically, for ACOs we
proposed that the amount of any
distribution payments must be
determined in accordance with a
methodology that was substantially
based on quality of care and the
provision of EPM activities and that
may take into account the amount of
such EPM activities provided by a
collaboration agent relative to other
collaboration agents. In the proposed
rule, we discussed our belief that the
amount of a collaboration agent’s
provision of EPM activities (including
direct care) to EPM beneficiaries during
EPM episodes might contribute to the
EPM participant’s internal cost savings
and reconciliation payment that might
be available for making a gainsharing
payment to the EPM collaborator with
which the collaboration agent had a
distribution arrangement. Greater
contributions of EPM activities by one
collaboration agent versus another
collaboration agent that resulted in
different contributions to the
gainsharing payment made to the EPM
collaborator with which those
collaboration agents both had a
distribution arrangement might be
appropriately valued in the
methodology used to make distribution
payments to those collaboration agents.
Accordingly, we believed this would be
the appropriate standard for
determining the amount of distribution
payments from an ACO to its
collaboration agents.
We noted that for distribution
payments made by a PGP to PGP
members, the requirement that the
amount of any distribution payments
must be determined in accordance with
a methodology that was substantially
based on quality of care and the
provision of EPM activities might be
more limiting in how a PGP paid its
members than was allowed under
existing law. Therefore, to retain
existing flexibility for distribution
payments by a PGP to PGP members, we
proposed that the amount of the
distribution payment from a PGP to PGP
members must be determined either
using the methodology previously
described for distribution payments
from an ACO or in a manner that
complied with § 411.352(g). We noted
that the proposed option to allow the
amount of the distribution payment
from a PGP to a PGP member to be
determined in a manner that complied
with § 411.352(g) was not currently
permitted under the CJR model,
although we proposed this change for
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the CJR model in section V.J. of the
proposed rule (81 FR 50965). This
proposal would allow a PGP the choice
either to comply with the general
standard that the amount of a
distribution payment must be
substantially based on quality of care
and the provision of EPM activities or
to provide its members a financial
benefit through the EPM without
consideration of the PGP member’s
individual quality of care. In the latter
case, PGP members who were not
collaboration agents (including those
who furnished no services to EPM
beneficiaries) would be able receive a
share of the profits from their PGP that
included the monies contained in a
gainsharing payment. We believed this
would be an appropriate exception to
the general standard for determining the
amount of distribution payment under
the EPM from a PGP to a PGP member
because CMS has determined under the
physician self-referral law that
payments from a group practice as
defined under § 411.352 to its members
that comply with § 411.352(g) are
appropriate.
We sought comment on this proposal
and specifically whether there were
additional safeguards or a different
standard was needed to allow for greater
flexibility in calculating the amount of
distribution payments that would avoid
program integrity risks and whether
additional or different safeguards were
reasonable, necessary, or appropriate for
the amount of distribution payments
from a PGP to its members.
Similar to our proposed requirements
for sharing arrangements for those EPM
collaborators that furnished or billed for
items and services, except for a
distribution payment from a PGP to a
PGP member that complied with
§ 411.352(g), we proposed that a
collaboration agent would be eligible to
receive a distribution payment only if
the collaboration agent furnished or
billed for an item or service rendered to
an EPM beneficiary during an EPM
episode that occurred during the same
performance year for which the EPM
participant accrued the internal cost
savings or earned the reconciliation
payment that comprised the gainsharing
payment being distributed. We noted
that all individuals and entities that fell
within our proposed definition of
collaboration agent might either directly
furnish or bill for items and services
rendered to EPM beneficiaries. This
proposal ensured that, absent the
alternative safeguards afforded by a
PGP’s distribution payments in
compliance with § 411.352(g), there
would be the same required relationship
between direct care for EPM
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beneficiaries during EPM episodes and
distribution payment eligibility that we
proposed to require for gainsharing
payment eligibility. We believed this
requirement would provide a safeguard
against payments to collaboration agents
that were unrelated to direct care for
EPM beneficiaries during EPM episodes
when the amount of the distribution
payment was not determined in a
manner that complies with § 411.352(g).
Except for a distribution payment
from a PGP to a PGP member that
complied with § 411.352(g), we
proposed the same limitations on the
total amount of distribution payments to
physicians, nonphysician practitioners,
and PGPs as we proposed for
gainsharing payments. In the case of a
collaboration agent that was a physician
or nonphysician practitioner, we
proposed to limit the total amount of
distribution payments paid for a
performance year to the collaboration
agent to 50 percent of the total
Medicare-approved amounts under the
PFS for items and services furnished by
the collaboration agent to the EPM
participant’s EPM beneficiaries during
EPM episodes that occurred during the
same performance year for which the
EPM participant accrued the internal
cost savings or earned the reconciliation
payment that comprised the gainsharing
payment being distributed. In the case
of a collaboration agent that was a PGP,
we proposed that the limit would be 50
percent of the total Medicare-approved
amounts under the PFS for items and
services billed by the PGP for items and
services furnished by members of the
PGP to the EPM participant’s EPM
beneficiaries during EPM episodes that
occurred during the same performance
year for which the EPM participant
accrued the internal cost savings or
earned the reconciliation payment that
comprised the gainsharing payment
being distributed. In the proposed rule,
we discussed our belief that, absent the
alternative safeguards afforded by a
PGP’s distribution payments in
compliance with § 411.352(g), these
proposed limitations on distribution
payments, which were the same as those
for proposed for gainsharing payments
to physicians, nonphysician
practitioners, and PGPs, were necessary
to eliminate any financial incentives for
these individuals or entities to engage in
a financial arrangement as an EPM
collaborator versus as a collaboration
agent. Furthermore, we believed that
PGPs should be able to choose whether
to engage in financial arrangements
directly with EPM participants as EPM
collaborators or in distribution
arrangements with the ACO in which
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469
they were an ACO participant if that
ACO played a role in EPM care redesign
as an EPM collaborator, without having
a different limit on their maximum
financial gain from one arrangement
versus another.
We further proposed that with respect
to the distribution of any gainsharing
payment received by a PGP or ACO, the
total amount of all distribution
payments must not exceed the amount
of the gainsharing payment received by
the EPM collaborator from the EPM
participant. Like gainsharing and
alignment payments, we proposed that
all distribution payments must be made
by check, electronic funds transfer, or
another traceable cash transaction. The
collaboration agent must retain the
ability to make decisions in the best
interests of the patient, including the
selection of devices, supplies, and
treatments. Finally, we proposed that
the distribution arrangement must not
induce the collaboration agent to reduce
or limit medically necessary items and
services to any Medicare beneficiary or
reward the provision of items and
services that were medically
unnecessary.
We proposed that the EPM
collaborator must maintain
contemporaneous documentation
regarding distribution arrangements in
accordance with proposed § 512.110,
including:
• The relevant written agreements;
• The date and amount of any
distribution payment(s);
• The identity of each collaboration
agent that received a distribution
payment; and
• A description of the methodology
and accounting formula for determining
the amount of any distribution payment.
We proposed that the EPM
collaborator may not enter into a
distribution arrangement with any
individual or entity that has a sharing
arrangement with the same EPM
participant. This proposal would ensure
that the proposed separate limitations
on the total amount of gainsharing
payment and distribution payment to
PGPs, physicians, and nonphysician
practitioners that were substantially
based on quality of care and the
provision of EPM activities were not
exceeded in absolute dollars by a PGP,
physician, or nonphysician
practitioner’s participation in both a
sharing arrangement and distribution
arrangement for the care of the same
EPM beneficiaries during EPM episodes.
Allowing both types of arrangements for
the same individual or entity for care of
the same EPM beneficiaries during EPM
episodes could also allow for duplicate
counting of the individual or entity’s
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same quality of care and provision of
EPM activities in the methodologies for
both gainsharing and distribution
payments, leading to financial gain that
was disproportionate to the quality of
care and provision of EPM activities by
that individual or entity. Finally, we
proposed that the EPM collaborator
must retain and provide access to, and
must require collaboration agents to
retain and provide access to, the
required documentation in accordance
with proposed § 512.110.
The proposals for requirements for
distribution arrangements under the
EPM were included in proposed
§ 512.505(b). We sought comment about
all of the requirements set out in the
preceding discussion, including
whether additional or different
safeguards would be needed to ensure
program integrity, protect against abuse,
and ensure that the goals of the EPM
were met. In addition, we sought
comment on how the regulation of the
financial arrangements under this
proposal might interact with how these
or similar financial arrangements are
regulated under the Medicare Shared
Savings Program.
The following is a summary of the
comments received and our responses.
Comment: One commenter who
expressed support for the proposed cap
on distribution and downstream
distribution payments by PGPs to
individual clinicians at 50 percent of
the total Medicare-approved amounts
under the PFS for items and services
furnished by the clinician to the EPM
participant’s EPM beneficiaries during
EPM episodes in the applicable time
period opposed CMS’ proposal to
eliminate the requirements to link
quality to these payments and for the
clinicians to provide services to EPM
beneficiaries in EPM episodes for PGP
payments to clinicians under a
methodology that complies with
§ 411.352(g). The commenter observed
that under CMS’ proposal, distribution
arrangements would be subject to many
of the same requirements as sharing
arrangements. They claimed that while
some PGPs may want to cascade funds
in the same way as other funds that are
paid in accordance with § 411.352(g), a
provision that prohibits physicians in a
group practice from being directly or
indirectly compensated based on the
volume or value of his or her referrals,
the commenter believes that the
provision of all payments under EPM
financial arrangements, including
gainsharing payments, distribution
payments, and downstream distribution
payments, should have a direct
association with high-quality, cost-
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effective care furnished to EPM
beneficiaries.
Response: We appreciate the
commenter’s concerns about our
proposal to allow distribution payments
and downstream distribution payments
to be made by a PGP to PGP members
either based on a methodology that
complies with § 411.352(g) or in
accordance with a methodology that is
substantially based on quality of care
and the provision of EPM activities.
Under the latter methodology, we
proposed that the PGP member who is
a collaboration agent or a downstream
collaboration agent would be eligible to
receive a payment if he or she furnished
or billed for an item or service rendered
to an EPM beneficiary during an EPM
episode during the applicable time
period and the total amount of payment
for a performance year would be subject
to a cap. These requirements would not
apply to distribution or downstream
distribution payments by a PGP to PGP
members based on a methodology that
complies with § 411.352(g).
We remain concerned that without
the § 411.352(g) exception that we
proposed, the distribution and
downstream distribution methodologies
would be more limiting in how a PGP
pays its members than is allowed under
existing law. Our proposal would allow
a PGP the choice either to comply with
the standard under the EPM that the
amount of a distribution payment or
downstream distribution payment must
be substantially based on quality of care
and the provision of EPM activities or
to provide its members a financial
benefit under the general standard at
§ 411.352(g) without consideration of
the PGP member’s individual quality of
care. In the latter case, PGP members
who are not collaboration agents or
downstream collaboration agents
(including those who furnished no
services to EPM beneficiaries) would be
able receive a share of the profits from
their PGP that includes the monies
contained in a gainsharing or
distribution payment. We continue to
believe this is an appropriate exception
to the standard created under the EPM
for determining the amount of
distribution payment under the EPM
from a PGP to a PGP member because
CMS has determined under the
physician self-referral law that
payments from a group practice as
defined under § 411.352 to its members
that comply with § 411.352(g) are
appropriate. We note that even in such
cases, our proposal includes some
requirements to ensure a nexus between
the financial arrangements and the care
provided by PGP members to
beneficiaries in EPM episodes. In
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addition to the requirement in
§ 512.500(c)(2)(i) that for any EPM
collaborator to be eligible receive a
gainsharing payment, the EPM
collaborator must meet quality of care
criteria for the performance year, under
§ 512.500(c)(2)(iii) we further specify
that for PGPs to be eligible to receive a
gainsharing payment the PGP also must
have billed for an item or service that
was rendered by one or more members
of the PGP to an EPM beneficiary during
an EPM episode during the applicable
time period and that the PGP must have
contributed substantially to EPM
activities and been clinically involved
in the care of EPM beneficiaries during
that same time period. We believe these
requirements for gainsharing eligibility
establish a clear link between the
quality of care furnished to EPM
beneficiaries by PGP members and EPM
activities by the PGP and the subsequent
financial arrangements between the PGP
and its members. In addition, we require
in § 512.505(b)(5) that the amount of any
distribution payments from an ACO
(including those to a PGP) must be
determined in accordance with a
methodology that is substantially based
on quality of care and the provision of
EPM activities. Therefore, we believe
there is a sufficiently close link between
distribution payments and downstream
distribution payments that comply with
§ 411.352(g) and the quality of care
furnished to EPM beneficiaries by PGP
members and EPM activities by the PGP
that allowing payments by the PGP to its
members that comply with § 411.352(g)
does not substantially threaten the
important relationship between
payments under the EPM financial
arrangements and the quality of
furnished to EPM beneficiaries in EPM
episodes.
We are finalizing in §§ 512.505(6) and
512.510(6) that the amount of any
distribution payments or downstream
distribution payments from a PGP to a
PGP member must be determined either
in a manner that complies with
§ 411.352(g) of this chapter or in
accordance with a methodology that is
substantially based on quality of care
and the provision EPM activities.
Comment: One commenter requested
clarification about whether a provider of
outpatient therapy services can receive
distribution payments or downstream
distribution payments as either a
member of a PGP who is an EPM
collaborator or as a member of a PGP
that is an ACO participant in an ACO
that has a distribution arrangement with
an EPM collaborator.
Other commenters sought to clarify
whether groups of nonphysician
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practitioners could enter into financial
arrangements under the EPM.
Response: The definition of a member
of a PGP or PGP member means ‘‘a
physician, nonphysician practitioner, or
therapist who is an owner or employer
of a PGP and who has reassigned to the
PGP his or her right to receive Medicare
payment.’’ Thus, therapists who are PGP
members may be eligible to receive
distribution payments or downstream
distribution payments when those PGPs
enter into financial arrangements under
the EPM in accordance with all the
requirements in this final rule. We are
finalizing in § 512.2 the definition of
member of the PGP or PGP member to
include therapists.
Moreover, as we discussed
previously, in response to commenters’
confusion regarding the permissibility
of financial arrangements for therapists
both as individuals and as part of
groups we adopt multiple clarifications
in this final rule to affirm the
permissibility of such arrangements and
to clarify the applicable requirements.
In addition to the adoption of new
definitions that clarify the sharing
arrangements available to therapists in
private practice or TGPs as discussed
previously, this final rule adopts
parameters for TGPs and therapists in
private practice to receive distribution
payments from an ACO that is an EPM
collaborator, for TGPs to make
distribution payments and downstream
distribution payments to their members,
and for therapists to receive distribution
payments and downstream distribution
payments as either members of NPPGPs
or members of TGPs.
Similarly, in response to commenters
seeking clarity on whether groups of
nonphysician practitioners are eligible
to enter into financial arrangements
under the EPM that mirror those
expressly permitted for PGPs, in this
final rule, we affirm the permissibility
of and parameters for such arrangements
for NPPGPs. In addition to the
provisions discussed previously and as
discussed further later in this section,
the final rule establishes parameters for
distribution payments to NPPGPs that
directly parallel the parameters we
proposed and now finalize for such
payments to PGPs. Similarly, as is also
discussed further later in this section,
the parameters for distribution
payments and downstream distribution
payments by an NPPGP to its members
directly parallel the parameters for
distribution payments and downstream
distribution payments by a PGP to its
members as proposed and adopted in
this final rule except for, due to the
inapplicability of the physician selfreferral law and its exceptions, NPPGPs
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do not have the options afforded to
PGPs to make distributions to their
members in a manner that complies
with § 411.352(g) of this chapter.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposals in § 512.505(b)
for the requirements for EPM
distribution arrangements, with
modification to include policies for
NPPGPs or TGPs that enter into
distribution arrangements with NPPGP
members or TGP members respectively.
Like a PGP, an NPPGP that is an ACO
participant in an ACO that is an EPM
collaborator may enter into distribution
arrangement with the ACO. The
distribution payments to the NPPGP are
subject to the same requirements as the
distribution payments to PGPs that are
collaboration agents. The NPPGP is
eligible to receive a distribution
payment only if the collaboration agent
billed for an item or service rendered to
an EPM beneficiary during an EPM
episode that occurred during the same
performance year for which the EPM
participant accrued the internal cost
savings or earned the reconciliation
payment that comprises the gainsharing
payment being distributed. The
distribution payment to the NPPGP is
capped at 50 percent of the total
Medicare-approved amounts under the
PFS for items and services billed by the
NPPGP for items and services furnished
by NPPGP members to the EPM
participant’s EPM beneficiaries during
EPM episodes that occurred during the
same performance year for which the
EPM participant accrued the internal
cost savings or earned the reconciliation
payment that comprises the gainsharing
payment being distributed.
If an NPPGP is an EPM collaborator,
it may enter into a distribution
arrangement with a NPPGP member,
who is a nonphysician practitioner or
therapist who is an owner or employee
of a NPPGP and who has reassigned to
the NPPGP his or her right to receive
Medicare payment. The requirements
for NPPGP distribution payments under
those distribution arrangements are the
same as those for PGPs, except that we
allow the amount of any distribution
payments from a PGP to a PGP member
to be determined in a manner that
complies with § 411.352(g). While CMS
has determined that under the physician
self-referral law payments from a group
practice as defined under § 411.352 to
its members that comply with
§ 411.352(g) are appropriate, NPPGPs do
not fall under this definition of group
practice. Therefore, the amount of any
distribution payments from a NPPGP to
a NPPGP member must always be
determined in accordance with a
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471
methodology that is substantially based
on quality of care and the provision
EPM activities, the same standard that
applies to PGP distribution payments
that are not determined in a manner that
complies with § 411.352(g). Like the
requirement for PGP members when a
distribution payment does not comply
with § 411.352(g), a NPPGP member is
eligible to receive a distribution
payment only if the collaboration agent
furnished an item or service to an EPM
beneficiary during an EPM episode that
occurred during the same performance
year for which the EPM participant
accrued the internal cost savings or
earned the reconciliation payment that
comprises the gainsharing payment
being distributed. Finally, the total
amount of distribution payments paid
for a performance year to the NPPG
member may not exceed 50 percent of
the total Medicare-approved amounts
under the PFS for items and services
furnished by the NPPGP member to the
EPM participant’s EPM beneficiaries
during EPM episodes that occurred
during the same performance year for
which the EPM participant accrued the
internal cost savings or earned the
reconciliation payment that comprises
the gainsharing payment being
distributed. In addition, with respect to
the distribution of any gainsharing
payment received by a NPPGP, the total
amount of all distribution payments
must not exceed the amount of the
gainsharing payment received by the
EPM collaborator from the EPM
participant.
Like a PGP and NPPGP, a TGP that is
an ACO participant in an ACO that is an
EPM collaborator may enter into
distribution arrangement with the ACO.
The distribution payments to the TGP
are not subject to the cap that applies to
PGPs and NPPGPs. While we cap
distribution payments to physicians and
nonphysician practitioners, we will not
cap such payments to therapists in
private practice for the same reasons
discussed for gainsharing payments to
these individuals and, therefore, we will
not cap distribution payments to TGPs.
Like PGPs and NPPGPs, the TGP is
eligible to receive a distribution
payment only if the collaboration agent
billed for an item or service rendered to
an EPM beneficiary during an EPM
episode that occurred during the same
performance year for which the EPM
participant accrued the internal cost
savings or earned the reconciliation
payment that comprises the gainsharing
payment being distributed.
If a TGP is an EPM collaborator, it
may enter into a distribution
arrangement with a TGP member, who
is a therapist who is an owner or
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employee of a TGP and who has
reassigned to the TGP his or her right to
receive Medicare payment. Like
distribution payments from a NPPGP to
a NPPGP member, the amount of any
distribution payments from a TGP to a
TGP member must be determined in
accordance with a methodology that is
substantially based on quality of care
and the provision EPM activities, the
same standard that applies to PGP
distribution payments that are not
determined in a manner that complies
with § 411.352(g). Like the requirement
for PGP members when a distribution
payment does not comply with
§ 411.352(g) and for NPPG members, a
TGP member is eligible to receive a
distribution payment only if the
collaboration agent furnished an item or
service to an EPM beneficiary during an
EPM episode that occurred during the
same performance year for which the
EPM participant accrued the internal
cost savings or earned the reconciliation
payment that comprises the gainsharing
payment being distributed. We will not
cap the total amount of distribution
payments paid for a performance year to
a TGP member for the reasons discussed
previously for not applying caps on
gainsharing payments to therapists in
private practice. Finally, with respect to
the distribution of any gainsharing
payment received by a TGP, the total
amount of all distribution payments
must not exceed the amount of the
gainsharing payment received by the
EPM collaborator from the EPM
participant.
Distribution arrangements under the
EPM must comply with the following
requirements:
• All distribution arrangements must
be in writing and signed by the parties,
contain the date of the agreement, and
be entered into before care is furnished
to EPM beneficiaries under the
distribution arrangement.
• Participation in a distribution
arrangement must be voluntary and
without penalty for nonparticipation.
• The distribution arrangement must
require the collaboration agent to
comply with all applicable laws and
regulations.
• The opportunity to make or receive
a distribution payment must not be
conditioned directly or indirectly on the
volume or value of past or anticipated
referrals or business otherwise
generated by, between or among the
EPM participant, any EPM collaborator,
any collaboration agent, any
downstream collaboration agent, or any
individual or entity affiliated with an
EPM participant, EPM collaborator,
collaboration agent, or downstream
collaboration agent.
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• The amount of any distribution
payments from an ACO, from a NPPGP
to a NPPGP member, or from a TGP to
a TGP member must be determined in
accordance with a methodology that is
substantially based on quality of care
and the provision EPM activities and
that may take into account the amount
of such EPM activities provided by a
collaboration agent relative to other
collaboration agents.
• The amount of any distribution
payments from a PGP must be
determined either in a manner that
complies with § 411.352(g) of this
chapter or in accordance with a
methodology that is substantially based
on quality of care and the provision
EPM activities and that may take into
account the amount of such EPM
activities provided by a collaboration
agent relative to other collaboration
agents.
• Except for a distribution payment
from a PGP to a PGP member that
complies with § 411.352(g) of this
chapter, a collaboration agent is eligible
to receive a distribution payment only if
the collaboration agent furnished or
billed for an item or service rendered to
an EPM beneficiary during an EPM
episode that occurred during the same
performance year for which the EPM
participant accrued the internal cost
savings or earned the reconciliation
payment that comprises the gainsharing
payment being distributed.
• Except for a distribution payment
from a PGP to a PGP member that
complies with § 411.352(g) of this
chapter, the total amount of distribution
payments for a performance year paid to
a collaboration agent must not exceed
the following:
++ In the case of a collaboration agent
that is a physician or nonphysician
practitioner, 50 percent of the total
Medicare-approved amounts under the
PFS for items and services furnished by
the collaboration agent to the EPM
participant’s EPM beneficiaries during
EPM episodes that occurred during the
same performance year for which the
EPM participant accrued the internal
cost savings or earned the reconciliation
payment that comprises the gainsharing
payment being distributed.
++ In the case of a collaboration agent
that is a PGP or NPPGP, 50 percent of
the total Medicare-approved amounts
under the PFS for items and services
billed by that PGP or NPPGP for items
and services furnished by PGP members
or NPPGP members to the EPM
participant’s EPM beneficiaries during
EPM episodes that occurred during the
same performance year for which the
EPM participant accrued the internal
cost savings or earned the reconciliation
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payment that comprises the gainsharing
payment being distributed.
• With respect to the distribution of
any gainsharing payment received by an
ACO, PGP, NPPGP, or TGP, the total
amount of all distribution payments
must not exceed the amount of the
gainsharing payment received by the
EPM collaborator from the EPM
participant.
• All distribution payments must be
made by check, electronic funds
transfer, or another traceable cash
transaction.
• The collaboration agent must retain
the ability to make decisions in the best
interests of the patient, including the
selection of devices, supplies, and
treatments.
• The distribution arrangement must
not—
++ Induce the collaboration agent to
reduce or limit medically necessary
items and services to any Medicare
beneficiary; or
++ Reward the provision of items and
services that are medically unnecessary.
• The EPM collaborator must
maintain contemporaneous
documentation regarding distribution
arrangements in accordance with
§ 512.110, including the following:
++ The relevant written agreements;
++ The date and amount of any
distribution payment(s);
++ The identity of each collaboration
agent that received a distribution
payment; and
++ A description of the methodology
and accounting formula for determining
the amount of any distribution payment.
• The EPM collaborator may not enter
into a distribution arrangement with any
individual or entity that has a sharing
arrangement with the same EPM
participant.
• The EPM collaborator must retain
and provide access to, and must require
collaboration agents to retain and
provide access to, the required
documentation in accordance with
§ 512.110.
6. Downstream Distribution
Arrangements Under the EPM
a. General
We proposed that the EPM allow for
certain financial arrangements within an
ACO between a PGP and its members.
Specifically, we proposed that certain
financial arrangements between a
collaboration agent that was both a PGP
and an ACO participant and other
individuals termed ‘‘downstream
collaboration agents’’ be termed a
‘‘downstream distribution
arrangement.’’ A downstream
distribution arrangement would be a
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financial arrangement between a
collaboration agent that was both a PGP
and an ACO participant and a
downstream collaboration agent for the
sole purpose of sharing a distribution
payment received by the PGP. We
proposed that a downstream
collaboration agent would be an
individual who was not an EPM
collaborator or a collaboration agent and
who was a PGP member that had
entered into a downstream distribution
arrangement with the same PGP in
which he or she was an owner or
employee, and where the PGP was a
collaboration agent. Where a payment
from a collaboration agent to a
downstream collaboration agent was
made pursuant to a downstream
distribution arrangement, we proposed
to define that payment as a
‘‘downstream distribution payment.’’ A
collaboration agent may only make a
downstream distribution payment in
accordance with a downstream
distribution arrangement which
complied with the requirements of this
section and all other applicable laws
and regulations, including the fraud and
abuse laws.
The proposals for the general
provisions for downstream distribution
arrangements under the EPM were
included in proposed § 512.510(a). We
sought comment about all of the
provisions set out in the preceding
discussion, including whether
additional or different safeguards would
be needed to ensure program integrity,
protect against abuse, and ensure that
the goals of the EPM were met.
We received no specific comments on
the proposed general provisions for
downstream distribution arrangements
under the EPM; however, the comments
described previously regarding
commenters’ confusion regarding the
permissibility of financial arrangements
for individuals and groups of therapists
and nonphysician practitioners under
our proposal are relevant to these
provisions.
Final Decision: We are finalizing the
proposals in § 512.510(a) for the general
requirements for EPM downstream
distribution arrangements, with
modification to allow NPPGPs or TGPs
to enter into downstream distribution
arrangements with NPPGP members or
TGP members respectively. Downstream
distribution arrangements under the
EPM must comply with the following
general provisions:
• An ACO participant that is a PGP,
NPPGP, or TGP and that has entered
into a distribution arrangement with an
EPM collaborator that is an ACO may
distribute all or a portion of any
distribution payment it receives from
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the EPM collaborator only in accordance
with a downstream distribution
arrangement.
• All downstream distribution
arrangements must comply with the
provisions of this section and all
applicable laws and regulations,
including the fraud and abuse laws.
b. Requirements
We proposed a number of specific
requirements for downstream
distribution arrangements as a program
integrity safeguard to help ensure that
their sole purpose was to create
financial alignment between
collaboration agents that were PGPs
which were also ACO participants and
downstream collaboration agents toward
the goals of the EPM to improve the
quality and efficiency of EPM episodes.
These proposed requirements largely
paralleled those proposed in proposed
§ 512.500(b) and (c) and § 512.505(b) for
sharing and distribution arrangements
and gainsharing and distribution
payments based on similar reasoning for
these three types of arrangements and
payments. We proposed that all
downstream distribution arrangements
must be in writing and signed by the
parties, contain the date of the
agreement, and entered into before care
was furnished to EPM beneficiaries
under the downstream distribution
arrangement. Furthermore, we proposed
that participation must be voluntary and
without penalty for nonparticipation,
and the downstream distribution
arrangement must require the
downstream collaboration agent to
comply with all applicable laws and
regulations.
Like our proposals for gainsharing
and distribution payments, we proposed
that the opportunity to make or receive
a downstream distribution payment
must not be conditioned directly or
indirectly on the volume or value of
past or anticipated referrals or business
otherwise generated by, between or
among the EPM participant, any EPM
collaborator, any collaboration agent,
any downstream collaboration agent, or
any individual or entity affiliated with
an EPM participant, EPM collaborator,
collaboration agent, or downstream
collaboration agent. We proposed the
more flexible standard for the
determination of the amount of
downstream distribution payments for
the same reasons we proposed this
standard for the determination of
distribution payments by a PGP to PGP
members. Specifically, the amount of
any downstream distribution payments
must be determined either in a manner
that complies with § 411.352(g) or in
accordance with a methodology that
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473
was substantially based on quality of
care and the provision of EPM activities
and that may take into account the
amount of such EPM activities provided
by a downstream collaboration agent
relative to other downstream
collaboration agents. In the proposed
rule, we discussed our belief that the
amount of a downstream collaboration
agent’s provision of EPM activities
(including direct care) to EPM
beneficiaries during EPM episodes
might contribute to the EPM
participant’s internal cost savings and
reconciliation payment that might be
available for making a gainsharing
payment to the EPM collaborator that
was then shared through a distribution
payment to the collaboration agent with
which the downstream collaboration
agent had a downstream distribution
arrangement. Greater contributions of
EPM activities by one downstream
collaboration agent versus another
downstream collaboration agent that
resulted in different contributions to the
distribution payment made to the
collaboration agent with which the
downstream collaboration agents both
had a downstream distribution
arrangement might be appropriately
valued in the methodology used to make
downstream distribution payments to
those downstream collaboration agents.
Just as we proposed an alternative to a
methodology that was substantially
based on quality of care and the
provision of EPM activities for
determining the amount of a
distribution payment from a PGP to a
PGP member, we similarly proposed an
alternative that the amount of a
downstream distribution payment from
a PGP to a PGP member may be
determined in a manner that complied
with § 411.352(g)
Similar to our proposed requirements
for distribution arrangements for those
EPM collaborators that were PGPs, we
proposed that, except for a downstream
distribution arrangement that complied
with § 411.352(g), a downstream
collaboration agent would be eligible to
receive a downstream distribution
payment only if the PGP billed for an
item or service furnished by the
downstream collaboration agent to an
EPM beneficiary during an EPM episode
that occurred during the same
performance year for which the EPM
participant accrued the internal cost
savings or earned the reconciliation
payment that comprised the gainsharing
payment from which the ACO made the
distribution payment to the PGP that
was an ACO participant. This proposal
would ensure that, absent the
alternative safeguards afforded by a
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PGP’s downstream distribution
payments in compliance with
§ 411.352(g), there would be the same
required relationship between direct
care for EPM beneficiaries during EPM
episodes and downstream distribution
payment eligibility that we proposed to
require for gainsharing and distribution
payment eligibility. We believed this
requirement would provide a safeguard
against payments to downstream
collaboration agents that were unrelated
to direct care for EPM beneficiaries
during EPM episodes when the amount
of the downstream distribution payment
was not determined in a manner that
complied with § 411.352(g).
We proposed the same limitations on
downstream distribution payments to
downstream collaboration agents as we
proposed for distribution payments by
EPM collaborators that were PGPs. We
proposed that, absent the alternative
safeguards afforded by compliance with
§ 411.352(g), the total amount of
downstream distribution payments paid
for a performance year to the
downstream collaboration agent would
be limited to 50 percent of the total
Medicare-approved amounts under the
PFS for services billed by the PGP and
furnished by the downstream
collaboration agent to the EPM
participant’s EPM beneficiaries during
EPM episodes that occurred during the
same performance year for which the
EPM participant accrued the internal
cost savings or earned the reconciliation
payment that comprised the gainsharing
payment from which the ACO made the
distribution payment to the PGP. We
believed that, absent the alternative
safeguards afforded by a PGP’s
downstream distribution payments in
compliance with § 411.352(g), this
proposed limitation on downstream
distribution payments that was the same
as those for distribution payments to
physicians and nonphysician
practitioners was necessary to eliminate
any financial incentives for a PGP
member to engage in a specific financial
arrangement as a collaboration agent
versus a downstream collaboration
agent.
We further proposed that the total
amount of all downstream distribution
payments made to downstream
collaboration agents must not exceed
the amount of the distribution payment
received by the collaboration agent (that
is, the PGP that was an ACO participant)
from the ACO that was an EPM
collaborator. Like gainsharing,
alignment, and distribution payments,
we proposed that all downstream
distribution payments must be made by
check, electronic funds transfer, or
another traceable cash transaction. The
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downstream collaboration agent must
retain the ability to make decisions in
the best interests of the patient,
including the selection of devices,
supplies, and treatments. The
distribution arrangement must not
induce a downstream collaboration
agent to reduce or limit medically
necessary items and services to any
Medicare beneficiary or reward the
provision of items and services that
were medically unnecessary.
We proposed that the PGP must
maintain contemporaneous
documentation regarding downstream
distribution arrangements in accordance
with proposed § 512.110, including all
of the following:
• The relevant written agreements.
• The date and amount of any
downstream distribution payment(s).
• The identity of each downstream
collaboration agent that received a
downstream distribution payment.
• A description of the methodology
and accounting formula for determining
the amount of any downstream
distribution payment.
We proposed that the PGP may not
enter into a downstream distribution
arrangement with any PGP member who
had a sharing arrangement with an EPM
participant or distribution arrangement
with the ACO the PGP was a participant
in. This proposal would ensure that the
proposed separate limitations on the
total amount of gainsharing payment,
distribution payment, and downstream
distribution payment to PGP members
that were substantially based on quality
of care and the provision of EPM
activities were not exceeded in absolute
dollars by a PGP member’s participation
in more than one type of arrangement
for the care of the same EPM
beneficiaries during EPM episodes.
Allowing more than one arrangement
for the same PGP member for the care
of the same EPM beneficiaries during
EPM episodes could also allow for
duplicate counting of the PGP member’s
same quality of care and provision of
EPM activities in the methodologies for
the different payments. Finally, we
proposed that the PGP must retain and
provide access to, and must require
downstream collaboration agents to
retain and provide access to, the
required documentation in accordance
with proposed § 512.110.
The proposals for requirements for
downstream distribution arrangements
under the EPM were included in
proposed § 512.510(b). We sought
comment about all of the requirements
set out in the preceding discussion,
including whether additional or
different safeguards would be needed to
ensure program integrity, protect against
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abuse, and ensure that the goals of the
EPM were met.
We received no specific comments on
the proposed requirements for
downstream distribution arrangements
under the EPM; however, the comments
described previously regarding
commenters’ confusion regarding the
permissibility of financial arrangements
for individuals and groups of therapists
and nonphysician practitioners under
our proposal and regarding the request
to simplify and reduce the burdens
associated with the programmatic
requirements are relevant to these
provisions.
Final Decision: We are finalizing the
proposals in § 512.510(b) for the
requirements for EPM downstream
distribution arrangements, with
modification to include policies for
NPPGPs or TGPs that enter into
downstream distribution arrangements
with NPPGP members or TGP members
respectively. Consistent with
commenters’ overall request that we
streamline the regulations, we are also
modifying proposed § 512.510(b)(6),
which is final § 512.510(b)(7), to
eliminate one of the two proposed
requirements for eligibility of a
downstream collaboration agent to
receive a downstream distribution
payment, specifically the requirement
that the PGP bill for the item or service
furnished by the downstream
collaboration agent. Instead, we base
downstream collaboration agent
eligibility only on whether the
downstream collaboration agent
furnished an item or service to an EPM
beneficiary during an EPM episode that
occurred during the same performance
year for which the EPM participant
accrued the internal cost savings or
earned the reconciliation payment that
comprises the gainsharing payment
from which the ACO made the
distribution payment to the PGP,
NPPGP, or TGP that is an ACO
participant. This approach is parallel to
§ 512.505(b)(7), which applies to
distribution payments from ACOs to
ACO participants or ACO providers/
suppliers and certain distribution
payments from PGPs to PGP members,
and ensures that the member of the PGP,
NPPGP, or TGP receiving the
downstream distribution payment
furnished items and services to an EPM
beneficiary during an EPM episode,
without explicitly requiring that the
PGP, NPPGP, or TGP to which the
member of the PGP, NPPGP, or TGP
would have reassigned his or her
benefits also billed for the item or
service. This latter additional
requirement adds complexity that is
unnecessary when our objective of the
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requirement is only to ensure that the
recipient of the downstream distribution
payment furnished an item or service to
an EPM beneficiary during an EPM
episode in order to link the payment to
actual care. Finally, as discussed
previously, in order to achieve
consistency in the parameters for
gainsharing payments and distribution
payments to therapists and to streamline
programmatic requirements, we are
revising proposed § 512.510(b)(7),
which is final in § 512.510(b)(8), by
removing the cap on downstream
distribution payments to PGP members
as applied to therapists who are PGP
members.
A NPPGP that is an ACO participant
that has entered into a distribution
arrangement with an EPM collaborator
that is an ACO may enter into a
downstream distribution arrangement
with a NPPGP member, who is a
nonphysician practitioner or therapist
who is an owner or employee of a
NPPGP and who has reassigned to the
NPPGP his or her right to receive
Medicare payment. The requirements
for NPPGP downstream distribution
payments under those downstream
distribution arrangements are the same
as those for PGPs, except that we allow
the amount of any downstream
distribution payments from a PGP to be
determined in a manner that complies
with § 411.352(g). The amount of any
downstream distribution payments from
a NPPGP to a NPPGP member must be
determined in accordance with a
methodology that is substantially based
on quality of care and the provision
EPM activities, the same standard that
applies to PGP downstream distribution
payments that are not determined in a
manner that complies with § 411.352(g).
Like the requirement for PGP members
when a downstream distribution
payment does not comply with
§ 411.352(g), a NPPGP member is
eligible to receive a downstream
distribution payment only if the
downstream collaboration agent
furnished an item or service to an EPM
beneficiary during an EPM episode that
occurred during the same performance
year for which the EPM participant
accrued the internal cost savings or
earned the reconciliation payment that
comprises the gainsharing payment
from which the ACO made the
distribution payment to the NPPGP that
is an ACO participant. Finally, the total
amount of downstream distribution
payments paid for a performance year to
the NPPGP member who is a
nonphysician practitioner may not
exceed 50 percent of the total Medicareapproved amounts under the PFS for
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items and services furnished by the
NPPGP member to the EPM
participant’s EPM beneficiaries during
EPM episodes that occurred during the
same performance year for which the
EPM participant accrued the internal
cost savings or earned the reconciliation
payment that comprises the gainsharing
payment from which the ACO made the
distribution payment to the NPPGP that
is an ACO participant. In addition, the
total amount of all downstream
distribution payments made to
downstream collaboration agents must
not exceed the amount of the
distribution payment received by the
NPPGP from the ACO.
A TGP that is an ACO participant that
has entered into a distribution
arrangement with an EPM collaborator
that is an ACO may enter into a
downstream distribution arrangement
with a TGP member, who is a therapist
who is an owner or employee of a
NPPGP and who has reassigned to the
TGP his or her right to receive Medicare
payment. Like downstream distribution
payments from a NPPGP to a NPPGP
member, the amount of any downstream
distribution payments from a TGP to a
TGP member must be determined in
accordance with a methodology that is
substantially based on quality of care
and the provision EPM activities, the
same standard that applies to PGP
distribution payments that are not
determined in a manner that complies
with § 411.352(g). Like the requirement
for PGP members when a distribution
payment does not comply with
§ 411.352(g) and for NPPG members, a
TGP member is eligible to receive a
distribution payment only if the
downstream collaboration agent
furnished an item or service to an EPM
beneficiary during an EPM episode that
occurred during the same performance
year for which the EPM participant
accrued the internal cost savings or
earned the reconciliation payment that
comprises the gainsharing payment
from which the ACO made the
distribution payment to the NPPGP that
is an ACO participant. We will not cap
the total amount of downstream
distribution payments paid for a
performance year to a TGP member.
Finally, the total amount of all
downstream distribution payments
made to downstream collaboration
agents must not exceed the amount of
the distribution payment received by
the TGP from the ACO.
Like PGPs, NPPGPs and TGPs must
maintain contemporaneous
documentation regarding downstream
distribution arrangements. Similarly,
the NPPG or TGP may not enter into a
downstream distribution arrangement
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475
with any NPPG member or TGP member
respectively who has a sharing
arrangement with an EPM participant or
a distribution arrangement with the
ACO the NPPG or TGP is a participant
in.
Downstream distribution
arrangements under the EPM must
comply with the following
requirements:
• All downstream distribution
arrangements must be in writing and
signed by the parties, contain the date
of the agreement, and be entered into
before care is furnished to EPM
beneficiaries under the downstream
distribution arrangement.
• Participation in a downstream
distribution arrangement must be
voluntary and without penalty for
nonparticipation.
• The downstream distribution
arrangement must require the
downstream collaboration agent to
comply with all applicable laws and
regulations.
• The opportunity to make or receive
a downstream distribution payment
must not be conditioned directly or
indirectly on the volume or value of
past or anticipated referrals or business
otherwise generated by, between or
among the EPM participant, any EPM
collaborator, any collaboration agent,
any downstream collaboration agent, or
any individual or entity affiliated with
an EPM participant, EPM collaborator,
collaboration agent, or downstream
collaboration agent.
• The amount of any downstream
distribution payments from a NPPGP to
a NPPGP member or from a TGP to a
TGP member must be determined in
accordance with a methodology that is
substantially based on quality of care
and the provision EPM activities and
that may take into account the amount
of such EPM activities provided by a
downstream collaboration agent relative
to other downstream collaboration
agents.
• The amount of any downstream
distribution payments from a PGP must
be determined either in a manner that
complies with § 411.352(g) of this
chapter or in accordance with a
methodology that is substantially based
on quality of care and the provision
EPM activities and that may take into
account the amount of such EPM
activities by a downstream collaboration
agent relative to other downstream
collaboration agents.
• Except for a downstream
distribution payment from a PGP to a
PGP member that complies with
§ 411.352(g) of this chapter, a
downstream collaboration agent is
eligible to receive a downstream
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distribution payment only if the
downstream collaboration agent
furnished an item or service to an EPM
beneficiary during an EPM episode that
occurred during the same performance
year for which the EPM participant
accrued the internal cost savings or
earned the reconciliation payment that
comprise the gainsharing payment from
which the ACO made the distribution
payment to the PGP, NPPGP, or TGP
that is an ACO participant.
• Except for a downstream
distribution payment from a PGP to a
PGP member that complies with
§ 411.352(g) of this chapter, the total
amount of downstream distribution
payments for a performance year paid to
a downstream collaboration agent who
is a physician or nonphysician
practitioner and is either a PGP member
or NPPGP member must not exceed 50
percent of the total Medicare-approved
amounts under the PFS for items and
services furnished by the downstream
collaboration agent to the EPM
participant’s EPM beneficiaries during
EPM episodes that occurred during the
same performance year for which the
EPM participant accrued the internal
cost savings or earned the reconciliation
payment that comprises the distribution
payment being distributed.
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• The total amount of all downstream
distribution payments made to
downstream collaboration agents must
not exceed the amount of the
distribution payment received by the
PGP, NPPGP, or TGP from the ACO.
• All downstream distribution
payments must be made by check,
electronic funds transfer, or another
traceable cash transaction.
• The downstream collaboration
agent must retain his or her ability to
make decisions in the best interests of
the patient, including the selection of
devices, supplies, and treatments.
• The downstream distribution
arrangement must not—
++ Induce the downstream
collaboration agent to reduce or limit
medically necessary services to any
Medicare beneficiary; or
++ Reward the provision of items and
services that are medically unnecessary.
• The PGP, NPPG, or TGP must
maintain contemporaneous
documentation regarding downstream
distribution arrangements in accordance
with § 512.110, including the following:
++ The relevant written agreements.
++ The date and amount of any
downstream distribution payment.
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++ The identity of each downstream
collaboration agent that received a
downstream distribution payment.
++ A description of the methodology
and accounting formula for determining
the amount of any downstream
distribution payment.
• The PGP, NPPGP, or TGP may not
enter into a downstream distribution
arrangement with any PGP member,
NPPGP member, or TGP member who
has—
++ A sharing arrangement with an
EPM participant; or
++ A distribution arrangement with
the ACO that the PGP, NPPGP, or TGP
is a participant in.
• The PGP, NPPGP, or TGP must
retain and provide access to, and must
require downstream collaboration
agents to retain and provide access to,
the required documentation in
accordance with § 512.110.
7. Summary of Policies for Sharing,
Distribution, and Downstream
Distribution Arrangements Under the
EPM
Figure 2 summarizes the proposals for
the defined terms and financial
arrangements discussed in sections
III.I.4. through 6. of the proposed rule
(81 FR 50920 through 50929).
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comments on the proposed rule.
Accordingly, Figure 2 summarizes the
final policies for the defined terms and
financial arrangements discussed in
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sections III.I.4. through 6. of this final
rule.
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Our final policies for financial
arrangements reflect a number of
changes to the proposals for EPM
financial arrangements in response to
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8. Enforcement Authority
As discussed in the proposed rule,
OIG authority is not limited or restricted
by the provisions of the EPM, including
the authority to audit, evaluate,
investigate, or inspect the EPM
participant, EPM collaborators,
collaboration agents, or any other
person or entity or their records, data,
or information, without limitations.
Additionally, no EPM provisions would
limit or restrict the authority of any
other Government Agency to do the
same.
The proposals for enforcement
authority under the EPM were included
in proposed § 512.520. We sought
comment about all of the requirements
set out in the preceding discussion,
including whether additional or
different safeguards would be needed to
ensure program integrity, protect against
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abuse, and ensure that the goals of the
EPM were met.
We received no comments on the
proposals for enforcement authority
under the EPM.
Final Decision: We are finalizing the
proposals in § 512.520 for the
enforcement authority for the EPM,
without modification. The final
provisions include—
• OIG authority is not limited or
restricted by the provisions of the EPM,
including the authority to audit,
evaluate, investigate, or inspect the EPM
participant, EPM collaborators, or any
other person or entity or their records,
data, or information, without limitation;
and
• None of the provisions of the EPM
limits or restricts the authority of any
other government agency permitted by
law to audit, evaluate, investigate, or
inspect the EPM participant, EPM
collaborators, or any other person or
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entity or their records, data, or
information, without limitation.
9. Beneficiary Engagement Incentives
under the EPM
a. General
Similar to our reasoning for the CJR
model (80 FR 73433 through 73437), in
the proposed rule, we discussed our
belief that the EPM would incentivize
EPM participants to furnish directly and
otherwise coordinate items and services
throughout the EPM episodes that lead
to higher quality care for EPM
beneficiaries and lower EPM episode
spending. We believed that one
mechanism that might be useful to EPM
participants in achieving these goals
would be the provision of certain items
and services as in-kind patient
engagement incentives to the EPM
beneficiary during the EPM episode.
Under such an approach, the costs of
the patient engagement incentives
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would be borne by the EPM participant.
However, we believed that certain
conditions on these incentives were
necessary to ensure that their provision
was solely for the purpose of achieving
the EPM goals of improving episode
quality and efficiency.
We proposed that the incentive must
be provided directly by the EPM
participant or by an agent of the EPM
participant under the EPM participant’s
direction and control to the EPM
beneficiary during an EPM episode. We
considered whether this policy on
beneficiary incentives should extend to
providers and suppliers other than the
EPM participant that furnish services
during the EPM episode, or to other
entities altogether, such as ACOs that
were EPM collaborators. However, as
discussed in section III.B.3. of the
proposed rule (81 FR 50813 through
50814), given our belief that the EPM
participant was best positioned to
coordinate the care of beneficiaries in
the EPM, we believed that EPM
participants would also be better suited
than other individuals and entities to
provide beneficiary incentives.
We proposed that the item or service
provided as an incentive must be
reasonably connected to medical care
provided to an EPM beneficiary during
an EPM episode. For example, EPM
participants could provide incentives
such as post-surgical or cardiac
monitoring equipment to track patient
weight and vital signs for post-surgical
or post-AMI patients discharged directly
to home, but could not provide theater
tickets, which would bear no reasonable
connection to the patient’s medical care.
Similarly, EPM participants might
provide cardiac or post-surgical
monitoring equipment, but not broadly
used technology that was more valuable
to the beneficiary than equipment that
was reasonably necessary for the
patient’s post-hospital discharge care,
such as a smartphone. In such
circumstances, a reasonable inference
would arise that the technology would
not be reasonably connected to the
medical care of the patient. Among
other things, this safeguard precluded
incentives that might serve to
inappropriately induce beneficiaries to
receive other medical care that was not
included in the episode. We also
proposed that the incentive must be a
preventive care item or service or an
item or service that advanced a clinical
goal, as described later in this section,
for a beneficiary in an EPM episode by
engaging the beneficiary in better
managing his or her own health.
We further proposed that the item or
service provided as an incentive must
not be tied to the receipt of items or
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services outside the EPM episode and
that the item or service must not be tied
to the receipt of items or services from
a particular provider or supplier. These
provisions would provide safeguards
against the provision of in-kind patient
engagement incentives to steer
beneficiaries toward certain providers or
suppliers for care.
We proposed that the availability of
the items or services provided as
incentives must not be advertised or
promoted except that a beneficiary may
be made aware of the availability of the
items or services at the time the
beneficiary could reasonably benefit
from them. This condition would
provide a safeguard against the
advertisement of in-kind patient
engagement incentives to certain
beneficiaries that could increase an EPM
participant’s number of EPM episodes
and shift the patient severity for an EPM
participant compared to historical EPM
episodes by encouraging more
beneficiaries with less severe clinical
conditions in the EPM to seek care at
the EPM participant. Such changes
could produce financial gain for the
EPM participant that would not be
related to improvements in EPM quality
and efficiency by resulting in the EPM
participant’s quality-adjusted target
prices for EPM episodes being higher
than would be appropriate based on the
lower average patient severity during
the EPM performance years. We did not
intend for any of the financial
arrangements proposed for the EPM,
including beneficiary incentives, to alter
an EPM participant’s market share of
care for a clinical condition in the EPM,
nor did we intend for these
arrangements to shift the patient
severity for an EPM participant or cause
access problems for Medicare
beneficiaries. Finally, we proposed that
the cost of the items or services must
not be shifted to another federal health
care program, as defined at section
1128B(f) of the Act.
Our proposals for the general
provisions for beneficiary incentives
were included in proposed § 512.525(a).
We sought comment on our proposed
general provisions for beneficiary
incentives and welcomed comment on
additional or alternative program
integrity safeguards. We summarize the
comments and provide our responses in
section III.I.9.d. of this final rule.
b. Technology Provided to an EPM
Beneficiary
In some cases, items or services
involving technology might be useful as
beneficiary engagement incentives that
could advance a clinical goal of the EPM
by engaging a beneficiary in managing
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479
his or health during the 90 days
following discharge from the anchor or
chained anchor hospitalization.
However, in the proposed rule we
discussed our belief that specific
enhanced safeguards were necessary for
these items and services to prevent
abuse, and our proposals were
consistent with the CJR model policies
(80 FR 73437). Specifically, we
proposed that items or services
involving technology provided to a
beneficiary may not exceed $1,000 in
retail value for any one beneficiary in
any one EPM episode, and that items or
services involving technology provided
to a beneficiary must be the minimum
necessary to advance a clinical goal as
discussed in this section for a
beneficiary in an EPM episode.
We proposed additional enhanced
requirements for items of technology
exceeding $100 in retail value as an
additional safeguard against misuse of
these items as beneficiary engagement
incentives. Specifically, we proposed
that these items of technology remain
the property of the EPM participant and
be retrieved from the beneficiary at the
end of the EPM episode. The EPM
participant must document all retrieval
attempts, including the ultimate date of
retrieval. However, because we
understood that EPM participants may
not always be able to retrieve these
items after the EPM episode ends, such
as when a beneficiary died or moved to
another geographic area, documented,
diligent, good faith attempts to retrieve
items of technology would be deemed to
meet the retrieval requirement.
Our proposals for enhanced
requirements for technology provided to
EPM beneficiaries as beneficiary
engagement incentives under the EPM
were included in proposed § 512.525(b).
We sought comment on our proposed
requirements for beneficiary
engagement incentives that involve
technology and welcomed comment on
additional or alternative program
integrity safeguards for this type of
beneficiary engagement incentive,
including whether the financial
thresholds proposed in this section were
reasonable, necessary, and appropriate.
We summarize the comments and
provide our responses in section
III.I.9.d. of this final rule.
c. Clinical Goals of the EPM
As discussed in section III.C.3. of the
proposed rule (81 FR 50829 through
50834), the proposed EPMs were
broadly defined to include most Part A
and Part B items and services furnished
during EPM episodes that would extend
90 days following discharge from the
anchor or chained anchor
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hospitalization that began the episode,
excluding only those Part A and Part B
services that were unrelated to the EPM
episode based on hospital readmissions
or diagnoses for which care was
unrelated to the EPM episode diagnosis
and procedures based on clinical
rationale. Therefore, in the proposed
rule we discussed our belief that in-kind
patient engagement incentives might
appropriately be provided for managing
acute conditions arising from EPM
episodes, as well as chronic conditions
if the condition was likely to have been
affected by care during the EPM episode
or when substantial services were likely
to be provided for the chronic condition
during the EPM episode.
We proposed that the following were
the clinical goals of the EPM, which
might be advanced through beneficiary
incentives:
• Beneficiary adherence to drug
regimens.
• Beneficiary adherence to a care
plan.
• Reduction of readmissions and
complications resulting from treatment
for the EPM clinical condition.
• Management of chronic diseases
and conditions that may be affected by
treatment for the EPM clinical
condition.
Our proposals for the clinical goals of
the EPM that a beneficiary engagement
incentive that was not a preventive care
item or service must be intended to
advance were included in proposed
§ 512.525(c). We sought comment on
our proposed clinical goals of the EPM,
as well as whether the advancement of
additional or different clinical goals
through beneficiary engagement
incentives might better advance the
overarching goals of the EPM while
maintaining appropriate program
integrity safeguards. We summarize the
comments and provide our responses in
section III.I.9.d. of this final rule.
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d. Documentation of Beneficiary
Engagement Incentives
As a program safeguard against
misuse of beneficiary engagement
incentives under the EPM, we proposed
that EPM participants must maintain
documentation of items and services
furnished as beneficiary engagement
incentives that exceeded $25 in retail
value. In addition, we proposed to
require that the documentation
established contemporaneously with the
provision of the items and services must
include at least the following:
• The date the incentive was
provided.
• The identity of the beneficiary to
whom the item or service was provided.
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We further proposed that the
documentation regarding items of
technology exceeding $100 in retail that
were required to be retrieved from the
beneficiary at the end of an EPM
episode must also include
contemporaneous documentation of any
attempt to retrieve technology. We
reiterated that documented, diligent,
good faith attempts to retrieve items of
technology would be deemed to meet
the retrieval requirement. Finally, we
proposed that the EPM participant must
retain and provide access to the
required documentation in accordance
with proposed § 512.110.
Our proposals for the documentation
requirements for beneficiary
engagement incentives under the EPM
were included in proposed § 512.525(d).
We sought comment on our proposed
documentation requirements, including
whether additional or different
documentation requirements might
provide better program integrity
safeguards.
The following is a summary of the
comments received and our responses
on all proposals for beneficiary
engagement incentives under the EPM.
Comment: Some commenters opposed
the proposed requirements that EPM
participant must maintain
documentation of items and services
furnished as beneficiary engagement
incentives that exceed $25 in retail
value. The commenters recommended
that CMS increase the documentation
threshold, for example to $50, in order
to reduce record keeping for
inexpensive beneficiary engagement
incentives and to minimize unnecessary
administrative requirements. One
commenter also recommended that CMS
allow beneficiary engagement incentives
greater than $25.
Response: We appreciate the
perspectives of the commenter on our
proposed requirements for
documentation of all items and services
provided as beneficiary engagement
incentives whose value exceeds $25,
including the date and the identity of
the beneficiary to whom the item or
service was provided. We proposed a
$25 retail value threshold for
documentation because we recognized
that a beneficiary could receive many
incentives that are each of low dollar
value but in the aggregate constitute an
excessively high value to the
beneficiary. While we considered
setting a cumulative threshold on the
retail value of beneficiary engagement
incentives received by an EPM
beneficiary during an EPM episode
above which documentation would be
required, we believe such an approach
would be even more burdensome than
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our proposal to require documentation
beginning at $25 in retail value for each
incentive that exceeds that value. A
documentation requirement based on a
cumulative threshold would require
documentation of every expense for
beneficiary engagement incentives
(including those below $25) to ensure
compliance with required
documentation of the cumulative retail
value of incentives that exceed the
threshold. Therefore, we believe it is
prudent to maintain a per-item/perservice documentation threshold and to
not increase the documentation
threshold, thereby keeping the threshold
at a modest level for all beneficiary
incentives in order to monitor
compliance with the requirements for
providing these items and services. We
continue to believe that the $25
threshold represents an appropriate
balance between the benefits of
beneficiary incentives and burden of the
documentation requirement.
For clarification, we did not propose
that EPM participant may only provide
in-kind beneficiary engagement
incentives less than $25. With the
exception of beneficiary engagement
incentives involving technology which
we proposed may not exceed $1,000 in
retail value for any one beneficiary in
any one EPM episode, there is no limit
on the retail value of a single item or
service provided as an in-kind patient
engagement incentive to a beneficiary in
an EPM episode, or to the aggregate of
such incentives provided to the
beneficiary in the episode.
We are finalizing in § 512.515(d)(1)
the requirement that an EPM participant
must maintain documentation of items
and services furnished as beneficiary
engagement incentives that exceed $25
in retail value. Under § 512.515(d)(4),
we set forth the requirement that the
EPM participant must retain and
provide access to the required
documentation in accordance with
§ 512.110.
Comment: In regards to beneficiary
engagement incentives involving
technology, one commenter requested
that the items or services involving
technology provided to an EPM
beneficiary not be capped at $1,000
given that CMS’ proposal would require
the EPM participant to pick up the
technology from the EPM beneficiary if
its retail value is greater than $100. The
same commenter recommended that
CMS increase the proposed cap of $100
to $500 for items of technology that
must remain the property of the EPM
participant and be retrieved from the
beneficiary at the end of the EPM
episode because under the proposed
threshold, the commenters believes it
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would cost the EPM participant more to
pick up the item of technology from the
EPM beneficiary than the item of
technology is worth.
Several commenters suggested that
CMS eliminate altogether the proposed
requirement that items of technology
provided as beneficiary engagement
incentives be retrieved from the
beneficiary at the end of the EPM
episode. One commenter claimed that
there may be situations where the
patient may continue to benefit from the
use of items of technology that were
originally provided as EPM beneficiary
engagement incentives beyond the 90day post-discharge episode duration.
They speculated that continued use of
the technology could reduce the future
need for urgent or emergent care and
impact the overall future cost to
Medicare to care for the beneficiary. The
commenter urged CMS to establish a
process or criteria to evaluate whether a
beneficiary should be able to keep the
technology and continue using it after
the EPM episode ends, ensuring that
any new policies take into the account
the need for flexibility at the local level
to provide benefits to patients, the
community, and the health system as a
whole. Finally, the commenter
requested that if CMS decides not to
establish a process to allowed continued
use of the technology after the EPM
episode ends, then CMS should require
that documentation of beneficiary
engagement incentives include written
acknowledgement by the beneficiary or
their representative that the technology
remains the property of the EPM
participant and must be returned upon
completion of the episode.
Another commenter pointed out
remote patient monitoring equipment
that could be provided as a beneficiary
engagement incentive under the EPM
must be linked to particular a particular
provider to be effective and sought
clarification about how devices
provided in conjunction with remote
patient monitoring could avoid being
tied to a particularly provider. They
further explained the Medicare program
does not provide any payment for
remote patient monitoring or other
items and services provided to patients
for improved self-management and
believes that EPM participants are likely
to engage in these activities only if they
believe that improved episode quality or
cost savings will result. The commenter
asserted that so long as the provision of
technology to beneficiaries is reasonably
related to the clinical goals of the EPM,
EPM participants should be encouraged
to explore the use of remote patient
monitoring through efforts that are not
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constrained by limitations CMS
proposed.
Response: We appreciate the requests
by the commenters for additional
flexibility with respect to items and
services involving technology provided
as EPM beneficiary engagement
incentives. We proposed that items or
services involving technology provided
to as a beneficiary engagement incentive
may not exceed $1,000 in retail value
for any one beneficiary in any one EPM
episode. While one commenter
requested that we raise this limit
because any technology exceeding $100
in retail value would remain the
property of the EPM participant, no
commenters provided information about
items and services involving technology
that would exceed this amount and that
EPM participants would specifically
wish to provide to advance the goals of
the EPM to improve the quality and
reduce the cost of care. Therefore, we
are maintaining the limit of $1,000 in
retail value for items or service
involving technology provided to any
one beneficiary during any one EPM
episode even though the beneficiary’s
use of the technology costing more than
$100 in retail value would be limited to
the EPM episode. We believe that
providing beneficiaries with more
expensive technology could pose a
program integrity risk of patient steering
and that a higher limit is not necessary
under the EPM.
We understand the administrative
burden on EPM participants that
tracking and retrieval requires, but
believe that a higher retrieval threshold,
such as $500, is not warranted.
Similarly, we do not believe it would be
appropriate to eliminate the retrieval
threshold altogether, even for items of
technology that may provide additional
health benefits to beneficiaries after the
EPM episode ends and/or lead to
reduced expenditures on health care. It
would be inappropriate for EPM
participants to furnish items of
technology with a retail value of over
$100 for beneficiaries’ permanent use
because the high value of these items
could unduly influence the beneficiary
to receive services from the EPM
participant, particularly services outside
of the EPM episode. We do not believe
the potential longer-term benefits of
continued use or the administrative
burden of retrieving items involving
technology with a retail value in excess
of $100 outweigh the program integrity
benefits of retrieval.
We propose documentation
requirements for beneficiary
engagement incentives that exceed $25
in retail value as a safeguard against
abuse, including the date the incentive
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481
is provided, the identity of the
beneficiary to whom the item or service
is provided, and contemporaneous
documentation of attempts to retrieve
items of technology exceeding $100 in
retail value. However, we believe that
any additional documentation
requirements such as the commenter’s
suggestion of written acknowledgement
by the beneficiary or their representative
that the technology remains the
property of the EPM participant and
must be returned upon completion of
the episode would be unnecessarily
prescriptive and burdensome for EPM
participants. For items of technology
with a retail value exceeding $100 that
remain the property of the EPM
participant, it is up to the EPM
participant to determine how they can
best ensure that EPM beneficiaries
understand the ownership of the
technology while minimizing the
burden on the EPM participant needed
for successful retrieval or the
documentation of retrieval attempts.
Finally, with respect to the
clarification requested by the
commenter about how items of
technology for remote monitoring could
meet the requirement for EPM
beneficiary engagement incentives that
the item or service must not be tied to
the receipt of items or service from a
particular provider or supplier, we note
that the intent of this latter requirement
is as a safeguard from the use of
beneficiary engagement incentives as a
way to steer beneficiaries toward a
certain provider or type of services. We
understand that remote monitoring
information that is collected from EPM
beneficiaries must be sent to a treating
provider for review and interpretation
in order for the remote-monitoring to
guide clinical care. However, in this
case the remote monitoring technology
would be linked to a provider that is
treating the beneficiary, rather than
being provided to steer the beneficiary
to a particular treating provider, so we
believe that remote monitoring
equipment may be provided as a
beneficiary engagement incentive
without violating the requirement that
the item or service not be tied to the
receipt of items or services from a
particular provider or supplier.
Comment: Some commenters
requested that CMS allow other
beneficiary engagement incentives in
the EPM to be provided by EPM
participants, such as forgiving primary
care or all beneficiary copayments for
items and services included in the
episode and making available
supportive services that are otherwise in
short supply or of inadequate quality,
rather than just those closely tied to the
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medical issues. The commenters
provided examples of in-kind assistance
they believe could be helpful to improve
the quality and reduce the cost of EPM
episode care, such as meal delivery or
other food assistance for beneficiaries
and the family caregiver; enhanced
homemaker and personal care aide
services; and housing assistance for
homeless patients. One commenter
noted that while this would be a more
expansive view of beneficiary
engagement incentives for the EPM than
CMS proposed, such an approach would
allow targeted services to address key
social determinants of health that could
improve the quality and reduce the cost
of EPM episodes by improving
beneficiary outcomes and reducing
readmissions. Another commenter
urged CMS to provide guidance on
specific circumstances where these or
other social support services would be
permissible, including applicable
patient screening protocols and
expenditure caps. The commenters
encouraged CMS to allow EPM
participants, who would be required to
take on financial risk for cardiac and
orthopedic episodes of care under the
EPM, to use a full suite of tools to
provide economically challenged
patients the social supports necessary to
minimize the risk of readmissions.
Other commenters requested
clarification about whether examples of
beneficiary engagement incentives more
directly related to medical issues would
meet CMS’ proposed requirements, such
paying for a beneficiary’s medications
for management of coronary artery
disease (either copayment or entire
prescription in the instance of a patient
who lacks Part D) or paying for a
beneficiary’s medications for
management of an exacerbating chronic
disease (for example, diabetes) (either
copayment or entire prescription in the
instance of a patient who lacks Part D).
Response: We appreciate the
commenters’ recommendations for
additional beneficiary engagement
incentives under the EPM, as well as
their requests for clarification about
certain items and services that EPM
participants may wish to provide as
beneficiary engagement incentives.
Regarding requests for CMS to waive
copayments for items and services
included in EPM episodes, most
beneficiaries in traditional Medicare
have supplemental coverage,
specifically employer-sponsored,
Medicaid, and Medigap in descending
order of prevalence.130 In 2011, 81
130 The Henry J. Kaiser Family Foundation. An
Overview of Medicare. April 1, 2016. https://kff.org/
medicare/issue-brief/an-overview-of-medicare.
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percent of beneficiaries in traditional
Medicare had supplemental coverage.
While we recognize that without
supplemental coverage the copayments
associated with an EPM episode could
be significant, most beneficiaries would
not experience significant out-of-pocket
costs for the items and services
themselves because their supplemental
coverage would help to cover those
costs. For the subset of beneficiaries
without supplemental coverage, we note
that, under current law, hospitals and
other providers and suppliers are
permitted to waive copayments under
certain limited conditions and that
copayment waivers that comply with
existing law continue to be permitted
under the EPM. In light of these factors,
we will not waive copayments for items
and services covered by Medicare under
the EPM.
No commenters suggested that our
specific proposal for the purpose of the
items and services provided as
beneficiary engagement incentives,
specifically that they must be preventive
care items or services or items and
services that advance a clinical goal for
a beneficiary in an EPM episode by
engaging the beneficiary in better
managing his or her own health, were
not appropriate for the EPM. Several
commenters who urged us to allow
them the flexibility to provide support
services as beneficiary engagement
incentives presented specific arguments
about how those items and services
would reduce readmissions or enhance
beneficiary adherence to the treatment
plan, which are on the proposed list of
clinical goals of the EPM. On the other
hand, some commenters expressed
concern that social support services that
have the potential to advance EPM goals
might not meet the proposed
requirements because they are not
closely tied to medical issues and,
therefore, would not meet the
requirement that the item or service
must be reasonably connected to
medical care provide to an EPM
beneficiary during and EPM episode.
While we appreciate that social issues
have a significant influence on
beneficiary health, we are testing the
EPM as an innovative payment
approach for Medicare beneficiaries,
which focuses on improving care
coordination following inpatient
hospitalization for treatment of a
clinical condition included in the EPM
to improve the quality and reduce the
cost of health care. The EPM is an APM
that is being tested as an alternative to
FFS Medicare. Therefore, we continue
to believe that it is important to
maintain the requirements of a
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reasonable connection between the item
or service provided as a beneficiary
engagement incentive and a
beneficiary’s medical care and that the
item or service advance a meaningful
clinical goal for the EPM beneficiary.
These requirements both protect against
EPM participants’ incentives to
influence the beneficiary’s choice of
providers and types of care in the EPM
and ensure that the EPM as
implemented with a standardized
episode payment design in a large
number and wide variety of EPM
participants can be appropriately
evaluated in comparison with FFS
Medicare.
We will not provide additional
interpretation of the requirements for
beneficiary engagement incentives that
we are finalizing in this final rule, nor
provide other guidance at this time.
Instead, we encourage EPM participants
considering offering items or services as
beneficiary engagements incentives to
EPM beneficiaries to closely consider
those potential items and services and
ensure that their provision would meet
all the requirements of § 512.525 before
deciding to provide those items or
services as beneficiary engagement
incentives under the EPM.
Comment: One commenter requested
that CMS address a specific scenario
where an EPM participant already has a
program in place prior to
implementation of the EPM to
encourage beneficiaries to follow
through on their plan of care after
hospital discharge. The commenter
requested that CMS clarify whether the
incentives under the existing program
become beneficiary engagement
incentives under the EPM and,
therefore, subject to the requirements of
the EPM, or whether the existing
incentives would only be considered
beneficiary engagement incentives
under the EPM if they are specifically
being offered to encourage improvement
of clinical goals based on the EPM care
redesign for the EPM episode.
Response: We appreciate the request
for clarification about the relationship of
a hospital’s existing incentives provided
to Medicare beneficiaries following
hospital discharge to encourage
adherence to the beneficiary’s care plan
to EPM beneficiary engagement
incentives provided by an EPM
participant that must meet the specific
requirements proposed in § 512.515 and
all other applicable laws and
regulations, including the applicable
fraud and abuse laws. If an EPM
participant has a program already in
place to provide incentives to
beneficiaries following hospital
discharge, we expect that all such
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incentives offered would comply with
all current laws and regulations,
including the fraud and abuse laws.
Therefore, if an EPM participant
provides beneficiary engagement
incentives to EPM beneficiaries during
EPM episodes, those incentives must
either comply with all current laws and
regulations, including the fraud and
abuse laws, or with the requirements for
EPM beneficiary engagement incentives
in § 512.515 and all other applicable
laws and regulations, including the
applicable fraud and abuse laws. We
note that any waivers of fraud and abuse
laws for the EPM or revisions to the
existing CJR waivers are outside the
scope of this rulemaking.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposals in §§ 512.525(a)
through (d) for the EPM general
provisions, technology provided to an
EPM beneficiary, clinical goals of the
EPM, and documentation of beneficiary
incentives, without modification.
Beneficiary engagement incentives
under the EPM must meet the following
conditions and requirements:
EPM participants may choose to
provide in-kind patient engagement
incentives to beneficiaries in an EPM
episode, subject to the following
conditions:
• The incentive must be provided
directly by the EPM participant or by an
agent of the EPM participant under the
EPM participant’s direction and control
to the EPM beneficiary during an EPM
episode.
• The item or service provided must
be reasonably connected to medical care
provided to an EPM beneficiary during
an EPM episode.
• The item or service must be a
preventive care item or service or an
item or service that advances a clinical
goal, as listed in paragraph (c) of this
section, for a beneficiary in an EPM
episode by engaging the beneficiary in
better managing his or her own health.
• The item or service must not be tied
to the receipt of items or services
outside the EPM episode.
• The item or service must not be tied
to the receipt of items or services from
a particular provider or supplier.
• The availability of the items or
services must not be advertised or
promoted except that a beneficiary may
be made aware of the availability of the
items or services at the time the
beneficiary could reasonably benefit
from them.
• The cost of the items or services
must not be shifted to another federal
health care program, as defined at
section 1128B(f) of the Act.
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Beneficiary engagement incentives
involving technology are subject to the
following additional conditions:
• Items or services involving
technology provided to a beneficiary
may not exceed $1,000 in retail value
for any one beneficiary in any one EPM
episode.
• Items or services involving
technology provided to a beneficiary
must be the minimum necessary to
advance a clinical goal, as listed in
paragraph (c) of this section, for a
beneficiary in an EPM episode.
• Items of technology exceeding $100
in retail value must—
++ Remain the property of the EPM
participant; and
++ Be retrieved from the beneficiary
at the end of the EPM episode. The EPM
participant must document all retrieval
attempts, including the ultimate date of
retrieval. Documented, diligent, good
faith attempts to retrieve items of
technology will be deemed to meet the
retrieval requirement.
The following are the clinical goals of
the EPM, which may be advanced
through beneficiary incentives:
• Beneficiary adherence to drug
regimens.
• Beneficiary adherence to a care
plan.
• Reduction of readmissions and
complications resulting from treatment
for the EPM clinical condition.
• Management of chronic diseases
and conditions that may be affected by
treatment for the EPM clinical
condition.
Documentation of beneficiary
engagement incentives:
• EPM participants must maintain
documentation of items and services
furnished as beneficiary engagement
incentives that exceed $25 in retail
value.
• The documentation established
contemporaneously with the provision
of the items and services must include
at least the following:
++ The date the incentive is
provided.
++ The identity of the beneficiary to
whom the item or service was provided.
• The documentation regarding items
of technology exceeding $100 in retail
must also include contemporaneous
documentation of any attempt to
retrieve technology at the end of an EPM
episode as described previously in this
section.
• The EPM participant must retain
and provide access to the required
documentation in accordance with
§ 512.110.
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483
10. Compliance With Fraud and Abuse
Laws
Certain arrangements between and
among EPM participants and third
parties or beneficiaries may implicate
civil monetary penalty (CMP) law
(subsections 1128A(a)(5), (b)(1), and
(b)(2) of the Act), the Federal Antikickback statute (subsections
1128B(b)(1) and (2) of the Act), or the
physician self-referral law (section 1877
of the Act). In many cases, arrangements
that implicate these laws can be
structured to comply with them by
using existing safe harbors and
exceptions. Section 1115A(d)(1) of the
Act authorizes the Secretary to waive
certain specified fraud and abuse laws
as may be necessary solely for purposes
of testing of payment models under
section 1115A(b) of the Act. A waiver is
not needed for an arrangement that does
not implicate the fraud and abuse laws
or that implicates the fraud and abuse
laws but either fits within an existing
exception or safe harbor, as applicable,
or does not otherwise violate the law.
Accordingly, pursuant to section
1115A(d)(1) of the Act, the Secretary
will consider whether waivers of certain
fraud and abuse laws are necessary to
test the EPM as such models develop.
Such waivers, if any, will be
promulgated separately from this final
regulation by OIG (as to sections 1128A
and 1128B of the Act) and CMS (as to
section 1877 of the Act), to which the
respective authorities have been
delegated.
As discussed in the proposed rule,
requirements for the EPM will bear on
the need for and scope of any fraud and
abuse waivers that might be granted for
the EPM. Because of the close nexus
between the regulations governing the
structure and operations of the EPM and
the development of any fraud and abuse
waivers necessary to carry out the
provisions of the EPM, CMS and OIG
may, when considering the need for or
scope of any waivers, consider
comments submitted in response to the
proposed rule and provisions of this
final rule.
J. Waivers of Medicare Program
Requirements
1. Overview
Under the CJR model, we stated that
it may be necessary and appropriate to
provide additional flexibilities to
hospitals participating in the CJR model,
as well as other providers that furnish
services to beneficiaries in CJR episodes.
The purpose of such flexibilities is to
increase CJR-episode quality and
decrease episode spending or internal
costs or both of providers and suppliers
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that results in better, more coordinated
care for beneficiaries and improved
financial efficiencies for Medicare,
providers, and beneficiaries. These
additional flexibilities were
implemented through our waiver
authority under section 1115A of the
Act, which affords broad authority for
the Secretary to waive statutory
Medicare program requirements as
necessary to carry out the provisions of
section 1115A.
As discussed in the proposed rule, in
testing EPMs, we believe that certain
program waivers, similar to those
adopted under the CJR model, will offer
providers and suppliers more flexibility
so that they may increase coordination
of care and management of beneficiaries
in EPM episodes. However, we stated in
the proposed rule that before adopting
the same waivers as we adopted in the
CJR model for EPMs, we stated that
further examination is necessary to
determine if doing so increases financial
vulnerability for the Medicare program
or creates inappropriate clinical
incentives that may reduce the quality
of beneficiary care.
Based on our analysis of data
available from current models being
tested and other available clinical data,
specific program requirements for
which we proposed waivers under the
AMI, CABG, and SHFFT models and for
which we invited comments are
included in the sections that follow. In
addition, for providers or suppliers of
cardiac rehabilitation and intensive
cardiac rehabilitation services furnished
to EPM beneficiaries during an AMI and
CABG episode, we proposed to waive
the physician definition to allow a
qualified nonphysician practitioner to
perform specific physician functions.
We proposed that these waivers of
program requirements would apply to
the care of beneficiaries who are in the
proposed AMI, CABG, or SHFFT
episodes at the time when such waivers
would be used to bill for services
furnished to the beneficiary, even if the
episode is later cancelled as described
in section III.C.4.b. of the proposed rule.
Thus, it may have been appropriate for
the hospital to have used a waiver if
there was a reasonable expectation that
the beneficiary was in the model at the
time the waiver was used. However, if
a service is found to have been billed
and paid by Medicare under
circumstances allowed only by a
program requirement waiver for a
beneficiary not in the proposed AMI,
CABG, or SHFFT models at the time the
service was furnished, CMS would
recoup payment for that service from
the provider or supplier who was paid,
and require that provider or supplier to
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repay the beneficiary for any
coinsurance previously collected. We
did not receive any comments on this
policy therefore, we are adopting this
policy in this final rule.
We also generally sought comment on
any additional Medicare program
requirements that may be necessary to
waive using our authority under section
1115A of the Act in order to effectively
test the proposed EPMs that we could
consider in the context of our early
model implementation experience to
inform any future proposals we may
make. While we cannot finalize program
requirement waivers that we have not
specifically proposed, we will
continually monitor the use of program
waivers in each EPM to ensure that the
appropriate outcomes in provider/
supplier financial incentives and patient
care are achieved.
The following is a summary of the
comments received and our responses.
Comment: Many commenters
recommended the CMS include other
program waivers in addition to the
proposed EPM waivers. In general, these
suggestions were similar to the
suggestions received during the CJR
rulemaking process. Specifically, one
commenter recommended that CMS
expand more innovation to the postacute care provider community in
models such as CJR, EPM, and BPCI by
allowing them to participate more
robustly in these models through
waiving some of the provider-specific
rules, such as the IRF 60-percent rule
and 3-hour therapy guideline. Another
commenter recommended that CMS
include a waiver to allow advance
practice registered nurses to certify
hospitalized patients for home health
care services for the CJR model and the
EPMs. Some commenters urged CMS to
waive discharge planning requirements
that prohibit hospitals from specifying
or otherwise limiting information about
post-acute care services, waive the
regulatory constraints on how therapy
services are delivered to EPM-eligible
beneficiaries, and promote parity across
Medicare programs by ensuring similar
flexibilities are available to Medicare
Advantage Organizations so that all
Medicare beneficiaries can benefit from
these services or removal of barriers.
Another commenter urged CMS to
waive audits of post-acute care and
other collaborators participating in an
EPM or CJR episode since the episodemanaging entity is financially
accountable for the provision of those
services. Some commenters
recommended that because certain
arrangements may not meet the
requirements of a ‘‘sharing
arrangement’’ as outlined in the EPM
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proposed rule, CMS should waive fraud
and abuse, beneficiary inducement, and
physician self-referral liability for EPM
entities.
Response: In the CJR Final Rule (80
FR 73439), we responded to numerous
comments to include additional waivers
under the CJR model. The final
regulations issued for the CJR model
reflect our responses to those comments.
We stated in the CJR Final Rule that
while we were not making any changes
to the proposed waivers, we would
continually monitor the data from early
testing of the CJR model. The CJR model
was implemented on April 1, 2016 thus
data is currently not available to
evaluate if changes to the program
waivers are warranted. We stated that if
the early CJR model testing data
supports changes to the program
waivers then we would do so in future
rulemaking.
Our goal for implementing program
waivers for EPMs was to replicate the
general aspects of the waivers that were
issued in the CJR final regulations.
However, we stated in the EPM
proposed rule that adopting the CJR
waivers for the proposed EPMs required
further examination to determine if such
adoption would increase financial
vulnerability to the Medicare program
or would create inappropriate
incentives to reduce the quality of
beneficiary care. Thus, for the EPMs we
proposed the following waivers that are
similar to the adopted CJR waivers;
• Adopt waivers of the telehealth
originating site and geographic site
requirement and to allow in-home
telehealth visits for all three proposed
EPMs, as well as the general waiver to
allow post-discharge home visits and;
• Provide waivers on the number of
post-discharge home visits and for the
SNF 3-day stay, made on an EPM
episode basis.
We anticipate that if the CJR model
testing data supports additions or
changes to the CJR program waivers,
then we would consider extending those
revisions to CJR waivers in future
rulemaking to the EPMs if those waivers
would be clinically appropriate for the
clinical conditions that are the focus of
the EPM. Hence, our responses to the
EPM waiver comments in this section
reflect this common relationship with
the final CJR model waivers.
Final Decision: We address the
specific Medicare program waivers we
proposed in the EPM proposed rule in
the following sections. We decline at
this time to waive any additional
Medicare program requirements. We
will review the information provided by
the commenters and our early CJR
model and EPM experience and may
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consider waiving additional
requirements during the course of the
CJR model and EPM test.
2. Summary of Waivers Adopted Under
the CJR Model
As part of the CJR model
implemented in 2016, we issued
regulatory waivers of the following
Medicare program requirements:
• Section 510.600 of the regulations
waives the direct supervision
requirement to allow clinical staff to
furnish certain post-discharge home
visits under the general, rather than
direct, supervision of a physician or
nonphysician practitioners. This waiver
allows a CJR beneficiary who does not
qualify for home health benefits to
receive up to 9 post-discharge visits in
his or her home or place of residence
any time during the episode. All other
Medicare rules for coverage and
payment of services incident to a
physician’s service continue to apply.
• Section 510.615 waives current
Medicare billing rules to allow the
separate billing of these post-discharge
home visits for CJR beneficiaries during
a 90-day post-operative global surgical
period. All other Medicare rules for
global-surgery billing during the 90-day
post-operative period continue to apply
• Section 510.605 of the regulations
allows a Medicare-approved telehealth
service to be furnished to a CJR
beneficiary regardless of the
beneficiary’s geographic location, and in
his or her home or place of residence.
CMS also waives certain telehealth
payment provisions. Specifically,
Medicare will not pay the originating
site facility fee if the service originates
in the beneficiary’s home or place or
residence, and the telehealth home
visits will be paid using unique HCPCS
codes with payment based on
comparable office visits, less the
practice expense portion of the payment
paid for these comparable visits when
furnished in-person. All other
requirements for Medicare coverage and
payment of telehealth services continue
to apply.
• Section 510.610 of the regulations
waives the 3-day hospital stay
requirement before a beneficiary may be
discharged from a hospital to a qualified
SNF, which CMS define as SNFs that
are rated an overall of 3 stars or better
for 7 of the last 12 months on the
Nursing Home Compare Web site. This
waiver applies to episodes being tested
under the CJR model for specific
performance years. For example, under
CJR, the waiver applies beginning in
performance year 2 (as hospitals are not
bearing risk in their first year). All other
Medicare rules for coverage and
payment of Part A-covered SNF services
continue to apply.
• Section 510.620 of the regulations
waives the deductible and coinsurance
statutory requirements to the extent
necessary to make reconciliation
payments or receive repayments based
on the episodic payment methodology
under the final payment model for CJR
participant hospitals. The reconciliation
or repayments do not affect the
beneficiary’s cost sharing amounts for
services furnished under the CJR model.
3. Analysis of Current Model Data
As discussed in the proposed rule, we
believe that before we adopt the same
regulatory waivers offered under the CJR
model, we must determine if doing so
would: (1) Be clinically-appropriate; (2)
not introduce financial vulnerabilities to
the Medicare program; and, more
importantly, (3) not decrease desired
outcomes of patient care. To make this
determination, we analyzed waiver
usage data and post-acute care usage
from Medicare claims data current being
tested in other EPMs. In addition, we
analyzed the latest arithmetic and
geometric means for the MS–DRGs
associated with the proposed AMI,
CABG, and SHFFT models published as
Table 5 in the IPPS FY 2016 Correction
Notice to the Final Rule (CMS–1632–
CN; 80 FR 60055). The following
summarizes the available data.
a. Analysis of Waiver Usage
As stated in the proposed rule, waiver
usage data is currently not available
485
from the CJR model, thus we reviewed
waiver usage data from the BPCI model.
Waivers were offered for all 48 episodes
under the BPCI model. However, we
note that such waivers were
significantly different from those
adopted under the CJR model. For
example, many BPCI model awardees
were concerned about the difficulties in
accurately identifying beneficiaries in
BPCI episodes, which we believe might
have been a disincentive to using the
waiver of the SNF 3-day hospital stay.
For the CJR model, we attempted to
address this by codifying that the SNF
stay would be covered if the beneficiary
was in the episode at the time that the
SNF waiver was utilized. With respect
to the home visit, the BPCI model only
allows 3 visits in a 90-day period (less
if the episode is shorter), and awardees
might not consider it worth the effort to
incorporate this limited number of visits
into their care design for episode
beneficiaries. For the CJR model, we
increased this allowance to 9 postdischarge visits in a 90-day period to
allow for one visit a week for the two
thirds of the 90-days post-discharge
when the beneficiary was not receiving
post-acute care. Finally, in the BPCI
model we waived the geographic
restrictions for telehealth visits, whereas
for the CJR model we allow telehealth
visits originating in the home, regardless
of geographic location.
Given that the waivers offered under
the BPCI model differ from the waivers
in the CJR model, and presumably for
the waivers that we are implementing in
this final rule, the BPCI model data
shows—
• The use of the home visit and
telehealth waiver is minimal; and
• The waiver of the SNF 3-day rule
may be getting the most use.
b. Analysis of Discharge Destination—
Post-Acute Care Usage
As discussed in the proposed rule, the
following Table 47 shows the discharge
destination and post-acute care usage
for the cardiac related episodes (CABG,
PCI, and AMI) in the BPCI model.
TABLE 47—DISCHARGE DESTINATION FOR BPCI CARDIAC DIAGNOSES *
[Source: Medicare claims data]
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Discharge destination
(in rounded percentages)
MS–DRG
MS–DRG title
Home w/o
home health
Home with
home health
SNF
Other
CABG
231 .......................
232 .......................
233 .......................
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W PTCA W MCC ..........................................................
W PTCA W/O MCC ......................................................
W CARDIAC CATH W MCC ........................................
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28
12
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49
34
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15
40
13
8
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TABLE 47—DISCHARGE DESTINATION FOR BPCI CARDIAC DIAGNOSES *—Continued
[Source: Medicare claims data]
Discharge destination
(in rounded percentages)
MS–DRG
MS–DRG title
Home w/o
home health
234 .......................
235 .......................
236 .......................
W CARDIAC CATH W/O MCC .....................................
W/O CARDIAC CATH W MCC .....................................
W/O CARDIAC CATH W/O MCC .................................
Home with
home health
SNF
Other
20
13
23
46
34
50
27
36
19
7
17
8
66
89
68
85
63
86
18
8
17
10
25
10
13
3
12
5
8
4
3
0
3
0
4
0
42
57
71
22
20
17
34
22
10
2
1
2
PCI
246
247
248
249
250
251
.......................
.......................
.......................
.......................
.......................
.......................
W DES W MCC OR 4+ VES/STENTS .........................
W DES STENT W/O MCC ...........................................
W NON DES W MCC OR 4+ VES/STENTS ................
W NON-DES W/O MCC ...............................................
W/O CAS W MCC ........................................................
W/O CAS W/O MCC .....................................................
AMI
280 .......................
281 .......................
282 .......................
DISCHARGED ALIVE W MCC .....................................
DISCHARGED ALIVE W CC ........................................
DISCHARGED ALIVE W/O CC/MCC ...........................
* ABBREVIATIONS:
PTCA—Percutaneous Transluminal Coronary Angioplasty
CC—Complications
MCC—Major Complications
DES—Drug-Eluting Stent
CAS—Coronary Artery Stent
VES—Vessels
Analysis of the data in Table 47
shows—
• Patients with CABG have high postacute care usage;
• Patients with PCI have very little
post-acute care usage; and
• Patients with AMI have average
post-acute care usage compared to
patients with PCI and CABG.
Analysis of the CJR model data shows
post-acute care usage of about 30 days
for MS–DRGs associated with the CJR
model.
c. Analysis of Hospital Mean Length of
Stay Data
As discussed in the proposed rule,
Table 48 shows the geometric and
arithmetic mean length of stay (LOS) for
MS–DRGs associated with the proposed
CABG, AMI (including PCI) and SHFFT
models.
TABLE 48—GEOMETRIC AND ARITHMETIC MEAN LENGTH OF STAY FOR BPCI CARDIAC DIAGNOSES AND SHFFT *
[Source: FY 2016 IPPS correction notice; Table 5] *
MS–DRG
Geometric
mean LOS
MS–DRG title
Arithmetic
mean LOS
CABG
231
232
233
234
235
236
....................................
....................................
....................................
....................................
....................................
....................................
W PTCA W MCC .....................................................................................................
W PTCA W/O MCC .................................................................................................
W CARDIAC CATH W MCC ....................................................................................
W CARDIAC CATH W/O MCC ................................................................................
W/O CARDIAC CATH W MCC ................................................................................
W/O CARDIAC CATH W/O MCC ............................................................................
9.9
7.9
11.6
8.0
8.9
6.0
11.7
8.6
13.0
8.6
10.3
6.5
4.1
2.2
4.8
2.5
4.2
2.4
5.5
2.7
6.3
3.1
5.7
2.9
4.5
2.9
2.0
5.8
3.6
2.4
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PCI
246
247
248
249
250
251
....................................
....................................
....................................
....................................
....................................
....................................
W DES W MCC OR 4+ VES/STENTS ....................................................................
W DES STENT W/O MCC .......................................................................................
W NON DES W MCC OR 4+ VES/STENTS ...........................................................
W NON-DES W/O MCC ..........................................................................................
W/O CAS W MCC ....................................................................................................
W/O CAS W/O MCC ................................................................................................
AMI
280 ....................................
281 ....................................
282 ....................................
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487
TABLE 48—GEOMETRIC AND ARITHMETIC MEAN LENGTH OF STAY FOR BPCI CARDIAC DIAGNOSES AND SHFFT *—
Continued
[Source: FY 2016 IPPS correction notice; Table 5] *
MS–DRG
Geometric
mean LOS
MS–DRG title
Arithmetic
mean LOS
SHFFT
480 ....................................
481 ....................................
482 ....................................
HIP & FEMUR PROCEDURES EXCEPT MAJOR JOINT W MCC ........................
HIP & FEMUR PROCEDURES EXCEPT MAJOR JOINT W CC ...........................
HIP & FEMUR PROCEDURES EXCEPT MAJOR JOINT W/O CC/MCC ..............
6.7
4.6
3.7
7.9
5.0
4.0
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* ABBREVIATIONS:
PTCA—Percutaneous Transluminal Coronary Angioplasty
CC—Complications
MCC—Major Complications
DES—Drug-Eluting Stent
CAS—Coronary Artery Stent
VES—Vessels
Analysis of data in Table 48 shows—
• Patients under all CABG MS–DRGs
have a mean LOS of 6 days up to 11–
13 days;
• Patients under all PCI MS–DRGs
have a mean LOS of about 2 days up to
about 6 days;
• Patients under all AMI MS–DRGs
have a mean LOS of about 2 days up to
about 6 days; and
• Patients under all SHFFT MS–DRGs
have a mean LOS of about 4 days up to
about 8 days.
Analysis of the CJR model data shows
the mean LOS for MS–DRGs associated
with the CJR model of about 3 days up
to about 7 days.
As discussed in the proposed rule,
based on our analysis of the available
data, we believe that minimal program
and patient outcome vulnerabilities
exist with adopting the same CJR
regulatory waivers to the following
program requirements for EPMs:
• The direct supervision requirement
for certain post-discharge home visits
and the Medicare billing requirement
that will allow the separate billing of
these post-discharge home visits for
EPM beneficiaries during a 90-day postoperative global surgical period.
• The telehealth geographic site
requirement and the requirement that
will allow in-home telehealth visits.
• The deductible and coinsurance
statutory requirements to the extent
necessary to make reconciliation
payments or receive repayments based
on the episodic payment methodology
under the final payment model for EPM
participants.
Therefore, in conjunction with the
comments received, we are adopting, as
proposed, the waivers for these program
requirements for EPMs as discussed in
the sections that follow.
In addition, as discussed in the
proposed rule, based on our analysis of
the available data, we believe some
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program and patient outcome
vulnerabilities may exist with the
adoption of the same CJR regulatory
waivers for the following program
requirements for some EPMs:
• The SNF 3-day rule.
• The number of post-discharge home
visits allowed during the model
episode.
Therefore, in conjunction with the
comments received, we are adopting, as
proposed, model-specific limits to the
number of post-discharge home visits
and to offer the waiver of the SNF 3-day
rule on a model-specific basis as
discussed in the sections that follow.
4. Post-Discharge Home Visits
As with the LEJR episodes, we expect
that the broadly-defined EPM episodes
with a duration of 90 days following
hospital discharge, as we discuss in
section III.A.1. of this final rule, will
result in EPM participants redesigning
care by increasing care coordination and
management of beneficiaries following
surgeries. We believe that beneficiaries
might have substantial mobility
limitations during EPM episodes
following discharge to their homes or
places of residence that may interfere
with their ability to travel easily to
physicians’ offices or other health care
settings. Adopting new strategies to
increase beneficiary adherence to and
engagement with recommended
treatment and follow-up care following
discharge from the hospital or postacute care setting will also be important
to high-quality episode care. Scientific
evidence exists to support the use of
home nursing visits among Medicare
beneficiaries in improving care
coordination following hospital
discharge.131 In addition, we believe the
financial incentives in the EPMs will
131 Naylor MD, Brooten D, Campbell R, Jacobsen
BS, Mezey MD, Pauly MV, Schwartz JS. JAMA.
1999:281(7):613–620. doi:10/1001/jama.281.7.613.
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encourage hospitals to closely examine
the most appropriate post-acute care
settings for beneficiaries so that the
clinically-appropriate setting of the
lowest acuity is recommended following
discharge from the anchor
hospitalization. We expect that all these
considerations will lead to greater
interest on the part of hospitals and
other providers and suppliers caring for
EPM beneficiaries in furnishing services
to beneficiaries in their homes or places
of residence. Such services could
include visits by licensed clinical staff
other than physicians and nonphysician
practitioners.
In order for Medicare to pay for home
health services, a beneficiary must be
determined to be ‘‘homebound.’’
Specifically, sections 1835(a) and
1814(a) of the Act require that a
physician certify (and recertify) that in
the case of home health services under
the Medicare home health benefit, such
services are or were required because
the individual is or was ‘‘confined to the
home’’ and needs or needed skilled
nursing care on an intermittent basis, or
physical or speech therapy or has or had
a continuing need for occupational
therapy. A beneficiary is considered to
be confined to the home if the
beneficiary has a condition, due to an
illness or injury, that restricts his or her
ability to leave home except with the
assistance of another individual or the
aid of a supportive device (that is,
crutches, a cane, a wheelchair or a
walker) or if the beneficiary has a
condition such that leaving his or her
home is medically contraindicated.
While a beneficiary does not have to be
bedridden to be considered confined to
the home, the condition of the
beneficiary must be such that there
exists a normal inability to leave home
and leaving home requires a
considerable and taxing effort by the
beneficiary.
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Absent this condition, it would be
expected that the beneficiary typically
could get the same services in an
outpatient or other setting. Thus, the
homebound requirement provides a way
to help differentiate between patients
that require medical care at home versus
patients who could more appropriately
receive care in less-costly outpatient
settings. Additional information
regarding the homebound requirement
is available in the Medicare Benefit
Manual (Pub 100–02); Chapter 7, ‘‘Home
Health Services,’’ section 30.1.1,
‘‘Patient Confined to the Home.’’
We considered whether a waiver of
the homebound requirement would be
appropriate under the AMI, CABG and
SHFFT models, particularly beginning
in performance year 2, where hospitals
begin to bear repayment responsibility
for excess episode spending. Waiving
the homebound requirement would
allow additional beneficiaries to receive
home health care services in their home
or place of residence. As previously
discussed, physician certification that a
beneficiary meets the homebound
requirement is a prerequisite for
Medicare coverage of home health
services, and waiving the homebound
requirement could result in lower
episode spending in some instances. For
example, if a beneficiary is allowed to
have home health care visits, even if the
beneficiary is not considered
homebound, the beneficiary may avoid
a hospital readmission. All other
requirements for the Medicare home
health benefit would remain unchanged.
Thus, under such a waiver, only
beneficiaries who otherwise meet all
program requirements to receive home
health services would be eligible for
coverage of home health services
without being homebound.
However, we did not propose to
waive the homebound requirement
under the proposed EPMs for several
reasons. Based on the typical clinical
course of beneficiaries after procedures
in the proposed EPMs, we believe that
many beneficiaries would meet the
homebound requirement for home
health services immediately following
discharge from the anchor
hospitalizations or following discharge
to their home or place of residence from
a SNF that furnished post-acute care
services immediately following the
hospital discharge, so they could receive
medically-necessary home health
services under existing program rules.
Home health episodes are 60 days in
duration, and payment adjustments are
made for beneficiaries who require only
a few visits during the episode or who
are discharged during the episode. For
those EPM beneficiaries who could
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benefit from home visits by licensed
clinical staff for purposes of assessment
and monitoring of their clinical
conditions, care coordination, and
improving adherence with treatment but
who are not homebound, we do not
believe that paying for these visits as
home health services under Medicare is
necessary or appropriate, especially
given that Medicare payments for home
health services are set based on the
clinical care furnished to beneficiaries
who are truly homebound. Finally, in
other CMS episode payment models,
such as the BPCI initiative and the CJR
model, we have not waived the
homebound requirement for home
health services.
The following is a summary of the
comments received and our responses.
Comment: Some commenters stated
the CMS should waive the homebound
requirement for the EPMs. One
commenter stated that hospitals would
not have an incentive to direct patients
to home health when a less costly
option, such as outpatient therapy, also
would be clinically appropriate and that
CMS should allow physicians, working
together with participating hospitals, to
determine the most clinically
appropriate plan for a patient’s postacute care, unimpeded by regulatory
barriers. Another commenter suggested
the establishment of a homebound
waiver to fit the circumstances
described in the ‘‘incident to’’ waiver.
Other commenters recommended that
CMS incrementally test a waiver of the
homebound requirement for the home
health benefit by using a limited waiver.
Other commenters recommended that
CMS waive the home health
homebound rule in accordance with the
new Star Rating program for homecare
providers
Response: While we appreciate the
commenters’ requests that we waive the
homebound requirement for home
health services, we disagree that
waiving the homebound requirement is
necessary for the test of the EPMs. In the
CJR model Final Rule (80 FR 73440
through 73441) we responded to similar
comments regarding the home health
homebound requirement. Under the
EPMs, we continue to believe that
waiving the homebound requirement is
not appropriate for the same reasons
stated in the CJR model Final Rule.
As discussed in the EPM proposed
rule, we proposed to waive the
‘‘incident to’’ direct physician
supervision requirement for postdischarge home visits in order to allow
clinical staff to furnish post-discharge
home visits to EPM beneficiaries who
do not meet the requirements for home
health services. We believe that this
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would allow the home visits by clinical
staff for non-homebound EPM
beneficiaries that we believe are
necessary for testing the model. As we
discussed in the EPM proposed rule, we
believe many EPM beneficiaries should
qualify for home health services under
the existing program rules, especially
immediately after discharge from the
hospital or discharge from an
institutional setting such as a SNF to
their residence. Furthermore, as a
retrospective payment model, all
providers and suppliers are paid for
services furnished to model
beneficiaries at their usual rates, and
program payments for home health
services are set based on the needs of
Medicare beneficiaries who are truly
homebound. The resources required to
care for homebound beneficiaries in the
home are likely greater than those
required for EPM beneficiaries who are
not homebound. Therefore, waiving the
homebound requirement would lead to
inappropriate payment for postdischarge home visits to EPM
beneficiaries and could result in
increased EPM actual spending, which
is counter to the goals of the EPM.
Final Decision: After consideration of
the public comments we received, we
are finalizing our proposal, without
modification, to maintain the existing
Medicare requirements for home health
services, including the requirement that
the beneficiary be homebound, when
home health services are furnished to
EPM beneficiaries.
For the EPMs, we proposed to adopt
program requirement waivers similar to
the post-discharge home visit waivers
implemented for the CJR model. We
proposed to waive the ‘‘incident to’’ rule
set forth in § 410.26(b)(5) to allow an
EPM beneficiary who does not qualify
for home health services to receive postdischarge visits in his or her home or
place of residence any time during the
episode. The waiver would not apply to
services furnished to beneficiaries who
would qualify for home health services
under the Medicare program, as set forth
under § 409.42. Therefore, these visits
would not be billed for such
beneficiaries. Under the proposed
waiver, we would allow services
furnished under the waiver to be billed
under the PFS by the physician or
nonphysician practitioner who is
supervising the licensed clinical staff or
by the hospital to which the supervising
physician has reassigned his or her
benefits if all other requirements are
met. In the latter scenario, we note that
the post-discharge home visit services
will not be ‘‘hospital services,’’ even
when furnished by licensed clinical
staff of the hospital.
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Under the CJR model, we allow up to
9 post-discharge home visits to be billed
and paid during each 90-day postanchor hospitalization CJR episode.
This limit on the number of visits is
based on the average post-acute care
LOS of approximately 30 to 45 days for
CJR episodes and the incentives under
CJR to improve efficiency, which may
shorten post-acute care stays. Thus, 9
visits represent a home visit on average
of once per week for two-thirds of the
90-day episode duration, the period of
time when the typical beneficiary may
have concluded post-acute care in an
efficient episode.
Since current model data shows that
the average post-acute care LOS may
vary or in some case post-acute care
may not be used at all, for EPMs, we
proposed to use model-specific limits
on post-discharge home visits as
follows:
a. AMI Model
Current model data show that most
beneficiaries with AMI diagnoses,
regardless of AMI medical treatment or
PCI treatment for AMI, are not
discharged to post-acute care. Based on
no post-acute care usage, we proposed
that a beneficiary in the AMI model
could receive up to 13 home visits,
which represents a home visit on
average of once per week for the entire
90-day AMI episode.
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b. CABG Model
Current model data show that most
beneficiaries with CABG diagnoses are
discharged to SNFs or to home health.
Assuming an average post-acute care
LOS of 30 days, we proposed that a
beneficiary in the CABG model could
receive up to 9 home visits, which
represents a home visit on average of
once per week for 60 days, or two-thirds
of a 90-day CABG episode.
c. SHFFT Model
Current model data show that most
beneficiaries with SHFFT diagnoses are
discharged to SNFs with average postacute care LOSs of 30 days. Thus, we
proposed that a beneficiary in the
SHFFT model could receive up to 9
home visits, which represents a home
visit on average of once per week for 60
days, or two-thirds of a 90-day SHFFT
episode.
The following is a summary of the
comments received and our responses.
Comment: Most commenters
supported the ‘‘incident to’’ waiver to
allow general supervision rather than
direct supervision. A few commenters
recommended that the post-discharge
home visits be available to all EPM
beneficiaries, including those who
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qualify for home health services. Some
commenters requested that CMS issue a
clarification that specifically permits a
hospital or community physician or
nonphysician practitioner to contract
with an HHA for home nursing visits
under the ‘‘incident to’’ waiver and that
this clarification should also provide
that the Medicare home health agency
Conditions of Participation do not apply
to such visits.
Response: In the CJR Final Rule, we
responded to similar comments
regarding the ‘‘incident to’’ direct
supervision waiver (80 FR 73442
through 73444). While we appreciate
the commenters’ suggestions that we
provide maximal flexibility to
participant hospitals to deliver the
configuration of services the hospital
believes to be most appropriate to
manage a beneficiary’s care, under the
EPMs we continue to believe that home
visits furnished under the ‘‘incident to’’
direct physician supervision waiver
should be limited to model beneficiaries
who otherwise would not qualify for
home health services. We note that
while home health episodes are 60 days
in duration, payment adjustments are
made for beneficiaries who require only
a few visits during the episode or who
are discharged during the home health
episode. Therefore, EPM beneficiaries
who qualify for home health services
could receive home health services that
would be appropriately paid even if
they qualified for such services for less
than 60 days. Those beneficiaries who
qualify for home health services for any
duration of time during the EPM
episode would not need to receive postdischarge home visits under the
‘‘incident to’’ direct physician
supervisions waiver. Furthermore, we
expect that homebound EPM
beneficiaries may typically need other
types of services provided under the
home health benefit than just postdischarge home visits by clinical staff,
including skilled nursing services,
therapy services, medical supplies, and
medical social services. We would not
expect that post-discharge home visits
provided under the ‘‘incident to’’ direct
physician supervision waiver would
adequately substitute for home health
services under the more comprehensive
Medicare home health benefit. For those
beneficiaries receiving home health
care, paying additionally for postdischarge home visits under the
‘‘incident to’’ direct physician
supervision waiver would be
duplicative of services that should be
furnished under the home health
episode and could lead to ineffective
care coordination and management due
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489
to the involvement of multiple clinical
staff working for different organizations
or physician practices.
Although we proposed to waive the
direct physician supervision
requirement in § 410.26(b)(5) as
previously discussed, licensed clinical
staff providing post-discharge home
visits as ‘‘incident to’’ services would
still need to be considered ‘‘auxiliary
personnel’’ (employed, contracted, or
leased employee of the physician or
same employing organization as
physician) as required by § 410.26(a)(1)
and § 410.26(b)(6). Therefore, it would
not be permissible for HHAs,
community-based organizations,
hospitals, or others to provide postdischarge home visits under the
proposed ‘‘incident to’’ direct physician
supervision waiver as these entities
would not meet the definition of
‘‘auxiliary personnel’’ as outlined in
regulation. At this time, we are
declining to waive any additional
requirements of the ‘‘incident to’’ rules
that would be necessary for these other
entities to furnish EPM post-discharge
home visits because we continue to
believe that the post-discharge home
visits should always be ‘‘incident to’’ a
physician’s professional services,
including that they are an integral,
although incidental, part of the
physician’s professional services in the
course of the diagnosis or treatment of
an illness of injury, and that they are
furnished by auxiliary personnel (if not
by the physician or practitioner with an
‘‘incident to’’ benefit), who by definition
are linked to the physician (or
employing organization of the
physician) by employment, contract, or
lease. We believe the ‘‘incident to’’
relationship of post-discharge home
visits to a physician’s professional
services is critical due to the importance
of robust care coordination and close
care management to episode cost and
quality performance, given the lengthy,
broadly defined EPM episodes. We note
that in the case where a post-discharge
home visit is furnished by licensed
clinical staff employed by the hospital,
the hospital could bill under the PFS if
the supervising physician who is an
employee or a contractor of the hospital
has reassigned his or her benefits to the
hospital. As a result, we are not
providing additional waivers for postdischarge home visits to EPM
beneficiaries who otherwise do not
qualify for Medicare home health
services.
Comment: Most commenters
supported the additional allowance of
visits for AMI model patients, but were
not clear what the clinically appropriate
number should be for any particular
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patient. Some commenters suggested
that CMS not place any limits on the
number of visits since in some cases this
may result in readmissions during the
episode that may be avoided with
additional home monitoring. Other
commenters were concerned that
differential rules about the number of
visits permitted for specific EPM
episodes may be confusing for model
participants. Some commenters
supported CMS’ proposal for differential
post-discharge visit limits at this time,
but urge the agency to monitor care
patterns and consider refinements in the
future with an eye toward consistency
through future rulemaking.
Response: In the CJR Final Rule, we
responded to similar comments
regarding the limit on the number of
post-discharge home visits (80 FR
73444). While we understand that some
commenters would prefer no limit or a
higher limit on the number of postdischarge home visits, as discussed
previously these visits are restricted to
model beneficiaries who do not quality
for home health services. As discussed
in the CJR Final Rule, we continue to
believe it is appropriate to limit the
number of post-discharge home visits
that can be paid under an episode-based
payment model to mitigate the risk of
overutilization, especially in the early
years of the model where EPM
participants have no, or limited,
repayment responsibility for excess
actual episode spending above the
quality-adjusted target price. As with
the CJR post-discharge home visits, we
believe that a limit on the number of
visits is appropriate for the EPMs. In
addition, we believe that the average
post-acute care length of stay data
supports differences in post-acute care
usage for each of the EPMs as discussed
in the proposed rule. Thus, we continue
to believe that it is clinically
appropriate to account for these
differences on an episode-specific basis
when setting the limits on the number
of visits covered under the waiver.
As with the post-discharge home visit
waiver for the CJR model, we are not
prescribing the periodicity, pattern, or
number of these visits for model
beneficiaries. We will monitor
utilization of these visits and may
revisit the maximum number of visits
over the course of the EPMs based on
the implementation experience of EPM
participants.
Comment: Some commenters urged
CMS to require more specific
identification of all the clinicians who
provide services that are billed incident
to another practitioner.
Response: While we believe this
‘‘incident to’’ waiver can be a significant
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tool to support a participant’s success
with the EPM, we believe that the
administrative complexity of changing
the billing requirements in order to
collect this additional information
outweighs the potential usefulness of
this information in evaluating this
aspect of the EPMs.
Final Decision: After consideration of
the public comments we received, we
are finalizing the proposal, without
modification, to waive the ‘‘incident to’’
direct physician supervision
requirement set forth at § 410.26(b)(5),
to allow an EPM beneficiary who does
not qualify for home health services to
receive post-discharge visits in his or
her home or place of residence any time
during the EPM episode following
discharge from an anchor
hospitalization, limited to 13 visits for
the AMI model, 9 visits for the CABG
model, and 9 visits for the SHFFT
model. We will allow practitioners to
bill for services provided by licensed
clinical staff, such as nurses, who are
considered ‘‘auxiliary personnel’’ as
defined in § 410.26(a)(1), when
provided under the general, rather than
direct, supervision of a physician or
nonphysician practitioner. In some
situations the clinical staff providing
these services may be employees of the
participant hospital and, as long as
these clinical staff are supervised by the
billing physician or nonphysician
practitioner and the appropriate
relationship exists between the
physician and the clinical staff,
payment under the PFS can be made.
We plan to monitor utilization patterns
of post-discharge home visits under the
EPMs to monitor for overutilization and
significant reductions in medical home
health services.
Similar to the CJR model, we
proposed that the service be reported
with HCPCS code GXXXX (EPM–AMI,
CABG, or SHFFT model home visit for
patient assessment performed by
clinical staff for an individual not
considered homebound, including, but
not necessarily limited to patient
assessment of clinical status, safety/fall
prevention, functional status/
ambulation, medication reconciliation/
management, compliance with orders/
plan of care, performance of activities of
daily living, and ensuring beneficiary
connections to community and other
services; for use only in the Medicareapproved EPM–AMI, CABG, or SHFFT
model; may not be billed for a 30-day
period covered by a transitional care
management code) and estimated that it
would be paid at approximately $50
under the PFS. The standard PFS rate
setting methodologies establish relative
value units (RVUs) based on the
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resources required to furnish the typical
service. We proposed that final RVUs
under the CY 2017 PFS for the proposed
new HCPCS code for AMI, CABG, and
SHFFT home visits will be included in
this final rule. In addition, we proposed
to update the values each year to
correspond to final values established
under the PFS.
The waiver would not apply with
respect to an AMI, CABG, or SHFFT
beneficiary who has qualified, or would
qualify, for home health services when
the visit was furnished. We expect that
the visits by licensed clinical staff could
include patient assessment, monitoring,
assessment of functional status and fall
risk, review of medications, assessment
of adherence with treatment
recommendations, patient education,
communication and coordination with
other treating clinicians, care
management to improve beneficiary
connections to community and other
services, etc. These post-discharge home
visits would remove barriers to followup care outside of the home with
providers and suppliers and allow the
beneficiary to be treated in his or her
home environment or place of
residence, where potential safety
concerns, such as tripping hazards,
could quickly be identified and
remediated. Given these occasions for
further patient assessment and
intervention, we believe that where
such post-discharge home visits are
furnished, there are opportunities to
increase patient-centered care
coordination and decrease episode
spending, potentially resulting in
higher-quality care for beneficiaries and
increased episode efficiency which may
benefit the beneficiaries, the Medicare
Trust Fund, and EPM participants.
We also proposed to waive current
Medicare billing rules in order to allow
the separate reporting of these postdischarge home visits during surgical
global periods. The PFS payment for the
surgical procedure includes 90 days of
post-operative care furnished by the
surgeon. Post-operative follow-up care
is not separately billable by the surgeon
or, when there is a transfer of care, by
the practitioner to whom care is
transferred. The current construction of
the global packages included in PFS
payments reflects a narrow view of
surgical follow-up care that does not
encompass broader, more
comprehensive models of post-operative
care, such as an episode payment model
like the proposed AMI, CABG, and
SHFFT models. As we have noted in the
past, it is also difficult to determine the
appropriate valuation of the various
components of the current global
packages (2015 Physician Fee Schedule
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79 FR 67584). We do not believe that the
AMI, CABG, and SHFFT post-discharge
home visits, which can include nursing
assessments for chronic conditions for
which care may be affected by the
surgery, would replace or substantially
duplicate the kind of post-operative
visits involved in furnishing postoperative follow-up care for the global
surgery procedure under the PFS.
Instead, we anticipate that the work of
these post-discharge visits will be
similar to the work furnished by the
physician coordinating the patient’s
overall episode care. Therefore, we
proposed to waive the global surgery
billing rules to allow the surgeon or
other practitioners to furnish and bill for
the post-discharge home visits during
surgical global periods.
Comment: Several commenters
supported the proposal to waive current
Medicare billing rules for global
surgeries to allow the separate billing of
these post-discharge home visits by the
physician or nonphysician practitioner
who performed the EPM procedure.
One commenter supported the
proposal, but urged CMS to clarify how
this policy will interact with the PFS
proposal for CY 2017 to require billing
HCPCS G-codes during the global period
to collect information on post-surgical
visits.
Response: We appreciate the support
on these issues. In response to the
request for clarification, we note that
since the post-discharge home visits
furnished to EPM beneficiaries are being
paid for, they do not need to be
separately reported under the global
surgery data collection requirements
under the PFS. (See the CY 2017 PFS
Final Rule, 81 FR 80170, for the
finalized policies related to the global
surgery data collection requirements
under the PFS.)
Final Decision: Services furnished
under the waiver will be billed under
the PFS by the physician or
nonphysician practitioner or by the
entity, including a hospital, to which
the supervising physician or
nonphysician practitioner has
reassigned his or her benefits. We are
also waiving current Medicare billing
rules in order to allow the separate
reporting by the physician who
performed a procedure during the
anchor hospitalization of the EPM
episode of these post-discharge home
visits during surgical global periods
when he or she is providing the general
supervision of the post-discharge home
visit.
The post-discharge home visit will be
billed with the new HCPCS code G9863,
displayed in Table 49. This code will be
payable for EPM model beneficiaries
beginning July 1, 2017, the start date of
the first EPM performance year as
discussed in section III.D.2. of this final
rule. Rather than finalizing the specific
RVUs for this new HCPCS code in this
final rule, we are finalizing them
through reference to the RVUs for
another HCPCS G-code paid under the
PFS. Specifically, the RVUs for this new
code will be based upon the same
inputs used to determine the payment
rate for HCPCS code G9187 (BPCI
initiative home visit for patient
assessment performed by a qualified
health care professional for individuals
not considered homebound including,
but not limited to, assessment of safety,
491
falls, clinical status, fluid status,
medication reconciliation/management,
patient compliance with orders/plan of
care, performance of activities of daily
living, appropriateness of care setting;
(for use only in the Medicare-approved
BPCI initiative); may not be billed for a
30-day period covered by a transitional
care management code), the specific
HCPCS G-code currently used to report
post-discharge home visits under BPCI.
We are crosswalking the RVUs for new
HCPCS code G9863 to the RVUs for the
existing post-discharge home visit
HCPCS G-code for the BPCI model
because, given our view of the
similarities between these two services
in the two different models and the
similar HCPCS G-code descriptors, we
expect the resources required to be the
same so the two codes are assigned the
same inputs under the standard PFS
ratesetting methodologies. In summary,
we are finalizing the policy in this EPM
final rule that the new HCPCS code
G9863 for EPM post-discharge home
visits will have the same RVUs as
HCPCS code G9187 for BPCI model
post-discharge home visits.
The CY 2017 RVUs, geographic
practice cost indices and conversion
factor that determine the PFS payment
for HCPCS code G9187 are included in
the CY 2017 PFS Final Rule. We will
annually update the RVUs for HCPCS
code G9863 for post-discharge home
visits for EPM beneficiaries by
crosswalking the RVUs for HCPCS code
G9863 to HCPCS code G9187 as part of
the annual PFS update, and information
on the update will be included in the
PFS Final Rule each year.
TABLE 49—HCPCS CODE FOR POST-DISCHARGE HOME VISITS FOR EPM BENEFICIARIES
Long descriptor
Short descriptor
G9863 .............................
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HCPCS code number
Episode Payment Model (EPM)—AMI, CABG, or SHFFT model home visit
for patient assessment performed by clinical staff for an individual not
considered homebound, including, but not necessarily limited to patient
assessment of clinical status, safety/fall prevention, functional status/ambulation, medication reconciliation/management, compliance with orders/
plan of care, performance of activities of daily living, and ensuring beneficiary connections to community and other services; for use only in the
Medicare approved EPM—AMI, CABG, or SHFFT model; may not be
billed for a 30-day period covered by a transitional care management
code.
EPM in home visit .....
The waiver of direct supervision
requirements for certain post-discharge
home visits is set forth at § 512.600. The
waiver of certain post-operative billing
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restrictions under the PFS global
surgery rules is set forth at § 512.615.
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RVUs equal to
those of this
HCPCS code
for same calendar year
under the PFS
G9187
5. Billing and Payment for Telehealth
Services
As discussed in the previous section,
we expect that the EPMs’ design
features will lead to greater interest on
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the part of hospitals and other providers
and suppliers caring for EPM
beneficiaries in furnishing services to
beneficiaries in their homes or places of
residence, including physicians’
professional services. While physicians
may furnish and be paid by Medicare
for home visits under the PFS, few visits
actually are furnished to Medicare
beneficiaries because of the significant
physician resources required for such
visits and the general structure of most
office-based physician practices. For
example, in 2014, only 2.6 million
physician or nonphysician practitioner
home visits were furnished to Medicare
beneficiaries, in contrast to almost 250
million office or other outpatient
evaluation and management visits
furnished by physicians or
nonphysician practitioners. EPMs
would create new incentives for
comprehensive episode care
management for beneficiaries, including
early identification and intervention
regarding changes in health status
following discharge from the anchor
hospitalization. We understand that
EPM participants may want to engage
physicians in furnishing timely visits to
homebound or non-homebound EPM
beneficiaries in their homes or places of
residence to address concerning
symptoms or observations raised by
beneficiaries themselves, clinicians
furnishing home health services, or
licensed clinical staff furnishing postdischarge home visits, while physicians
committed to the proposed AMI, CABG,
and SHFFT care redesign may not be
able to revise their practice patterns to
meet this home visit need for EPM
beneficiaries.
Under section 1834(m) of the Act,
Medicare pays for telehealth services
furnished by a physician or practitioner
under certain conditions even though
the physician or practitioner is not in
the same location as the beneficiary.
The telehealth services must be
furnished to a beneficiary located in one
of the eight types of originating sites
specified in section 1834(m)(4)(C)(ii) of
the Act and the site must satisfy at least
one of the requirements of sections
1834(m)(4)(C)(i)(I) through (III) of the
Act. Generally, for Medicare payment to
be made for telehealth services under
the PFS several conditions must be met,
as set forth under § 410.78(b).
Specifically, for a service to be eligible
for payment, the individual receiving
the services must be in an eligible
originating site, and the service must
be—
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• On the Medicare list of telehealth
services; 132
• Furnished via an interactive
telecommunications system; and
• Furnished to a telehealth-eligible
individual.
When all of these conditions are met,
Medicare pays a facility fee to the
originating site and provides separate
payment to the distant-site practitioner
for the service. Section 1834(m)(4)(F)(i)
of the Act defines Medicare telehealth
services to include professional
consultations, office visits, office
psychiatry services, and any additional
service specified by the Secretary, when
furnished via a telecommunications
system.
Under section 1834(m)(4)(F)(ii) of the
Act, CMS has an annual process to
consider additions to and deletions from
the list of telehealth services. We do not
include any services as telehealth
services when Medicare does not
otherwise make a separate payment for
them.
Some literature suggests that
technologies that enable health care
providers to deliver care to patients in
locations remote from providers are
being increasingly used to complement
face-to-face patient-provider encounters
in both urban and rural areas.133 In
these cases, the use of remote access
technologies may improve the
accessibility and timeliness of needed
care, increase communication between
providers and patients, enhance care
coordination, and improve the
efficiency of care. We note that certain
professional services that are commonly
furnished remotely using
telecommunications technology are paid
under the same conditions as in-person
physicians’ services, and thus do not
require a waiver to be considered as
telehealth services.
Such services that do not require the
patient to be present in person with the
practitioner when they are furnished are
covered and paid in the same way as
services delivered without the use of
telecommunications technology when
the practitioner is in person at the
medical facility furnishing care to the
patient.
In other CMS episode-based payment
models, such as BPCI Models 2 and 3
and the CJR model, we determined it
was necessary to waive the geographic132 For the list of approved Medicare telehealth
services, see the CMS Web site at https://
www.cms.gov/Medicare/Medicare-Generalinformation/telehealth/.
133 Telehealth in an Evolving Health Care
Environment: Workshop Summary (2012).
Available at https://www.ic4n.org/wp-content/
uploads/2014/06/IoM-Telehealth-2012-WorkshopSummary.pdf. Accessed on June 7, 2015.
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site requirements of sections
1834(m)(4)(C)(i)(I) through (III) of the
Act. This waiver allows telehealth
services to be furnished to eligible
telehealth individuals when they are
located at one of the eight originating
sites at the time the service is furnished
via a telecommunications system but
without regard to the site meeting one
of the geographic site requirements. For
the proposed EPMs—AMI, CABG, and
SHFFT—we proposed a waiver of this
same provision as well as waiver of the
requirement that the eligible telehealth
individual be in an originating site
when an otherwise-eligible individual is
receiving telehealth services in his or
her home or place of residence. This
waiver would allow providers and
suppliers furnishing services to EPM
beneficiaries to utilize telemedicine for
beneficiaries that are not classified as
rural and to allow the greatest degree of
efficiency and communication between
providers and suppliers and
beneficiaries by allowing beneficiaries
to receive telehealth services at their
home or place of residence. We believe
that these waivers are essential to
maximize the opportunity to improve
the quality of care and efficiency for the
proposed EPMs’ episodes.
Specifically, like the telehealth waiver
for the BPCI and CJR models, we
proposed to waive the geographic-site
requirements of sections
1834(m)(4)(C)(i)(I) through (III) of the
Act that limit telehealth payment to
services furnished within specific types
of geographic areas or in an entity
participating in a federal telemedicine
demonstration project approved as of
December 31, 2000. Waiver of this
requirement would allow beneficiaries
located in any region to receive services
related to the episode to be furnished
via telehealth, as long as all other
Medicare requirements for telehealth
services are met. Any service on the list
of Medicare approved telehealth
services and reported on a claim with an
ICD–9 principal diagnosis code that is
not excluded from the proposed EPMs
episode definition (see section III.C. of
this final rule) could be furnished to an
EPM beneficiary, regardless of the
beneficiary’s geographic location. Under
the proposed EPMs, this waiver would
support care coordination and
increasing timely access to high quality
care for all EPM beneficiaries, regardless
of geography. Additionally, we
proposed, only for the purpose of testing
the proposed EPMs, waiving the
originating site requirements of section
1834(m)(4)(C)(ii)(I)–(VIII) of the Act that
specify the particular sites at which the
eligible telehealth individual must be
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located at the time the service is
furnished via a telecommunications
system. Specifically, we proposed to
waive the requirement only when
telehealth services are being furnished
in the EPM beneficiary’s home or place
of residence during the episode. Any
service on the list of Medicare approved
telehealth services and reported on a
claim with an ICD–10–CM principal
diagnosis code that is not excluded from
the applicable EPM’s episode definition
(see section III.C. of this final rule)
could be furnished to an EPM
beneficiary in his or her home or place
of residence, unless the service’s HCPCS
code descriptor precludes delivering the
service in the home or place of
residence. For example, subsequent
hospital care services could not be
furnished to beneficiaries in their home
since those beneficiaries would not be
inpatients of the hospital.
The existing set of codes used to
report evaluation and management (E/
M) visits are extensively categorized and
defined by the setting of the service, and
the codes describe the services
furnished when both the patient and the
practitioner are located in that setting.
Section 1834(m) of the Act provides for
particular conditions under which
Medicare can make payment for office
visits when a patient is located in a
health care setting (the originating sites
authorized by statute) and the eligible
practitioner is located elsewhere.
However, we do not believe that the
kinds of E/M services furnished to
patients outside of health care settings
via real-time, interactive
communication technology are
accurately described by any existing E/
M codes. This would include
circumstances when the patient is
located in his or her home and the
location of the practitioner is
unspecified. Therefore, in order to
create a mechanism to report E/M
services accurately under the EPMs, we
proposed to create a specific set of
HCPCS G-codes to describe the E/M
services furnished to EPM beneficiaries
in their homes via telehealth. Among
the existing E/M visit services, we
envision these services would be most
similar to those described by the office
and other outpatient E/M codes.
Therefore, we proposed to structure the
new codes similarly to the office/
outpatient E/M codes but adjusted to
reflect the location as the beneficiary’s
residence and the virtual presence of the
practitioner. Specifically, we proposed
to create a parallel structure and set of
descriptors currently used to report
office or other outpatient E/M services,
(CPT codes 99201–99205 for new
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patient visits and CPT codes 99212–
99215 for established patient visits). For
example, the proposed G-code for a
level 3 E/M visit for an established
patient would be a remote in-home visit
for the evaluation and management of
an established patient, which requires at
least two of the following three key
components:
• An expanded problem focused
history.
• An expanded problem focused
examination.
• Medical decision making of low
complexity, furnished in real time using
interactive audio and video technology.
Counseling and coordination of care
with other physicians, other qualified
health care professionals or agencies are
provided consistent with the nature of
the problem(s) and the needs of the
patient or the family or both. Usually,
the presenting problem(s) are of low to
moderate severity. Typically, 15
minutes are spent with the patient or
family or both via real-time, audio and
video intercommunications technology.
We note that we did not propose a Gcode to parallel the level 1 office/
outpatient visit for an established
patient, since that service does not
require the presence of the physician or
other qualified health professional. We
also believe this would duplicate the
home visits for non-homebound
beneficiaries previously proposed in
this section.
We proposed to develop payment
rates for these new telehealth G-codes
for E/M services in the patient’s home
that are similar to the payment rates for
the office/outpatient E/M services, since
the codes will describe the work
involved in furnishing similar services.
Therefore, we proposed to include the
resource costs typically incurred when
services are furnished via telehealth. In
terms of the relative resource costs
involved in furnishing these services,
we believe that the efficiencies of virtual
presentation generally limit resource
costs other than those related to the
professional time, intensity, and
malpractice risk to marginal levels.
Therefore, we proposed to adopt work
and malpractice (MP) RVUs associated
with the corresponding level of office/
outpatient codes as the typical service
because the practitioner’s time and
intensity and malpractice liabilities
when conducting a visit via telehealth
are comparable to the office visit.
We proposed to include final RVUs
under the CY 2016 PFS when we
finalize the rules for EPMs.
Additionally, we proposed to update
these values each year to correspond to
final values established under the PFS.
We considered whether each level of
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493
visit typically would warrant support by
auxiliary licensed clinical staff within
the context of the proposed EPMs. The
cost of such staff and any associated
supplies, for example, would be
incorporated in the practice expense
(PE) RVUs under the PFS. For the lowerlevel visits (levels 1–3 for new visits and
levels 2 and 3 for established visits), we
stated that we do not believe that visits
necessarily would require auxiliary
medical staff to be available in patients’
homes. We anticipate these lower-level
visits would be the most-commonly
furnished and would serve as
mechanisms for patients to consult
quickly with practitioners for concerns
that patients can easily describe and
explain. We did not proposed to include
PE RVUs for these services, since we do
not believe that virtual visits envisioned
for EPMs typically incur the kinds of
costs included in the PE RVUs under
the PFS. For higher-level visits, we
typically would anticipate some amount
of support from auxiliary clinical staff.
For example, wound examination and
minor wound debridement would be
considered included in an E/M visit and
would require licensed clinical staff to
be present in the beneficiary’s home
during the telehealth visit for the
complete service to be furnished. We
believe it would be rare for a
practitioner to conduct as complex and
detailed a service as a level 4 or 5 E/M
home visit via telehealth for
beneficiaries in the proposed EPMs’
episodes without licensed clinical staff
support in the home.
However, we also note that the
proposed EPMs already include several
avenues for licensed clinical staff to be
in the patient’s home, either through a
separately paid home visit as proposed
for the model or through home health
services as discussed earlier in this
section of this final rule. Therefore,
although we consider support by
auxiliary clinical staff to be typical for
levels 4 or 5 E/M visits furnished to
EPM beneficiaries in the home via
telehealth, we did not propose to
incorporate these costs through PE
RVUs. Given the anticipated complexity
of these visits, we would expect to
observe levels 4 and 5 E/M visits to be
reported on the same claim with the
same date of service as a home visit or
during a period of authorized home
health care. If neither of these occurs,
we proposed to require the physician to
document in the medical record that
auxiliary licensed clinical staff were
available on site in the patient’s home
during the visit and if they were not, to
document the reason that such a high-
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level visit would not require such
personnel.
We note that because these home
telehealth services are E/M services, all
other coverage and payment rules
regarding E/M services would continue
to apply.
Under the proposed EPMs, we believe
that this proposal to waive the
originating site requirements and create
new home visit telehealth HCPCS codes
would support the greatest efficiency
and timely communication between
providers and beneficiaries by allowing
beneficiaries to receive telehealth
services at their places of residence.
With respect to home health services
paid under the home health prospective
payment system (HH PPS), we
emphasize that telehealth visits under
this model cannot substitute for inperson home health visits per section
1895(e)(1)(A) of the Act. Furthermore,
telehealth services by social workers
cannot be furnished for EPM
beneficiaries who are in a home health
episode of care because medical social
services are included as home health
services per section 1861(m) of the Act
and paid for under the Medicare HH
PPS. However, telehealth services
permitted under section 1834(m) of the
Act and furnished by physicians or
other practitioners, specifically
physician assistants, nurse practitioners,
clinical nurse specialists, certified nurse
midwives, nurse anesthetists,
psychologists, and dieticians, can be
furnished for EPM beneficiaries who are
in a home health episode of care.
Finally, sections 1835(a) and 1814(a) of
the Act require that the patient has a
face-to-face encounter with the
certifying physician or an allowed
nonphysician practitioner working in
collaboration with or under the
supervision of the certifying physician
before the certifying physician certifies
that the patient is eligible for home
health services. Under § 424.22(a)(1)(v),
the face-to-face encounter can be
performed up to 90 days prior to the
start of home health care or within 30
days after the start of home health care.
Section 424.22(a)(1)(v)(A) also allows a
physician, with privileges, who cared
for the patient in an acute or post-acute
care setting (from which the patient was
directly admitted to home health) or an
allowed nonphysician practitioner
working in collaboration with or under
the supervision of the acute or postacute care physician to conduct the
face-to-face encounter.
Although sections 1835(a) and 1814(a)
of the Act allow the face-to-face
encounter to be performed via
telehealth, we did not propose that the
waiver of the telehealth geographic site
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requirement for telehealth services and
the originating site requirement for
telehealth services furnished in the EPM
beneficiary’s home or place of residence
would apply to the face-to-face
encounter required as part of the home
health certification when that encounter
is furnished via telehealth. In other
words, when a face-to-face encounter
furnished via telehealth is used to meet
the requirement for home health
certification, the usual Medicare
telehealth rules apply with respect to
geography and eligibility of the
originating site. We expect that this
policy will not limit EPM beneficiaries’
access to medically-necessary home
health services because beneficiaries
receiving home health services during a
proposed EPM episode will have had a
face-to-face encounter with either the
physician or an allowed nonphysician
practitioner during their anchor
hospitalization or a physician or
allowed nonphysician practitioner
during a post-acute facility stay prior to
discharge directly to home health
services.
Under the proposed waiver of the
geographic site requirement and
originating site requirement, all
telehealth services would be required to
be furnished in accordance with all
Medicare coverage and payment criteria,
and no additional payment would be
made to cover set-up costs, technology
purchases, training and education, or
other related costs. The facility fee paid
by Medicare to an originating site for a
telehealth service would be waived if
there is no facility as an originating site
(that is, the service was originated in the
beneficiary’s home).
Finally, providers and suppliers
furnishing a telehealth service to a EPM
beneficiary in his or her home or place
of residence during the episode would
not be permitted to bill for telehealth
services that were not fully furnished
when an inability to provide the
intended telehealth service is due to
technical issues with
telecommunications equipment
required for that service.
Beneficiaries would be able to receive
services furnished pursuant to the
telehealth waivers only during the
proposed EPM episode.
We plan to monitor patterns of
utilization of telehealth services under
the proposed EPMs to monitor for
overutilization or reductions in
medically-necessary care, and
significant reductions in face-to-face
visits with physicians and nonphysician
practitioners. We plan to specifically
monitor the distribution of new
telehealth home visits that we did
propose, as we anticipate greater use of
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lower level visits. Given our concern
that auxiliary licensed clinical staff be
present for level 4 and 5 visits, we will
monitor our proposed requirement that
these visits be billed on the same claim
with the same date of service as a home
nursing visit, during a period authorized
home health care, or that the physician
document the presence of auxiliary
licensed clinical staff in the home or an
explanation as to the specific
circumstances precluding the need for
auxiliary staff for the specific visit.
The existing set of codes used to
report evaluation and management (E/
M) visits are extensively categorized and
defined by the setting of the service, and
the codes describe the services
furnished when both the patient and the
practitioner are located in that setting.
Section 1834(m) of the Act provides for
particular conditions under which
Medicare can make payments for office
visits when a patient is located in a
health care setting (the originating sites
authorized by statute) and the eligible
practitioner is located elsewhere.
However, in the proposed rule, we
stated that we did not believe that the
kinds of E/M services furnished to
patients outside of health care settings
via real-time, interactive
communication technology are
accurately described by any existing E/
M codes. This would include
circumstances when the patient is
located in his or her home and the
location of the practitioner is at another
location. Therefore, in order to create a
mechanism to report E/M services
accurately under the EPMs, we
proposed to create a specific set of
HCPCS G-codes to describe the E/M
services furnished to EPM beneficiaries
in their homes via telehealth when the
physician or practitioner is in another
location.
Among the existing E/M visit services,
we stated that we envision these
services would be most similar to those
described by the office and other
outpatient E/M codes. Therefore, we
proposed to structure the new codes
similarly to the office/outpatient E/M
codes but adjusted to reflect the location
as the beneficiary’s residence and the
virtual presence of the practitioner.
Specifically, we proposed to create a
parallel structure and set of descriptors
currently used to report office or other
outpatient E/M services, (CPT codes
99201 through 99205 for new patient
visits and CPT codes 99212 through
99215 for established patient visits). For
example, in the proposed rule we
discussed a HCPCS G-code for a level 3
E/M visit for an established patient
would be a telehealth visit for the
evaluation and management of an
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established patient in the patient’s
home, which requires at least 2 of the
following 3 key components:
• An expanded problem focused
history.
• An expanded problem focused
examination.
• Medical decision making of low
complexity.
Counseling and coordination of care
with other physicians, other qualified
health care professionals or agencies are
provided consistent with the nature of
the problem(s) and the patient’s or
family’s needs or both. Usually, the
presenting problem(s) are of low to
moderate severity. Typically, 15
minutes are spent with the patient or
family or both via real-time, audio and
video intercommunications technology.
The preceding text would be included
in the code descriptor for the proposed
level 3 established patient telehealth E/
M visit HCPCS G-code, just as this
information is currently included in the
code descriptor for the corresponding
level 3 established patient office/
outpatient E/M CPT code.
In the proposed rule, we noted that
we were not proposing a HCPCS G-code
to parallel the level 1 office/outpatient
visit for an established patient, since
that service does not require the
presence of the physician or other
practitioner. We stated our belief that
this would duplicate the home visits for
non-homebound beneficiaries
previously discussed in this section.
We proposed to develop payment
rates for these new telehealth G-codes
for E/M services in the patient’s home
that are similar to the payment rates for
the office/outpatient E/M services, since
the codes will describe the work
involved in furnishing similar services.
Therefore, we proposed to include the
resource costs typically incurred when
services are furnished via telehealth. In
terms of the relative resource costs
involved in furnishing these services, in
the proposed rule we stated our belief
that the efficiencies of virtual
presentation generally limit resource
costs other than those related to the
professional time, intensity, and MP risk
to marginal levels. Therefore, we
proposed to adopt work and MP RVUs
associated with the corresponding level
of office/outpatient codes as the typical
service because the practitioner’s time
and intensity and MP liabilities when
conducting a visit via telehealth are
comparable to the office visit. We stated
that final RVUs under the CY 2016 PFS
would be included in the EPM final
rule. Additionally, we proposed to
update these values each year to
correspond to final values established
under the PFS.
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We considered whether each level of
visit typically would warrant support by
auxiliary licensed clinical staff within
the context of the EPMs. The cost of
such staff and any associated supplies,
for example, would be incorporated in
the practice expense (PE) RVUs under
the PFS. For the lower level visits,
levels 1 through 3 for new visits and 2
and 3 for established visits, we did not
believe that the visit would necessarily
require auxiliary clinical staff to be
available in the patient’s home. We
anticipated these lower level visits
would be the most commonly furnished
and would serve as a mechanism for the
patient to consult quickly with a
practitioner for concerns that can be
easily described and explained by the
patient. We did not propose to include
PE RVUs for these services, since we did
not believe that virtual visits envisioned
for this model typically incur the kinds
of costs included in the PE RVUs under
the PFS. For higher level visits, we
typically would anticipate some amount
of support from auxiliary clinical staff.
For example, wound examination and
minor wound debridement would be
considered included in an E/M visit and
would require licensed clinical staff to
be present in the beneficiary’s home
during the telehealth visit in order for
the complete service to be furnished.
We stated our belief that it would be
rare for a practitioner to conduct as
complex and detailed a service as a
level 4 or 5 E/M home visit via
telehealth for EPM beneficiaries in the
EPM episodes without licensed clinical
staff support in the home.
However, we also noted that the
proposed model already includes
several avenues for licensed clinical
staff to be in the patient’s home, either
through a separately paid home visit as
proposed for the model or through home
health services as discussed earlier in
this final rule. Therefore, although we
considered support by auxiliary clinical
staff to be typical for level 4 or 5 E/M
visits furnished to EPM beneficiaries in
the home via telehealth, we did not
propose to incorporate these costs
through PE RVUs. Given the anticipated
complexity of these visits, we noted that
we would expect to observe level 4 and
5 E/M visits to be reported on the same
claim with the same date of service as
a home visit or during a period of
authorized home health care. If neither
of these occurs, we proposed to require
the physician to document in the
medical record that auxiliary licensed
clinical staff were available on site in
the patient’s home during the visit and
if they were not, to document the reason
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495
that such a high-level visit would not
require such personnel.
We noted that because the services
described by the HCPCS G-codes for the
proposed model, by definition, are
furnished remotely using
telecommunications technology, they
therefore are paid under the same
conditions as in-person physicians’
services and they do not require a
waiver to the requirements of section
1834(m) of the Act. We also noted that
because these home telehealth services
would be E/M services, all other
coverage and payment rules regarding
E/M services would continue to apply.
We additionally noted that under the
EPMs, this proposal to waive the
originating site requirements and create
new home visit telehealth HCPCS codes
would support the greatest efficiency
and timely communication between
providers and beneficiaries by allowing
beneficiaries to receive telehealth
services at their places of residence.
We sought comments on the proposed
waivers with respect to telehealth
services, and the proposed creation of
the home visit telehealth codes.
The following is a summary of the
comments received and our responses.
Comment: Many commenters
supported the waiver of originating site
and geographic site requirements and
allowing telehealth visits for the EPMs.
One commenter urged CMS to clarify
that EPM participants can provide
telehealth services that are not covered
by Medicare or not paid for when
provided free of charge if that supports
the goal of improving quality while
reducing costs. Another commenter
suggested that CMS waive the
requirement that services furnished
under this waiver be performed by
physicians or nonphysician
practitioners and to permit the
provision of telehealth services by
HHAs through licensed clinicians to
individuals who are not receiving
Medicare-covered home health services.
Another commenter cautioned CMS
against the use of wasteful telehealth
services that increase costs without
improving health care access or quality.
One commenter recommended that
CMS allow even greater flexibility for
EPM episode services and proceed
further by allowing a waiver for
technological restrictions and to offer
up-front payment for investment in
telehealth services beyond those
currently covered under the telehealth
benefit. One commenter requested that
this waiver, if implemented, be
authorized for any provider types that
are allowed to provide telehealth
services per state laws. Another
commenter urged CMS to engage with
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patients and providers to determine the
most effective ways to test telehealth in
populations that need it most.
Response: We appreciate the
information from commenters on
alternative approaches to providing care
other than in-person. In the CJR Final
Rule, we responded to similar
comments regarding the telehealth
waivers (80 FR 73448). As with the CJR
model, the EPM is not testing a
telehealth model and, therefore, we do
not intend to fundamentally change the
scope of telehealth requirements for
payment under Medicare. Rather, we
proposed to waive certain existing
telehealth requirements to provide
participant hospitals with additional
tools to improve episode quality and
efficiency given the constraints on
physician time for in-person visits at
distant locations or in the beneficiary’s
home. The proposed waivers would
allow greater physician engagement via
telehealth in EPM beneficiary care
coordination and management following
an EPM anchor hospitalization,
regardless of the beneficiary’s
geographic location or home location.
We believe that under the EPM it is
important for beneficiaries to receive
telehealth services in a way that permits
them to interact with treating health
care professionals in real-time,
including being able to both see and
interact with those providers, and the
treating health care professionals being
able to see and listen to the
beneficiaries. Beneficiaries recovering at
home following an EPM anchor
hospitalization benefit from meaningful
engagement in care that is patientcentered in order to improve their
understanding and adherence to
treatment regimens. Therefore, we do
not believe it would be appropriate to
allow telehealth services to be furnished
to EPM model beneficiaries that do not
meet the existing Medicare telehealth
requirements for communications
technology.
As with CJR model, we continue to
believe that it would not be appropriate
to allow telehealth services to be
furnished to EPM beneficiaries that do
not meet the existing Medicare
telehealth requirements for
communications technology. Finally, in
response to the commenter requesting
that we clarify that EPM participants
can provide telehealth services free-ofcharge, when they are not covered and
paid by Medicare, we refer to section
III.I.9. of this final rule for discussion of
the requirements for in-kind beneficiary
engagement incentives that may be
provided by EPM participants under the
EPMs.
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Comment: One commenter strongly
objected to the proliferation of new
telehealth-specific HCPCS G-codes
when there is a suitable CPT code to
describe the service and urged CMS to
allow for telehealth coverage of any
related CPT/HCPCS procedure codes for
physical medicine and rehabilitation.
Another commenter was concerned that
new codes are without clinical merit or
distinction and undermine parity of
clinical standards of care between
services provided by telehealth means
and service provided in-person.
Response: As discussed in the CJR
Final Rule (80 FR 73450), we continue
to believe that specific HCPCS G-codes
are the most appropriate way for
telehealth visits furnished in a model
beneficiary’s home or place of residence
to be reported and paid. The work and
MP RVUs for these new HCPCS G-codes
will be the same as those for the
comparable office and other outpatient
E/M visit codes under the CY 2017 PFS.
The HCPCS G-codes, their descriptors,
and the CPT codes upon which their
RVUs are based are displayed in Table
50. While we acknowledge that
telehealth services are likely to incur
practice expenses, as discussed in the
proposed rule, we do not believe that
virtual visits envisioned for this model
typically incur the kinds of costs
included in the PE RVUs under the PFS;
we believe that these are merely a subset
of the expenses incurred for in-person
visits. And while we would be
interested in examining any publicly
available data regarding these costs
relative to the costs included in the
RVUs for other PFS services, we are
finalizing our proposal not to include
PE RVUs in the payment rate for these
unique EPM services. Accordingly, we
are waiving section 1834(m)(4)(2)(B) to
allow this deviation from the payment
of office/outpatient visits for purposes
of the EPM telehealth in-home visit
services. Finally, we will consider new
CPT codes as they are released
according to our usual processes, and
will specifically evaluate whether they
may be used in the future to report
home telehealth visits for CJR model
and EPM beneficiaries.
Final Decision: After consideration of
the public comments received, we are
finalizing our proposal, without
modification, to waive the geographic
site requirements of section
1834(m)(4)(C)(i)(I) through (III) of the
Act that limit telehealth payment to
services furnished within specific types
of geographic areas or in an entity
participating in a federal telemedicine
demonstration project approved as of
December 31, 2000. Any service on the
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list of Medicare-approved telehealth
services and reported on a claim with an
ICD–10–CM principal diagnosis code
that is not excluded from the EPM
episode definition (see section III.C.3.b.
of this final rule) can be furnished to an
EPM beneficiary, regardless of the
beneficiary’s geographic location. We
also are finalizing our proposal to waive
the originating site requirements of
section 1834(m)(4)(C)(ii)(I) through
(VIII) of the Act that specify the
particular sites at which the eligible
telehealth individual must be located at
the time the service is furnished via a
telecommunications system only when
telehealth services are being furnished
in the EPM beneficiary’s home or place
of residence during the episode. Any
service on the list of Medicare approved
telehealth services and reported on a
claim with an ICD–10–CM principal
diagnosis code that is not excluded from
the EPM episode definition (see section
III.C.3.b. of this final rule) can be
furnished to a EPM beneficiary in his or
her home or place of residence, unless
the service’s HCPCS code descriptor
precludes delivering the service in the
home or place of residence. We will
continue to require that telehealth
services furnished under the EPM
telehealth waiver be furnished using an
interactive telecommunications system,
consistent with the current requirement
for payment of telehealth services under
the PFS. The waiver of certain
telehealth requirements is set forth at
§ 512.605.
We are finalizing the proposal,
without modification, to create 9 HCPCS
G-codes to report home telehealth E/M
visits furnished under the EPM waiver
as displayed in Table 50. These codes
will be payable for EPM beneficiaries
beginning July 1, 2017, the start date of
the EPM performance year as discussed
in section III.D.2. of this final rule.
Rather than finalizing the RVUs for the
new HCPCS codes in this final rule, we
are finalizing them through reference to
the RVUs for other CPT codes paid
under the PFS as equal to the work and
MP RVUs established for the
comparable office/outpatient visits.
The final CY 2017 RVUs, geographic
practice cost indices and conversion
factor that determine the payment rates
for the CPT codes are included in the
CY 2017 PFS Final Rule.
We will update the RVUs for the EPM
HCPCS telehealth G-codes annually by
crosswalking them to the corresponding
CPT codes as part of the annual PFS
update, and information on the updates
will be included in the PFS final rule
each year.
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497
TABLE 50—HCPCS CODES FOR TELEHEALTH VISITS FOR EPM BENEFICIARIES IN HOME OR PLACE OF RESIDENCE
Code number
Long descriptor
G9864 ...........
Remote in-home visit for the evaluation and management of a new patient for use
only in the Medicare-approved Episode Payment Model—AMI, CABG, or SHFFT
model, which requires these 3 key components:
• A problem focused history;
• A problem focused examination; and
• Straightforward medical decision making, furnished in real time using interactive
audio and video technology.
Counseling and coordination of care with other physicians, other qualified health
care professionals or agencies are provided consistent with the nature of the
problem(s) and the needs of the patient or the family or both. Usually, the presenting problem(s) are self limited or minor. Typically, 10 minutes are spent with
the patient or family or both via real time, audio and video intercommunications
technology.
Remote in-home visit for the evaluation and management of a new patient for use
only in the Medicare-approved Episode Payment Model—AMI, CABG, or SHFFT
model, which requires these 3 key components:
• An expanded problem focused history;
• An expanded problem focused examination;
• Straightforward medical decision making, furnished in real time using interactive
audio and video technology.
Counseling and coordination of care with other physicians, other qualified health
care professionals or agencies are provided consistent with the nature of the
problem(s) and the needs of the patient or the family or both. Usually, the presenting problem(s) are of low to moderate severity. Typically, 20 minutes are
spent with the patient or family or both via real time, audio and video intercommunications technology.
Remote in-home visit for the evaluation and management of a new patient for use
only in the Medicare-approved Episode Payment Model—AMI, CABG, or SHFFT
model, which requires these 3 key components:
• A detailed history;
• A detailed examination;
• Medical decision making of low complexity, furnished in real time using interactive audio and video technology.
Counseling and coordination of care with other physicians, other qualified health
care professionals or agencies are provided consistent with the nature of the
problem(s) and the needs of the patient or the family or both. Usually, the presenting problem(s) are of moderate severity. Typically, 30 minutes are spent with
the patient or family or both via real time, audio and video intercommunications
technology.
Remote in-home visit for the evaluation and management of a new patient for use
only in the Medicare-approved Episode Payment Model—AMI, CABG, or SHFFT
model, which requires these 3 key components:
• A comprehensive history;
• A comprehensive examination;
• Medical decision making of moderate complexity, furnished in real time using
interactive audio and video technology.
Counseling and coordination of care with other physicians, other qualified health
care professionals or agencies are provided consistent with the nature of the
problem(s) and the needs of the patient or the family or both. Usually, the presenting problem(s) are of moderate to high severity. Typically, 45 minutes are
spent with the patient or family or both via real time, audio and video intercommunications technology.
G9865 ...........
G9866 ...........
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G9867 ...........
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Short descriptor
Sfmt 4700
Work and MP
RVUs equal to
those of the corresponding office/outpatient E/
M visit CPT code
for same calendar year under
the PFS
In home E/M new pt
10 mins.
99201
In home E/M new pt
20 mins.
99202
In home E/M new pt
30 mins.
99203
In home E/M new pt
45 mins.
99204
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TABLE 50—HCPCS CODES FOR TELEHEALTH VISITS FOR EPM BENEFICIARIES IN HOME OR PLACE OF RESIDENCE—
Continued
Code number
Long descriptor
G9868 ...........
Remote in-home visit for the evaluation and management of a new patient for use
only in the Medicare-approved Episode Payment Model—AMI, CABG, or SHFFT
model, which requires these 3 key components:
• A comprehensive history;
• A comprehensive examination;
• Medical decision making of high complexity, furnished in real time using interactive audio and video technology.
Counseling and coordination of care with other physicians, other qualified health
care professionals or agencies are provided consistent with the nature of the
problem(s) and the needs of the patient or the family or both. Usually, the presenting problem(s) are of moderate to high severity. Typically, 60 minutes are
spent with the patient or family or both via real time, audio and video intercommunications technology.
Remote in-home visit for the evaluation and management of an established patient
for use only in the Medicare-approved Episode Payment Model—AMI, CABG, or
SHFFT model, which requires at least 2 of the following 3 key components:
• A problem focused history;
• A problem focused examination;
• Straightforward medical decision making, furnished in real time using interactive
audio and video technology.
Counseling and coordination of care with other physicians, other qualified health
care professionals or agencies are provided consistent with the nature of the
problem(s) and the needs of the patient or the family or both. Usually, the presenting problem(s) are self limited or minor. Typically, 10 minutes are spent with
the patient or family or both via real time, audio and video intercommunications
technology.
Remote in-home visit for the evaluation and management of an established patient
for use only in the Medicare-approved Episode Payment Model—AMI, CABG, or
SHFFT model, which requires at least 2 of the following 3 key components:
• An expanded problem focused history;
• An expanded problem focused examination;
• Medical decision making of low complexity, furnished in real time using interactive audio and video technology.
Counseling and coordination of care with other physicians, other qualified health
care professionals or agencies are provided consistent with the nature of the
problem(s) and the needs of the patient or the family or both. Usually, the presenting problem(s) are of low to moderate severity. Typically, 15 minutes are
spent with the patient or family or both via real time, audio and video intercommunications technology.
Remote in-home visit for the evaluation and management of an established patient
for use only in the Medicare-approved Episode Payment Model—AMI, CABG, or
SHFFT model, which requires at least 2 of the following 3 key components:
• A detailed history;
• A detailed examination;
• Medical decision making of moderate complexity, furnished in real time using
interactive audio and video technology.
Counseling and coordination of care with other physicians, other qualified health
care professionals or agencies are provided consistent with the nature of the
problem(s) and the needs of the patient or the family or both. Usually, the presenting problem(s) are of moderate to high severity. Typically, 25 minutes are
spent with the patient or family or both via real time, audio and video intercommunications technology.
G9869 ...........
G9870 ...........
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G9871 ...........
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Short descriptor
Sfmt 4700
Work and MP
RVUs equal to
those of the corresponding office/outpatient E/
M visit CPT code
for same calendar year under
the PFS
In home E/M new pt
60 mins.
99205
In home E/M est. pt
10 mins.
99212
In home E/M est. pt
15 mins.
99213
In home E/M est. pt
25 mins.
99214
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TABLE 50—HCPCS CODES FOR TELEHEALTH VISITS FOR EPM BENEFICIARIES IN HOME OR PLACE OF RESIDENCE—
Continued
Code number
Long descriptor
G9872 ...........
Remote in-home visit for the evaluation and management of an established patient
for use only in the Medicare-approved Episode Payment Model—AMI, CABG, or
SHFFT model, which requires at least 2 of the following 3 key components:
• A comprehensive history;
• A comprehensive examination;
• Medical decision making of high complexity, furnished in real time using interactive audio and video technology.
Counseling and coordination of care with other physicians, other qualified health
care professionals or agencies are provided consistent with the nature of the
problem(s) and the needs of the patient or the family or both. Usually, the presenting problem(s) are of moderate to high severity. Typically, 40 minutes are
spent with the patient or family or both via real time, audio and video intercommunications technology.
6. SNF 3-Day Rule
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a. Waiver of SNF 3-Day Rule
Pursuant to section 1861(i) of the Act,
a beneficiary must have a prior inpatient
hospital stays of no fewer than 3
consecutive days, within a short period
of time (generally 30 days), in order to
be eligible for Medicare coverage of
inpatient SNF care. We refer to this as
the SNF 3-day rule. We note that the
SNF 3-day rule has been waived for
Medicare SNF coverage under other
episode payment models, including
BPCI Model 2 and the CJR model. BPCI
Model 2 awardees that request and are
approved for the waiver can discharge
Model 2 beneficiaries in fewer than 3
days from an anchor hospital stay to a
SNF, where services are covered under
Medicare Part A as long as all other
coverage requirements for such services
are satisfied. Under the CJR model, we
adopted a waiver of the SNF 3-day rule
that applies beginning in performance
year 2 as hospitals are not bearing risk
in their first year. As discussed in
section V.N. of this final rule, we are
revising the effective date of the waiver
of the SNF 3-day rule for the CJR model,
and we are stating that participant
hospitals may begin using the waiver for
episodes that begin on or after January
1, 2017.
We proposed EPM payment policies,
similar to CJR payment policies which
would require participating EPM
hospitals to repay Medicare for excess
episode spending beginning in
performance year 2. Episode payment
models like BPCI, CJR, and those being
finalized in this final rule have the
potential to mitigate the existing
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Short descriptor
incentives under the Medicare program
to overuse SNF benefits for
beneficiaries, as well as to furnish many
fragmented services that do not reflect
significant coordinated attention to and
management of complications following
hospital discharge. The removal of these
incentives in an EPM lays the
groundwork for offering EPM
participants greater flexibility around
the parameters that determine SNF stay
coverage. BPCI participants considering
the early discharge of a beneficiary
pursuant to the waiver during a Model
2 episode must evaluate whether early
discharge to a SNF is clinicallyappropriate and SNF services are
medically-necessary. Next, they must
balance that determination and the
potential benefits to the hospital in the
form of internal cost savings due to
greater financial efficiency with the
understanding that a subsequent
hospital readmission, attributable to
premature discharge or low quality SNF
care, could substantially increase
episode spending while also resulting in
poorer quality of care for the
beneficiary. Furthermore, early hospital
discharge for a beneficiary who would
otherwise not require a SNF stay (that
is, the beneficiary has no identified
skilled nursing or rehabilitation need
that cannot be provided on an
outpatient basis) following a hospital
stay of typical length does not improve
episode efficiency under episode-based
payment models such as BPCI, the CJR
model, or the EPMs in this final rule.
Because of the potential benefits we
see for participating EPM hospitals,
their provider partners, and
beneficiaries, we proposed to waive in
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In home E/M est. pt
40 mins.
Work and MP
RVUs equal to
those of the corresponding office/outpatient E/
M visit CPT code
for same calendar year under
the PFS
99215
certain instances, where it is clinicallyappropriate, the SNF 3-day rule for
coverage of a SNF stay following the
anchor hospitalization under EPM for
episodes that begin on or after April 1,
2018. While our intent is to align the
effective date of the availability of this
program waiver with performance year
2 of the model, when repayment
responsibility for actual episode
spending that exceeds the target price
begins, we believe that an effective date
based on the start of the episode will be
clearer to participant hospitals, SNFs,
and others in determining whether the
waiver is available for an EPM
beneficiary. We believe that clarity
regarding whether a waiver applies to
SNF services furnished to a particular
beneficiary is important to help ensure
compliance with the conditions of the
waiver and also improve our ability to
monitor waivers for misuse. We
proposed to use our authority under
section 1115A of the Act with respect to
certain SNFs that furnish Medicare Part
A post-hospital extended care services
to beneficiaries included in an EPM
episode. We believe this waiver is
necessary to the model test so that EPM
participants can redesign care
throughout the episode continuum of
care extending to 90 days post-discharge
from the anchor hospital stay in order
to maximize quality and hospital
financial efficiency, as well as reduce
episode spending under Medicare.
However, we did not propose to waive
this requirement in performance year 1,
when EPM participants are not
responsible for excess actual episode
spending. We believe that there is some
potential for early hospital discharge
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followed by a SNF stay to increase
actual episode spending over historical
patterns unless EPM participants are
particularly mindful of this potential
unintended consequence. Without
participant repayment responsibility in
performance year 1, we are concerned
that Medicare would be at full risk
under the model for increased episode
spending because, without a financial
incentive to closely manage care,
hospitals might be more likely to
discharge beneficiaries to SNFs early
leading to increased episode spending
for which the hospital would bear no
responsibility. For EPM episodes
beginning on or after April 1, 2018, we
proposed to waive the SNF 3-day rule,
where clinically-appropriate, because
participants will bear partial or full
responsibility (capped at the proposed
stop-loss limit described in section
III.D.7.b. of this final rule) for excess
episode actual spending, thereby
providing a strong incentive in those
years for participants to redesign care
with both quality and efficiency
outcomes as priorities. All other
Medicare rules for coverage and
payment of Part A-covered SNF services
would continue to apply to EPM
beneficiaries in all performance years of
the model.
In addition, for the EPMs being
finalized in this final rule and for future
EPMs where this waiver is clinicallyappropriate and the average LOS for
Medicare beneficiaries hospitalized for
certain EPM procedures without major
complications or comorbidities may be
already relatively short at 3 days we
believe that we should protect
immediate EPM beneficiary safety and
optimizing health outcomes. Therefore,
we proposed to require that participants
may only discharge an EPM beneficiary
under this proposed waiver of the SNF
3-day rule to a SNF rated an overall of
three stars or better by CMS based on
information publicly available at the
time of hospital discharge. Problem
areas due to early hospital discharge
may not be discovered through model
monitoring and evaluation activities
until well after the episode has
concluded, and the potential for later
negative findings alone may not afford
sufficient beneficiary protections. CMS
created a Five-Star Quality Rating
System for SNFs to allow SNFs to be
compared more easily and to help
identify areas of concerning SNF
performance. The Nursing Home
Compare Web site gives each SNF an
overall rating of between 1 and 5
stars.134 Those SNFs with 5 stars are
considered to have much above average
134 www.medicare.gov/NursingHomeCompare/
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quality, and SNFs with 1 star are
considered to have quality much below
average. Published SNF ratings include
distinct ratings of health inspection,
staffing, and quality measures, with
ratings for each of the three sources
combined to calculate an overall rating.
These areas of assessment are all
relevant to the quality of SNF care
following discharge from the anchor
hospitalization initiating an EPM
episode, especially if that discharge
occurs after fewer than 3 days in the
hospital. Because of the potential greater
risks following early inpatient hospital
discharge, we believe it is appropriate
that all EPM beneficiaries discharged
from the EPM participant to a SNF in
fewer than 3 days be admitted to a SNF
that has demonstrated that it is capable
of providing quality care to patients
with significant unresolved postsurgical symptoms and problems. We
believe such a SNF would need to
provide care of at least average overall
quality, which would be represented by
an overall SNF 3-star or better rating.
As discussed in the CJR Final Rule (80
FR 73457 through 73459), commenters
expressed concern about the variation in
the number of SNFs across the
participating MSAs rated an overall 3
stars or better that would qualify for the
SNF 3-day rule waiver under CJR. While
we appreciate the variation in qualifying
SNFs across the participating MSAs, we
continue to believe that we need to
balance the goal of improved efficiency
under an episode payment model
through additional access to a covered
SNF stay after an anchor hospitalization
of less than 3 days with protecting
beneficiaries from the risks of care
stinting and premature discharge from
the hospital that may result from the
financial incentives of episode payment.
We note that all 294 MSAs that we
proposed as eligible for selection for the
AMI and CABG models in the proposed
rule have at least one SNF that passed
the 3 star requirement from June 2015
to May 2016 and would therefore
qualify for the waiver under our
proposal. Therefore, all EPM
beneficiaries would have access to at
least one SNF in the MSA of the
participant hospital that meets the SNF
overall star rating requirement for the
proposed EPM waiver.
Thus, the participating hospital must
discharge the beneficiary to a SNF that
is qualified under the SNF 3-day rule
waiver. We proposed that to be qualified
under the SNF 3-day rule waiver a SNF
must be included in the most recent
calendar year quarter Five-Star Quality
Rating System listing for SNFs on the
Nursing Home Compare Web site for the
date of the beneficiary’s admission to
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the SNF. The qualified SNF must be
rated an overall 3 stars or better for at
least 7 of the 12 months based on a
review of the most recent rolling 12
months of overall star ratings. We
proposed to post on the CMS Web site
the list of qualified SNFs in advance of
the calendar quarter.
For the CJR model, we justified the
waiver of the SNF 3-day rule by
reviewing data specific to the
characteristics of CJR beneficiaries, such
as, the geometric mean hospital LOS for
the MS–DRGs associated with lower
extremity joint replacement (3 to 7 days)
and the frequency and length of SNF
usage (typically 30 days) for CJR
beneficiaries. We stated in the CJR Final
Rule that we believe this waiver is
necessary to the model test so that CJR
participant hospitals could redesign
care throughout the episode continuum
of care extending to 90 days postdischarge from the anchor hospital stay
in order to maximize quality and
hospital financial efficiency, as well as
reduce episode spending under
Medicare. However, the waiver does not
apply in performance year 1, when CJR
participant hospitals are not responsible
for excess actual episode spending.
Based on our analysis of data
discussed in section III.J.3. of this final
rule, we believe some program and
patient outcome vulnerabilities may
exist with adopting the waiver of the
SNF 3-day rule for the proposed AMI,
CABG, and SHFFT models or under
future EPMs. To mitigate these possible
vulnerabilities, we believe it will be
necessary to determine if this waiver
applies to EPMs on a model-specific
basis as follows:
• AMI Model—AMI beneficiaries
have geometric mean hospital LOSs that
are similar to CJR beneficiaries, 2.0–4.5
days (see Table 47). Most AMI
beneficiaries, regardless of AMI medical
treatment or PCI treatment for AMI, are
not discharged to post-acute care. There
is no research that shows increased
mortality associated with the hospital
LOS. Therefore, we believe that is may
be clinically-appropriate to proposed to
waive the SNF 3-day rule for the AMI
model for episodes beginning on or after
April 1, 2018, as participant hospitals
are not bearing risk in their first
performance year or performance year 2
(NDR).
We proposed that the waiver be
available for the AMI beneficiary’s care.
The SNF would insert a Treatment
Authorization Code on the claim for a
beneficiary in the model where the SNF
seeks to the use the waiver. This process
would promote coordination between
the SNF and the AMI model participant,
as the SNF would need to be in close
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communication with the EPM
participant to ensure that the
beneficiary is in the model at the time
the waiver is used. We proposed that
where the beneficiary would be eligible
for inclusion in an AMI episode of care
at the time of hospital discharge, use of
the waiver would be permitted where it
is medically-necessary and appropriate
to discharge the beneficiary to a SNF
prior to a 3-day inpatient stay. A
beneficiary would be eligible to receive
services furnished under the 3-day rule
waiver only during the AMI episode.
• CABG Model—CABG beneficiaries
have a geometric mean hospital LOS of
6.0 to 11.6 days (see Table 47), much
longer than the CJR model’s mean LOS.
While most CABG beneficiaries are
discharged to SNFs, a mean hospital
LOS well above 3 days indicates that it
would not be clinically-appropriate for
early discharges provided with this
waiver. Therefore, we did not propose
to waive the SNF 3-day rule for the
CABG model.
• SHFFT Model—SHFFT
beneficiaries have a geometric mean
hospital LOS of 3.7–6.7 days (see Table
47), somewhat close to the CJR model’s
mean LOS. However, studies show that
shorter than average hospital LOSs for
hip fracture are associated with higher
mortality.135 While most SHFFT
beneficiaries are discharged to SNFs, a
mean hospital LOS above 3 days along
with a higher mortality rates associated
with shorter than average hospital LOSs
indicates that it would not be clinicallyappropriate for early discharges
provided with this waiver. Therefore,
we proposed not to waive the SNF 3-day
rule for the SHFFT model.
We plan to monitor patterns of SNF
utilization under the EPM, particularly
with respect to hospital discharge in
fewer than 3 days to a SNF, to ensure
that beneficiaries are not being
discharged prematurely to SNFs and
that they are able to exercise their
freedom of choice without patient
steering. We sought comment on our
proposal to waive the SNF 3-day stay
rule for stays in SNFs rated overall as 3
stars or better following discharge from
the anchor hospitalization in EPM
episodes.
The following is a summary of the
comments received and our responses.
Comment: Commenters generally
supported the proposal to allow EPM
beneficiaries to be discharged to a SNF
after less than a 3-day inpatient hospital
stay, though one commenter
recommended CMS not adopt its
proposal to permit EPM participants
135 https://www.ncbi.nlm.nih.gov/pubmed/
19817664.
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under any condition to waive the SNF
3-Day Stay Rule when referring EPM
beneficiaries to a SNF.
Commenters urged CMS to implement
the waiver on July 1, 2017, rather than
delaying until April 1, 2018 so that
providers have an opportunity to use
the waiver and redesign care pathways
in ways that streamline and improve the
quality of care before the measurement
period begins for cost reconciliations.
One commenter was concerned that
limiting the 3-day SNF waiver to
discharges from the anchor
hospitalization would be problematic if
a patient is readmitted to a hospital
during the 90-day post-discharge
episode duration and subsequently
needs SNF care. One commenter
strongly suggested a broader waiver of
the 3-day Rule for small and rural
hospitals than CMS proposed.
A few commenters requested that
CMS make the SNF waiver available
regardless of the star rating of the
admitting SNF. Some of these
commenters acknowledged the rationale
for a quality requirement for the
admitting SNF but asserted that the
proposed use of the star rating would
not be appropriate for determining the
quality requirement. A couple of
commenters asserted that the overall
star rating would not directly correlate
to an AMI episode and would therefore
not be predictive of which SNFs would
be most capable of caring for AMI
beneficiaries under the waiver. A few
commenters recommended that CMS
modify the proposed criteria of ‘‘at least
3 stars’’ to ‘‘at least 3 stars overall OR
at least 3 stars on both the staffing and
quality measure components.’’ Another
commenter suggested the waiver apply
only if the facility has a star-rating of
four stars or above, while another
commenter suggested the waiver apply
to any SNF with a star rating of two
stars or above. One commenter
recommended that some allowance/
methodology be developed to allow new
SNFs that have not received a Star
Rating to participate in the Waiver.
Another commenter was concerned that
the demand on SNFs with three or more
stars will create capacity issues and
limit the ability to discharge patients to
those facilities, and a few commenters
were concerned that the quality
requirement would constrain
beneficiary freedom of choice.
Response: In the CJR Final Rule, we
responded to similar comments
regarding the SNF waiver (80 FR 73456).
As we discussed in the EPM proposed
rule and the CJR Final Rule, an episode
payment model like the CJR model or
the EPM has the potential to mitigate
the existing incentives under the
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501
Medicare program to overuse SNF
benefits for beneficiaries, as well as to
furnish many fragmented services that
do not reflect significant coordinated
attention to and management of
complications following hospital
discharge. The reduction of these
incentives in an episode payment model
lays the groundwork for offering
participant hospitals greater flexibility
around the parameters that determine
SNF stay coverage. As discussed in the
CJR Final Rule, we understand from
many current BPCI Model 2 participants
engaged in LEJR episodes that this
waiver plays an important role in their
care redesign efforts to streamline and
improve the quality of care, as they
work closely with their SNF partners.
Regarding the delay in availability of
the 3-day rule waiver, we linked the
proposed availability of the 3-day rule
waiver to the downside risk of the EPM
participant. Specifically, we stated in
the proposed rule that since EPM
participants had no downside risk
during PY 1 (for discharges prior to
April 1, 2018), we were concerned that
participants may be more likely to
discharge beneficiaries to SNFs early
leading to increased episode spending
for which the participant would bear no
responsibility. Accordingly, we
proposed to delay the availability of the
3-day rule waiver until PY 2 for
discharges on or after April 1, 2018 and
beyond.
In section III.D.2.c. of this final rule,
based on comments requesting phasedin downside risk beginning later than
we proposed for the EPM, we agreed
that delaying the date by which
participants would be required to
assume downside risk would improve
participants’ ability to successfully
achieve the goals of the models.
Accordingly, we are finalizing the
policy that EPM participants will not be
required to assume downside risk until
PY 3—that is, episodes ending on or
after January 1, 2019, with anchor
hospital discharges that occur on or
after October 4, 2018 (90 days prior to
January 1, 2019).
Consistent with linking the
availability of the 3-day rule waiver to
the participant’s downside risk, for this
final rule, we believe it is appropriate to
delay the availability of the 3-day rule
waiver until PY 3. For the purposes of
implementing this waiver, we will allow
the 3-day rule waiver for anchor
hospital discharges that occur on or
after October 4, 2018. We believe that
implementing this waiver with an
effective date for discharges that occur
on or after October 4, 2018, rather than
implementing this waiver with an
effective date for episodes ending on or
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after January 1, 2019, provides clarity to
the anchor hospital and the recipient
SNF whether the waiver applies to SNF
services furnished to a particular
beneficiary. We believe this clarity is
important to help ensure compliance
with the conditions of the waiver and
also improves our ability to
operationally monitor waivers for
misuse.
Also, we are allowing participants to
voluntarily elect downside risk for
episodes ending on or after January 1,
2018 (PY 2). However, we will not
provide the waiver for those
participants who elect voluntary early
downside risk in PY 2. It is
operationally infeasible for us to first
allow use of the waiver in different
years for different EPM participants. We
expect that most participants will not
elect early downside risk, because we
do not expect to have more robust riskadjustment in place until performance
year 3. Regarding responses to other 3day rule comments, we believe that
limiting the 3-day SNF waiver to
discharges from the anchor
hospitalization at an EPM participant is
appropriate as the care redesign needed
to support a clinically appropriate early
discharge from an AMI anchor
hospitalization would not necessarily
support other types of hospital
discharges that might occur during the
course of an episode. We note that
limiting use of the waiver to discharges
from the anchor hospitalization does not
preclude a beneficiary from receiving
SNF care at other points during the 90day episode. Medicare will continue to
cover SNF stays for EPM beneficiaries
who require SNF care and remain in the
hospital 3 days or longer under all
existing rules for Medicare coverage and
payment of Part A-covered SNF
services.
With respect to the use of the star
rating as a quality requirement for the
admitting SNF, we believe that our
proposal to limit use of the SNF 3-day
stay rule waiver to discharges of
beneficiaries to SNFs with an overall
rating of three stars or better provides
sufficient and appropriate protection
against premature hospital discharge,
especially in the context of the financial
and quality incentives under the model
itself. As discussed in the CJR Final
Rule (80 FR 73458) we believe it is
appropriate to restrict access to the
waiver in order to ensure SNF quality
and, therefore, protect the beneficiary
from potential harm that could arise
from the financial incentives of an
episode payment model. We continue to
believe that SNF overall ratings reflect
important differences in quality among
SNFs that are applicable to care of EPM
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beneficiaries. With respect to
beneficiary choice, we note that
imposing conditions upon a waiver to
limit its use is not the same as
restricting access to certain SNFs that
would continue to be available to
beneficiaries after a qualifying 3-day
inpatient stay. Medicare will continue
to cover SNF stays for EPM beneficiaries
who require SNF care and remain in the
hospital 3 days or longer under all
existing rules for Medicare coverage and
payment of Part A-covered SNF
services, and these rules do not include
a star rating requirement. In this way,
the EPM waiver of the SNF 3-day stay
rule is an extension of existing coverage
for a Part A-covered SNF stay, and is not
a limit to it.
Comment: Some commenters believed
that 3-day rule waiver should apply to
the CABG and SHFFT models in
addition to the AMI model. Some of
these commenters asserted that the
waiver should be available for all
clinical episodes under the EPMs, with
participant hospitals given the
flexibility to evaluate on a case-by-cases
basis when early discharge to a SNF is
clinically appropriate and the SNF
services are medically necessary, with
some recommending that CMS also
implement the SNF 3-day rule waiver
for Medicare Advantage Organizations
and all Shared Savings Program ACOs.
Response: As discussed in the
proposed rule, to mitigate program and
patient outcome vulnerabilities that may
exist with adopting the waiver of the
SNF 3-day rule, we believe it will be
necessary to determine if this waiver
applies to EPMs on a model-specific
basis. Based on our analysis of data
discussed in section III.J.3. of this final
rule, we continue to believe the 3-day
rule waiver should not be applied to
CABG and SHFFT model beneficiaries,
given the typical severity of their
clinical conditions treated with surgery
that is followed by relatively lengthy
inpatient hospital care. We will
continue to monitor this waiver during
the EPM testing to determine if
modification of this limited waiver is
warranted. We note that
recommendations regarding the waivers
under Medicare programs other than the
EPM or CJR model are out of scope of
this rule.
Comment: One commenter
recommended that instead of requiring
SNF to insert a Treatment Authorization
Code on the claim for a beneficiary in
the model where the SNF seeks to the
use the waiver, CMS should provide
SNFs with reference numbers for EPM
beneficiaries that are eligible to receive
services under the waiver, similar to the
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list that CMS provides to ACOs under
the Shared Savings Program.
Response: Under the Shared Savings
Program, beneficiaries are attributed to
an ACO and CMS can compile and
provide ACOs with a beneficiary
assignment list for the performance
year. In contrast, EPM episodes are
triggered by admission to an EPM
participant that results in discharge
from an anchor hospitalization for a
specified surgery or clinical condition,
and it would not be practical or timely
for CMS to compile and disseminate a
prospective list of EPM beneficiaries
that would be available to SNFs upon
SNF admission.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal, with
modification to waive the SNF 3-day
rule for AMI episodes for discharges
from anchor hospitalizations that occur
on or after October 4, 2018, without
modification of the SNF quality
requirements. We will waive the SNF 3day rule for a beneficiary who is an AMI
model beneficiary on the date of
discharge from the anchor
hospitalization only if the SNF is
qualified at the time of the AMI model
beneficiary’s SNF admission. We define
a qualified SNF as one that has an
overall rating of three stars or better in
the Five-Star Quality Rating System for
SNFs on the Nursing Home Compare
Web site for at least 7 of the 12
preceding months, as determined by
CMS based on the most recent rolling 12
months of SNF star rating data available
for the calendar quarter that includes
the date of the beneficiary’s admission
to the SNF. We will post the list of
qualified SNFs quarterly to the CMS
Web site. If a SNF is on this list, the
other requirements for the waiver as
listed previously are met, and other
existing Medicare coverage
requirements are met, the SNF stay for
the AMI model beneficiary will be
covered under Part A under the AMI
model SNF 3-day rule waiver.
The SNF would insert a Treatment
Authorization Code on the claim for a
beneficiary in the AMI model where the
SNF seeks to the use the waiver. This
process would promote coordination
between the SNF and the AMI model
participant, as the SNF would need to
be in close communication with the
AMI model participant to ensure that
the beneficiary is in the model at the
time the waiver is used. Where the
beneficiary is an AMI model beneficiary
on the date of discharge from an anchor
hospitalization, use of the waiver would
be permitted where it is medically
necessary and appropriate to discharge
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the beneficiary to a SNF prior to a 3-day
inpatient stay.
All other Medicare rules for coverage
and payment of Part A-covered SNF
services continue to apply. The waiver
of the SNF 3-day rule is set forth at
§ 512.610.
b. Additional Beneficiary Protections
Under the SNF 3-Day Stay Rule Waiver
For those specific proposed EPMs,
where we proposed to allow the SNF 3day rule waiver, we proposed
beneficiary protections against financial
liability in addition to the beneficiary
protections discussed elsewhere in this
final rule. In proposing additional
beneficiary protections that may be
necessary to ensure proper use of the
SNF 3-day rule waiver under the
proposed EPMs, we noted that there are
existing, well-established payment and
coverage policies for SNF services based
on sections 1861(i), 1862(a)(1), and 1879
of the Act that include protections for
beneficiaries from liability for certain
non-covered SNF charges. These
existing payment and coverage policies
for SNF services continue to apply
under the EPMs, including SNF services
furnished pursuant to the SNF 3-day
waiver. (For example, see section 70 in
the Medicare Claims Processing Manual,
Chapter 30—Financial Liability
Protections on the CMS Web site at
https://www.cms.gov/Regulations-andGuidance/Guidance/Manuals/
Downloads/clm104c30.pdf; and
Medicare Coverage of Skilled Nursing
Facility Care at https://
www.medicare.gov/Pubs/pdf/10153.pdf;
Medicare Benefit Policy Manual,
Chapter 8—Coverage of Extended Care
(SNF) Services Under Hospital
Insurance at https://www.cms.gov/
Regulations-and-Guidance/Guidance/
Manuals/downloads/bp102c08.odf). In
general, CMS requires that the SNF
inform a beneficiary in writing about
services and fees before the beneficiary
is discharged to the SNF (§ 483.10(b)(6));
a beneficiary cannot be required to
request extra services as a condition of
continued stay (§ 483.10(c)(8)(iii)(B));
and the SNF must inform a beneficiary
that requests an item or service for
which a charge will be made that there
will be a charge for the item or service
and what the charge will be
(§ 483.10(c)(8)(iii)(C)). (See also Chapter
6 of Medicare Coverage of Skills
Nursing Facility Care at https://
www.medicare.gov/Pubs/pdf/
10153.pdf.)
As discussed in the CJR Final Rule,
commenters expressed concern
regarding the lag between a CJR
beneficiary’s Medicare eligibility status
change and a participant hospital’s
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awareness of that change. There may be
cases in which a SNF waiver is used by
a participant hospital because the
participant hospital believes that the
beneficiary meets the criteria, based on
the information available to the hospital
and SNF at the time of the beneficiary’s
admission to the SNF, but in fact the
beneficiary’s Medicare eligibility status
has changed and the hospital was
unaware of it based on available
information. We recognize that despite
good faith efforts by participant
hospitals and SNFs to determine a
beneficiary’s Medicare status for the
model, it may occur that a beneficiary
is not eligible to be included in the CJR
model at the time the SNF waiver is
used.
As discussed in section V.N. of this
final rule, for the CJR model we
proposed to cover services furnished
under the SNF waiver at § 510.610 when
the information available to the provider
at the time the services under the SNF
waiver were furnished indicated that
the beneficiary was included in the CJR
model (see 81 FR 50968 through 50971).
Similarly for EPM, we proposed to cover
services furnished under the SNF
waiver at proposed § 512.61 when the
information available to the provider at
the time the services furnished under
the SNF waiver were furnished
indicated that the beneficiary was
included in the CJR model (see 81 FR
50941 through 50943).
In addition, as discussed in the CJR
Final Rule, we noted that we would
continue to evaluate the waiver of the
SNF 3-day rule, including further
lessons learned from Innovation Center
models in which a waiver of the SNF 3day rule is being tested. We indicated
that in the event we determine that
additional safeguards or protections for
beneficiaries or other changes were
necessary, such as to incorporate
additional protections for beneficiaries,
we would propose the necessary
changes through future rulemaking.
We have continued to learn from
implementation of the SNF 3-day rule
waiver in the CJR model, other models,
and the Shared Savings Program. Based
on these experiences, we believe there
are situations where it would be
appropriate to require additional
beneficiary financial protections under
the SNF 3-day rule waiver for the
applicable proposed EPMs. Specifically,
we are concerned about potential
beneficiary financial liability for noncovered Part A SNF services that might
be directly related to use of the SNF 3day waiver under the applicable EPMs.
For instance, we are concerned that a
beneficiary could be charged for noncovered SNF services if an EPM
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503
participant discharges a beneficiary to a
SNF that does not meet the quality
requirement (3 stars or higher in 7 of the
last 12 months), and the beneficiary is
not provided a discharge planning
notice, as described in proposed
§ 512.450(b). Another scenario would be
where the EPM participant applies the
SNF 3-day rule waiver for episodes that
begin prior to April 1, 2018, when this
waiver is not applicable (as proposed),
and payment to the qualified SNF for
furnishing Medicare covered SNF
services is denied. A third scenario
would be if an EPM participant applies
the SNF 3-day rule waiver for a specific
proposed EPM where the waiver is not
allowed, such as under the CABG and
SHFFT episodes in this final rule. In
any of these circumstances, we assume
the EPM participant’s intent was to rely
upon the SNF 3-day rule waiver, but the
waiver requirements were not met.
When this occurs, we are concerned that
once the claim is rejected, the
beneficiary may not be protected from
financial liability under existing
Medicare rules because the waiver
would not be available, and the
beneficiary would not have had a
qualifying inpatient hospital stay. Thus,
the EPM beneficiary could be charged
by the SNF for non-covered SNF
services that were a result of an
inappropriate attempt to use the waiver.
In these cases, Medicare would deny
payment of the SNF claim, and the
beneficiary could potentially be charged
by the SNF for these non-covered SNF
services, potentially subjecting such
beneficiaries to significant financial
liability. We believe that the rejection of
the claim, in these cases, could easily
have been avoided if the hospital had
confirmed that the requirements for
applying of the SNF 3-day waiver were
satisfied.
Other models have addressed similar
issues in which the beneficiary may be
subject to financial liability for noncovered SNF services related to the
waiver. The Next Generation ACO
Model generally places the risk on the
SNF, where the SNF did not qualify
under the waiver or otherwise knew or
reasonably could be expected to have
known that payment would not be made
for the non-covered SNF services. In
such cases, CMS makes no payment for
the services, and the SNF may not
charge the beneficiary for the services
and must return any monies collected
from the beneficiary. Additionally,
under the Next Generation ACO Model,
the ACO must indemnify and hold the
beneficiary harmless for the services. In
the proposed rule, we stated our belief
that it is appropriate to adopt a similar
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policy under the EPMs. In contrast to
the Next Generation ACO Model,
however, we stated our belief that it was
most appropriate to hold the EPM
participants financially responsible for
misusing the waiver in situations where
waiver requirements are not met,
because EPM participants are required
to be aware of the 3-day waiver
requirements. EPM participants are the
entities financially responsible for
episode spending under the proposed
EPMs and will make the decision as to
whether it is appropriate to discharge a
beneficiary without a 3-day stay.
We proposed that EPM participants
may begin using this waiver only for
specific episodes beginning on or after
April 1, 2018, and may only utilize the
waiver to discharge a beneficiary to a
SNF that meets the quality
requirements. We proposed that EPM
participants are required to ensure the
waiver requirements of proposed
§ 512.610 (a) and (b) are met. Therefore,
in the proposed rule we stated our belief
that it is reasonable that the ultimate
responsibility and liability for a noncovered SNF stay should rest with the
EPM participant. We considered
holding the SNF responsible but
decided that since hospitals, not SNFs,
are the EPM participants, they therefore
should be held responsible for
complying with the SNF 3-day rule
waiver conditions for the reasons stated
previously.
To protect EPM beneficiaries from
being charged for non-covered SNF
charges in instances when the waiver
was used inappropriately, we proposed
to add certain beneficiary protection
requirements in proposed § 512.610.
These requirements would apply for
SNF services that would otherwise have
been covered except for lack of a
qualifying 3-day hospital stay.
Specifically, we proposed if, subsequent
to an EPM participant applying the SNF
3-day rule waiver, we determine that the
following waiver requirements were not
met then the EPM participant will be
financially liable for the SNF stay:
• The EPM participant discharges a
beneficiary that is in a specific EPM
where the SNF 3-day rule waiver does
not apply.
• The EPM participant discharges a
beneficiary prior to April 1, 2018 (as
proposed), where the SNF 3-day rule
waiver does not apply.
• The EPM participant discharges a
beneficiary to a SNF that does not meet
the quality requirement (3 stars or
higher in 7 of the last 12 months) and
does not provide a discharge planning
notice, as described in proposed
§ 512.450(b), to the beneficiary alerting
them of potential financial liability.
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In these preceding instances, we
proposed to apply the following rules:
• CMS shall make no payment to the
SNF for such services.
• The SNF shall not charge the
beneficiary for the expenses incurred for
such services, and the SNF shall return
to the beneficiary any monies collected
for such services.
• The hospital shall be responsible
for the cost of the non-covered SNF
services furnished during the SNF stay.
In addition, if the EPM participant
discharges an EPM beneficiary to a SNF
that does not meet the quality
requirement (3 stars or higher in 7 of the
last 12 months) and a discharge
planning notice, as described in
proposed § 512.450(b), is provided to
the EPM beneficiary alerting them of
potential financial liability then the
hospital will not be financially liable for
the cost of the SNF stay and the normal
Medicare FFS rules for coverage of SNF
services will apply.
The discharge notice absolves the
EPM participant of liability. However,
we are requiring EPM participants to
keep a record of discharge planning
notice distribution to EPM beneficiaries.
We will monitor EPM participants’ use
of discharge notification letters to
protect EPM beneficiaries from potential
abuse of the waiver. Nevertheless, we
recognize there are some situations in
which a beneficiary may wish to be
discharged before a qualifying 3-day
stay and may accept financial liability
for a non-qualifying stay, in which case
the participant hospital will not be held
financially liable for the SNF stay.
Therefore, when the EPM participant
has discharged a beneficiary to a SNF
that does not qualify under the
conditions of the waiver, we believe it
is reasonable that the ultimate
responsibility and financial liability for
a non-covered SNF stay should rest with
the EPM participant. We will
communicate with hospitals and SNFs
about how a hospital would pay SNFs
for non-qualifying services provided.
We sought comment on these
proposals. Specifically, we sought
comment on whether it is reasonable to:
(a) Cover services furnished under the
SNF waiver based on the EPM
participant’s knowledge of beneficiary
eligibility for the applicable proposed
EPMs, as determined by Medicare
status, at the time the services under the
waiver were furnished; and (b) to hold
the EPM participant financially
responsible for rejected SNF claims as a
result of lack of a qualifying inpatient
hospital stay in cases where the EPM
participant discharges a beneficiary to a
SNF that did not qualify for waiver use
and did not provide the beneficiary with
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a discharge planning notice. We sought
comment on whether SNFs instead of,
or in addition to, the EPM participant
should be held liable for such claims
and under what circumstances. Finally,
we sought comment on any other
related issues that we should consider
in connection with these proposals to
protect beneficiaries from significant
financial liability for non-covered SNF
services related to the waiver of the SNF
3-day rule under the proposed EPMs.
We may address those issues through
future notice and comment rulemaking.
The following is a summary of the
comments received and our responses.
Comment: Many commenters
expressed support for CMS’ proposal to
cover services furnished under the SNF
waiver based on an EPM participant’s
knowledge of beneficiary eligibility for
the EPM at the time the services under
the waiver were furnished. A few
commenters sought clarification
whether CMS was proposing this policy
for both the CJR model and the EPM,
though these same commenters
expressed their support and asserted
that the same protection should be
extended to both CJR and EPM
beneficiaries.
Response: We appreciate commenters’
support for this proposed policy. We
will finalize our proposal to cover
services furnished under the SNF
waiver based on the EPM participant’s
knowledge of beneficiary eligibility for
the applicable proposed EPMs, as
determined by Medicare status, at the
time the services under the waiver were
furnished. We refer readers to section
V.N. of this final rule for a discussion
of the additional beneficiary protections
under the SNF 3-day stay rule waiver
for CJR beneficiaries.
Comment: Commenters agreed that
beneficiaries should not be charged for
non-covered SNF charges in instances
where the EPM participant discharges a
beneficiary to a SNF that did not qualify
for waiver use and did not provide the
beneficiary with a discharge planning
notice. Some commenters asserted that
hospitals should not be solely
responsible for non-covered SNF
services resulting from discharging a
beneficiary to a SNF that does not meet
the quality requirement as it is
challenging for hospitals to keep track of
changes in SNF ratings or to identify
EPM beneficiaries in a timely manner. A
few of these commenters recommended
that CMS provide EPM participants
with a list of eligible SNFs on a
quarterly or periodic basis.
A couple of commenters expressed
concern that independent physicians
could refer and admit a beneficiary to a
SNF that does not meet the quality
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requirement without including the
hospital, yet the hospital would be
financially liable for the non-covered
SNF stay under the proposed policy.
Some commenters suggested that the
SNF should share in financial liability
for non-covered SNF services related to
misuse of the waiver as the SNF is
providing and billing for these noncovered services, and CMS should
consider ways in which it could ensure
the SNFs take steps to ensure that
patients discharged to the SNF with less
than a 3-day inpatient stay qualify to
receive services under the waiver.
Response: We appreciate commenters’
support for our proposal that
beneficiaries should not be charged for
non-covered SNF charges in instances
where the EPM participant discharges a
beneficiary to a SNF that did not qualify
for waiver use and did not provide the
beneficiary with a discharge planning
notice.
As discussed in the previous section,
we proposed that to be qualified under
the SNF 3-day rule waiver a SNF must
be rated an overall 3 stars or better for
at least 7 of the 12 months based on a
review of the most recent rolling 12
months of overall star ratings, and we
proposed to post on the CMS Web site
the list of qualified SNFs in advance of
the calendar quarter.
As discussed in the previous section,
the waiver of the SNF 3-day rule only
applies to circumstances where the
beneficiary is medically appropriate for
discharge and requires a SNF stay after
less than a 3-day inpatient hospital stay.
Medicare will continue to cover SNF
stays for EPM beneficiaries who require
SNF care and remain in the hospital 3
days or longer under all existing rules
for Medicare coverage and payment of
Part A-covered SNF services, and these
rules do not include a star rating
requirement. In this way, the EPM
waiver of the SNF 3-day stay rule is an
extension of existing coverage for a Part
A-covered SNF stay, and is not a limit
to it. An EPM participant that believes
it is incapable of identifying qualifying
SNFs or EPM beneficiaries is not
required to use the waiver.
As discussed in the previous section,
the waiver provides EPM participants
with additional flexibilities to redesign
care in order to maximize quality and
efficiency, as well as reduce episode
spending and generate hospital internal
cost savings. Therefore, we believe that
it is appropriate to hold the EPM
participants financially responsible for
misusing the waiver in situations where
waiver requirements are not met.
We acknowledge that an independent
physician might refer a beneficiary to a
SNF that does not qualify under the
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waiver. However, we believe that the
established process for discharge
planning would typically involve the
hospital. EPM participants are required
to be aware of the 3-day waiver
requirements, and the EPM participants
will make the decision as to whether it
is appropriate to discharge a beneficiary
without a 3-day stay. We note that if the
beneficiary chooses a SNF that does not
qualify under the waiver based on a
physician’s recommendation and the
hospital provides proper notification of
non-coverage, the beneficiary would be
financially liable for the SNF stay, while
the EPM participant would not be
financially liable for the SNF stay.
We considered the suggestions of
commenters that SNFs share in financial
liability for non-covered SNF services
related to the waiver of the SNF 3-day
rule under the proposed EPMs. EPM
participants are required to be aware of
the 3-day waiver requirements. SNFs are
not EPM participants, and we believe
that SNFs will rely upon the hospital, as
the EPM participant, to determine
whether use of the waiver is
appropriate. As we gain experience with
the EPM, we may revisit this issue in
future rulemaking.
Comment: One commenter suggested
that CMS assume responsibility for
providing the beneficiary notice as an
objective, informed and trusted voice in
this process. Another commenter
requested that CMS provide clarification
as to what an EPM participant needs to
maintain as documentation showing the
hospital has provided the proper
discharge notice to the patient prior to
discharge, which would absolve the
EPM participant of financial liability if
the SNF waiver is not appropriate. One
commenter recommended that CMS
require EPM participant to inform
beneficiaries of their options, including
(1) waiving the 3-day hospital stay and
going to a 3-star or higher rated SNF
with no additional financial
consequences for the beneficiary; (2)
beneficiary can opt to stay in the
hospital the full 3 days and then select
a SNF of their choosing regardless of
star status; or (3) beneficiary can accept
the 3-day stay waiver and choose any
SNF understanding that they are liable
for the full cost of that care, as it would
not be a Medicare eligible expense. One
commenter urged CMS to modify its
proposal so that beneficiaries are held
harmless for non-covered SNF services
for which they are referred by the
originating hospital, regardless of
whether a discharge planning notice is
provided.
Response: As discussed in section
III.G. of this final rule, hospitals are
required to provide beneficiaries with
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505
written notification of their post-acute
care options upon discharge. Given the
existing relationship between the
hospital and the patient, and the
hospital’s established role in discharge
planning, we believe that it is
appropriate to require the EPM
participant to provide beneficiaries with
written notification if the EPM
participant makes any referrals for noncovered services as part of the discharge
planning process. We do not believe
that it would be practical or consistent
with existing Medicare policy for CMS
to provide the beneficiary with notice at
time of discharge if the SNF waiver is
not appropriate and the services would
not be covered. With respect to the
commenter’s suggested approach for
notifying the beneficiary of the range of
options available post-discharge, we
refer to section III.G. of this final rule for
discussion of discharge planning
requirements for EPM participants and
the essential elements that are required
for proper beneficiary notification.
Comment: One commenter was
concerned that the proposal does not
address cases in which Medicare
accepts a beneficiary’s appeal of
Medicare Provider Non-Coverage after
the discharging physician determined
not to certify that patient for Skilled
Nursing Facility (‘‘SNF’’) care. The
commenter believes that CMS should
not penalize EPM participant for cases
where Medicare allowed an appeal.
Response: Under this proposal, if the
EPM participant provides the
beneficiary with proper notification that
the SNF stay would not be covered, the
hospital would not be financially liable
for the non-covered SNF stay regardless
of the results of a beneficiary’s appeal of
Medicare Provider Non-Coverage.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal, without
modification, to cover services
furnished under the SNF waiver based
on the EPM participant’s knowledge of
beneficiary eligibility for the applicable
proposed EPMs, as determined by
Medicare status at the time the services
under the waiver were furnished. We
are also finalizing the proposal, without
modification, to hold the EPM
participant financially responsible for
rejected SNF claims if an EPM
beneficiary is discharged to a SNF
without a qualifying 3-day inpatient
stay, but the SNF is not on the qualified
list as of the date of admission to the
SNF, and the EPM participant has failed
to provide a discharge planning notice
as specified in § 512.450(b)(3).
Specifically, if subsequent to an EPM
participant applying the SNF 3-day rule
waiver, we determine that the following
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waiver requirements were not met then
the EPM participant will be financially
liable for the SNF stay:
• The EPM participant discharges a
beneficiary that is in a specific EPM
where the SNF 3-day rule waiver does
not apply.
• The EPM anchor hospital
discharges a beneficiary prior to October
4, 2018 (as finalized in section III.J.6.a.
of this final rule), where the SNF 3-day
rule waiver does not apply.
• The EPM participant discharges a
beneficiary to a SNF that does not meet
the quality requirement (3 stars or
higher in 7 of the last 12 months) and
does not provide a discharge planning
notice, as described in proposed
§ 512.450(b)(3), to the beneficiary
alerting them of potential financial
liability.
In these preceding instances, we
proposed to apply the following rules:
• CMS shall make no payment to the
SNF for such services.
• The SNF shall not charge the
beneficiary for the expenses incurred for
such services, and the SNF shall return
to the beneficiary any monies collected
for such services.
• The hospital shall be responsible
for the cost of the non-covered SNF
services furnished during the SNF stay.
The final policies for financial
liability for non-covered SNF services
provided due to incorrect application of
the SNF 3-day rule waiver are set forth
in § 512.610(c).
7. Waivers of Medicare Program Rules
To Allow Reconciliation Payment or
Repayment Actions Resulting From the
Net Payment Reconciliation Amount
In order to make a reconciliation
payment to or carry out recoupment
from a participant that results from the
NPRA calculation for each performance
year as discussed in section III.D.5. of
this final rule, we believe we would
need to waive certain Medicare program
rules. Therefore, in accordance with the
authority in section 1115A(d)(1) of the
Act, we proposed to waive requirements
of the Act for all Medicare Part A and
Part B payment systems only to the
extent necessary to make reconciliation
payments or receive repayments based
on the NPRA that reflect the episode
payment methodology under this
proposed payment model for EPM
participants selected in accordance with
CMS’s proposed selection methodology.
In addition, our proposals on
reconciliation payments or repayments
would not change beneficiary costsharing from the regular Medicare
program cost-sharing for the related Part
A and Part B services that were paid for
CJR beneficiaries and aggregated to
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determine actual episode spending in
the calculation of the NPRA. We
therefore would waive the requirements
of sections 1813 and 1833(a) of the Act
to the extent that they would otherwise
apply to reconciliation payments or
repayments from an EPM participant.
We sought comment on our proposed
waivers related to repayment and
recoupment actions as a result of the
NPRA calculated.
We did not receive any comments
suggesting changes to this waiver thus,
we are finalizing the proposal, without
modification, to waive requirements of
the Act for all Medicare Part A and Part
B payment systems only to the extent
necessary to make reconciliation
payments or receive repayments based
on the NPRA that reflect the episode
payment methodology under this
proposed payment model for EPM
participants selected in accordance with
CMS’s proposed selection methodology.
In addition, reconciliation payments or
repayments would not change
beneficiary cost-sharing from the regular
Medicare program cost-sharing for the
related Part A and Part B services that
were paid for EPM beneficiaries and
aggregated to determine actual episode
spending in the calculation of the
NPRA. We therefore are waiving the
requirements of sections 1813 and
1833(a) of the Act to the extent that they
would otherwise apply to reconciliation
payments or repayments from an EPM
participant. The waiver of deductible
and coinsurance that otherwise apply to
reconciliation payments or repayments
is set forth at § 512.620.
8. New Waiver for Providers and
Suppliers of Cardiac Rehabilitation and
Intensive Cardiac Rehabilitation
Services Furnished to EPM Beneficiaries
During an AMI or CABG Episode
A cardiac rehabilitation (CR) program,
as defined in § 410.49(a) of the
regulations, means a physiciansupervised program that furnishes
physician prescribed exercise, cardiac
risk factor modification, psychosocial
assessment, and outcomes assessment.
An intensive cardiac rehabilitation (ICR)
program, as defined in § 410.49(a) of the
regulations, means a physiciansupervised program that furnishes
cardiac rehabilitation and has shown, in
peer-reviewed published research, that
it improves patients’ cardiovascular
disease through specific outcome
measurements described in § 410.49(c).
Services provided under CR and ICR
programs may be furnished to EPM
beneficiaries during the proposed AMI
and CABG episodes. We note that all
EPM beneficiaries in an AMI or CABG
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episode would meet CMS’s coverage
criteria for CR and ICR services.
Section 410.49(f) describes the
limitations of coverage of cardiac
rehabilitation programs. The coverage
requirements of CR limits the number of
cardiac rehabilitation program sessions
to a maximum of 2 one-hour sessions
per day for up to 36 sessions over a
period up to 36 weeks with the option
for an additional 36 sessions over an
extended period of time if approved by
the MAC under section 1862(a)(1)(A) of
the Act. Intensive cardiac rehabilitation
program sessions are limited to 72 onehour sessions (as defined in section
1848(b)(5) of the Act), up to 6 sessions
per day, over a period of up to 18 weeks.
In section VI. of this final rule, we are
making a payment adjustment under the
AMI and CABG models to account for
and possibly incentivize the provision
of CR and ICR services beyond what has
historically been provided during AMI
and CABG episodes. In addition, we
believe that waiving certain CR/ICR
program requirements may also increase
the use of these beneficial services
under the AMI and CABG models.
We reviewed the following physician
functions required under § 410.49 in
furnishing CR/ICR services:
• Medical director—defined at
§ 410.49(a) as a physician that oversees
or supervises the cardiac rehabilitation
or intensive rehabilitation program at a
particular site.
• Supervising physician—defined at
§ 410.49(a) as a physician that is
immediately available and accessible for
medical consultations and medical
emergencies at all times items and
services are being furnished to
individuals under cardiac rehabilitation
and intensive cardiac rehabilitation
programs.
• Physician-prescribed exercise—
defined at § 410.49(a) as aerobic exercise
combined with other types of exercise
(that is, strengthening, stretching) as
determined to be appropriate for
individual patients by a physician.
• Individualized treatment plan—
defined at § 410.49(a) as a written plan
tailored to each individual patient that,
under § 410.49(b)(2)(v), must be
established, reviewed, and signed by a
physician every 30 days.
Under § 410.49(a), and § 1861(r)(1) of
the Act, a physician is defined as a
doctor of medicine or osteopathy.
Section 410.49(b)(3) states that Medicare
Part B pays for CR/ICR in a physician’s
office or in a hospital outpatient setting.
All settings must have a physician
immediately available and accessible for
medical consultations and emergencies
at all times when items and services are
being furnished under the program. This
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provision is satisfied if the physician
meets the requirements for direct
supervision for physician office
services, at § 410.26 of this subpart; and
for hospital outpatient services at
§ 410.27 of this subpart.
To provide greater program flexibility
that might increase the availability of
CR and ICR services furnished to EPM
beneficiaries in AMI and CABG
episodes, we proposed to provide a
waiver to the definition of a physician
to include a nonphysician practitioner
(defined for the purposes of this waiver
as a physician assistant, nurse
practitioner, or clinical nurse specialist
as authorized under sections
1861(s)(2)(K)(i) and (ii) of the Act and
defined in section 1861(aa)(5) of the
Act, or in §§ 410.74, 410.75, and 410.76
of the regulations). Thus, this waiver
will allow, in addition to a physician, a
nonphysician practitioner to perform
the functions of supervisory physician,
prescribing exercise, and establishing,
reviewing, and signing an
individualized treatment plan for a
provider or supplier of CR and ICR
services furnished to an EPM
beneficiary during an AMI or CABG
episode. We do not believe a
nonphysician practitioner is qualified to
act in the capacity of a medical director.
Thus, we proposed to specifically
exclude the medical director function
from this waiver. In addition, we
proposed that all other definitions and
requirements related to a physician or
supervising physician under § 410.49
continue to apply. We proposed to
codify this waiver at § 512.630.
For an EPM beneficiary in an AMI or
CABG episode, we proposed that this
waiver will apply to any provider or
supplier that furnishes CR and ICR
services to that beneficiary. We
anticipate monitoring outcomes of care
for EPM beneficiaries that receive CR
and ICR services under this waiver
during an AMI or CABG episode. The
monitoring may involve an analysis of
all or a sample of claims, medical
records, or other clinical data for AMI
and CABG model beneficiaries and
providers or suppliers of CR and ICR
services. We solicited comments on
approaches we may take to monitor this
waiver to ensure this program flexibility
does not have a negative effect on how
beneficiaries receive CR and ICR
services which then may affect the
outcome of the EPM beneficiary’s care.
We also reviewed other program
requirements, such as waiving
beneficiary cost-sharing, allowing home
nursing visits/home monitoring, and
allowing telehealth visits in the home
under the AMI and CABG models. We
did not find clinical data and literature
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that we believed sufficient to support
propose any additional waivers to the
CR/ICR program requirements in this
final rule. We solicited comments on the
proposed CR/ICR waiver to allow
nonphysician practitioners to perform
the aforementioned physician functions
specified for the provision of CR/ICR
services, as well as comments on
possible other CR/ICR program
requirement waivers.
The following is a summary of the
comments received and our responses.
Comment: Many commenters
expressed appreciation and support for
the proposed waiver, though a number
of commenters stated that implementing
this kind of regulatory flexibility for
only a subset of CR/ICR patients that are
AMI and CABG beneficiaries in the CR/
ICR program would have limited impact
on increasing the availability of CR/ICR
services. The commenters observed that
providers and suppliers of CR/ICR
services still would have to comply with
physician supervision requirements for
patients other than AMI and CABG
beneficiaries. As a result, the added
flexibility will not occur in practice,
limiting its intended effect. Thus, the
commenters recommend
implementation of a site-specific rather
than a condition-specific physician
supervision waiver which should be
extended to all Medicare beneficiaries
receiving CR/ICR services at designated
institutions.
Some commenters recommended that
CMS consider applying this waiver to
all CR and ICR programs, including
those in the control groups, as it would
benefit the entire Medicare patient
population. Some of these commenters
asserted that the effects of the waiver
and the incentive payment will be
confounded in the EPMs and CR
incentive payment model as proposed,
while extending the waiver to all CR/
ICR programs would allow CMS to
isolate the impact of the EPMs and CR
incentive payment on model
participants.
Response: We appreciate the
commenters’ interest in ensuring the
availability of CR/ICR services for AMI
and CABG model beneficiaries,
including those beneficiaries who
would also be in the CR incentive
payment model. We proposed a waiver
that would allow, in addition to a
physician, a nonphysician practitioner
to perform the functions of supervisory
physician, prescribing exercise, and
establishing, reviewing, and signing an
individualized treatment plan for a
provider or supplier of CR and ICR
services furnished to an AMI or CABG
beneficiary during an AMI or CABG
episode. We appreciate that as proposed
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507
for AMI and CABG beneficiaries alone,
the physician functions of prescribing
exercise and establishing, reviewing,
and signing an individualized treatment
plan for a provider or supplier of CR
and ICR services are individual
beneficiary-specific actions. In other
words, a nonphysician practitioner can
prescribe the exercise and sign an
individualized CR/ICR treatment plan
for an AMI or CABG beneficiary as part
of that beneficiary’s care, with no
relationship to the other Medicare
beneficiaries not in the AMI or CABG
model but receiving CR/ICR services for
whom these two individual activities
would continue to be required to be
performed by a physician. Therefore,
the waiver to allow a nonphysician
practitioner to perform these two
physician functions should be useful for
AMI and CABG beneficiaries to
facilitate timely referral and initiation of
CR/ICR services.
We acknowledge that the third
physician function that we proposed to
waive, specifically that of physician
supervision for CR/ICR services, to
allow a nonphysician practitioner to
supervise CR/ICR services for AMI and
CABG beneficiaries is a different
circumstance. Our understanding is that
most CR/ICR programs operate during
hours where multiple patients receive
treatment in the CR/ICR program during
the same period of time, all supervised
by one physician while the
beneficiaries’ care is being furnished by
clinical staff of the program. Therefore,
it may be challenging for providers and
suppliers of CR/ICR services to actually
make meaningful use of the waiver of
the physician supervision requirement
for CR/ICR services furnished to AMI
and CABG beneficiaries during
operating hours of a CR/ICR program
where other patients are also being seen
who still require physician supervision.
As the commenters pointed out, we
also appreciate that providing a sitespecific waiver of physician supervision
for CR/ICR services to allow a
nonphysician practitioner to supervise
these services in a CR/ICR program at
that site could provide more meaningful
flexibilities that could expand the
availability of CR/ICR services for AMI
and CABG beneficiaries, consistent with
our rationale for proposing this waiver.
However, while some commenters
arguing in favor of CR/ICR site-specific
waivers of the physician supervision
function, rather than the proposed
limitation of the waiver only to AMI and
CABG beneficiaries, recommended that
we provide the waiver for CR/ICR
services at specific institutions, AMI
and CABG beneficiaries have complete
freedom of choice to obtain care from
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any provider or supplier throughout
AMI and CABG episodes, as discussed
in section III.G.2. of this final rule.
Therefore, we are not confident that we
could identify specific institutions for a
site-specific CR/ICR physician
supervision waiver and still preserve
AMI and CABG beneficiary freedom of
choice of providers and suppliers, if
certain institutions were afforded the
opportunity under the AMI and CABG
models to furnish CR/ICR services with
more flexibility to AMI and CABG
beneficiaries and others were not.
The other possibility we considered
in response to commenters’ concerns
was providing the waiver of physician
supervision to any CR/ICR site where an
AMI or CABG beneficiary was being
treated, an approach that would provide
the same flexibilities regarding CR/ICR
services to any CR/ICR provider or
supplier chosen by the AMI or CABG
beneficiary, thereby not interfering with
beneficiary freedom of choice. However,
this latter scenario would greatly
expand the CR/ICR physician
supervision waiver by potentially
applying it to the CR/ICR services
furnished to a large number of Medicare
beneficiaries who are not in the AMI or
CABG model just because they are being
treated in the same CR/ICR program as
even a single AMI or CABG beneficiary.
While some commenters urged us to
apply the proposed CR/ICR physician
supervision waiver to all CR/ICR
programs, including those in the AMI
and CABG model control groups, based
on their rationale that it would benefit
the entire Medicare patient population,
we may only provide waivers that are
necessary to test the AMI and CABG
models with regard to the cost and
quality of care for AMI and CABG
beneficiaries, not those that we believe
would benefit all Medicare
beneficiaries. Therefore, we do not
believe such an expansion is necessary
to test the AMI and CABG models.
We continue to believe that the
proposed waiver that would allow, in
addition to a physician, a nonphysician
practitioner to perform the functions of
supervisory physician, prescribing
exercise, and establishing, reviewing,
and signing an individualized treatment
plan for a provider or supplier of CR
and ICR services furnished to an AMI or
CABG beneficiary during an AMI or
CABG episode is a waiver that is
necessary to test the AMI and CABG
models. At this time, we will not modify
the proposed waiver to expand the
waiver of the CR/ICR physician
supervision requirement to any
beneficiaries that are not in AMI or
CABG episodes. We will continue to
seek input from AMI and CABG model
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participants, including those who are
also EPM–CR participants, throughout
implementation of the models and may
consider making future proposals if we
observe that limited availability of CR/
ICR services is affecting beneficiaries’
access to CR/ICR services under the
models.
Comment: Some commenters
expressed their support for a current
legislative bill that would expand access
to cardiac rehabilitation by allowing
physicians assistants, nurse
practitioners and clinical nurse
specialists to supervise cardiac,
intensive cardiac and pulmonary
rehabilitation programs. The
commenters requested that CMS
provide Congress with data from the
AMI and CABG models that support the
value of cardiac rehabilitation.
Response: Upon receiving a specific
request from Congress, the Secretary
will provide the necessary technical
assistance.
Comment: Some commenters sought
clarification whether the proposed
waiver would allow nonphysician
practitioners to independently refer,
that is, sign the order for CR/ICR
services, per state scope of practice
laws, therefore directly addressing the
delay between hospital discharge,
referral, and enrollment into CR/ICR
services.
Response: The waiver of physician
definition for prescribing exercise
would allow nonphysician practitioners
to independently sign the order for CR/
ICR services, subject to state scope of
practice laws.
Comment: A few commenters
recommended that CMS extend the
waiver to allow qualified nonphysician
practitioners to perform the functions of
a Medical Director for a provider or
supplier of CR or ICR services.
Response: We do not believe that
extending the waiver to cover the
functions of the Medical Director is
medically appropriate for testing the
AMI and CABG models.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal, without
modification, to provide a waiver to the
definition of a physician to include a
nonphysician practitioner (defined for
the purposes of this waiver as a
physician assistant, nurse practitioner,
or clinical nurse specialist as authorized
under sections 1861(s)(2)(K)(i) and (ii)
of the Act and defined in section
1861(aa)(5) of the Act, or in §§ 410.74,
410.75, and 410.76 of the regulations).
Thus, this waiver will allow, in addition
to a physician, a nonphysician
practitioner to perform the functions of
supervisory physician, prescribing
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exercise, and establishing, reviewing,
and signing an individualized treatment
plan for a provider or supplier of CR
and ICR services furnished to an EPM
beneficiary during an AMI or CABG
episode. The waiver of physician
definition for furnishing cardiac
rehabilitation and intensive cardiac
rehabilitation services to an EPM
beneficiary is set forth at § 512.630.
K. Data Sharing
1. Overview
In section III.D.2. (81 FR 50843
through 50845) of the proposed rule, we
proposed models similar to the CJR
model, to financially incentivize EPM
participants to engage in care redesign
efforts to improve quality of care and
reduce spending for the aggregate Part A
and B FFS spending for beneficiaries
included in the models during the
inpatient hospitalization and 90 days
post-discharge. Consistent with the CJR
model, we proposed retrospective
bundled payment models that would
provide financial incentives for EPM
participants to work with other health
care providers and suppliers to improve
the quality and efficiency of care for
Medicare beneficiaries by paying EPM
participants or holding them
responsible for repaying Medicare based
on EPM participants’ performance with
respect to the quality and spending for
AMI, CABG, and SHFFT episodes.
In addition to the CJR model, we have
experience with a range of efforts
designed to improve care coordination
for Medicare beneficiaries through
financial incentives similar to those
proposed, including the Shared Savings
Program, the Pioneer ACO model and
the BPCI initiative, all of which make
certain data available to participants to
better enable them to achieve their
goals. For example, participants in the
Shared Savings Program initially receive
aggregate information on their historical
financial performance as well as
quarterly data throughout their tenure in
the program. In addition, Shared
Savings ACOs receive certain
beneficiary-identifiable claims
information in accordance with our
regulations. As noted in the June 9, 2015
Medicare Shared Savings Program final
rule (80 FR 32733), ACOs participating
in the Shared Savings Program have
reported that the beneficiary-identifiable
claims data that they receive from CMS
are being used effectively to better
understand the FFS beneficiaries that
are receiving services from their
providers. As stated in that rule, these
data give ACOs valuable insight into
patterns of care for their beneficiary
population and enable them to improve
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care coordination among and across
providers and suppliers and sites of
care. Similarly, participants in the
Pioneer ACO model were given the
ability to request historical claims data
of beneficiaries aligned with the
particular Pioneer ACO entity. (For
more information see the CMS Web site
https://innovation.cms.gov/Files/factsheet/Pioneer-ACO-Model-BeneficiariesRights-Fact-Sheet.pdf).
In addition, we provide BPCI
participants with the opportunity to
request beneficiary claims data
regarding their own patients, both for
the historical period used to set baseline
prices for entities participating in BPCI
as well as ongoing monthly claims feeds
containing Medicare FFS claims for
beneficiaries that could have initiated
an episode of care for that particular
BPCI participant. These monthly claims
feeds provide BPCI participants with
data for both acute and post-acute care
spending for beneficiaries that could
have initiated an episode of care at that
BPCI participant.
Based on our experience with these
efforts, we believe that making certain
data available to EPM participants can
have a salutary effect on their
performance and is necessary for them
to, among other things, adequately
structure their care pathways,
coordinate care for beneficiaries, make
practice changes supported under the
models, identify services furnished to
beneficiaries receiving services under
the models, and estimate spending
across provider types within EPM
episodes. Further, we believe that
providing EPM participants with certain
claims and summary information on
beneficiaries in accordance with
applicable privacy and security laws
and established privacy and security
protections would improve their ability
to monitor their performance and
understand the totality of care provided
during an episode of care. With this
greater awareness and understanding,
we anticipate that EPM participants
would be better equipped to evaluate
and modify their practice patterns and
actively manage care delivery so that
care for beneficiaries is better
coordinated, quality and efficiency are
improved, and payments are aligned
more appropriately to the medically
necessary services beneficiaries have a
right to receive.
Accordingly, in the proposed rule, we
proposed to provide EPM participants
in the proposed AMI, CABG, and
SHFFT models with beneficiary-level
claims data for the historical period
used to calculate their episode
benchmark and quality-adjusted target
prices as well as with ongoing quarterly
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beneficiary-identifiable claims data in
response to their request for such data
in accordance with our regulations (81
FR 50944 through 50946). Given that we
also proposed to incorporate regional
pricing in the calculation of benchmark
and quality-adjusted target prices, we
also proposed to provide EPM
participants with aggregate regional data
(81 FR 50945). Our proposal to make
these data available to EPM participants
was included in § 512.350. We note that,
consistent with CJR, the EPM
participant with which we would share
data is the acute care hospital that is
held accountable for spending during
the episode of care. We believe our
proposal to share data as we do under
the CJR model would be the most
effective approach under the proposed
AMI, CABG, and SHFFT models, and
that proposing different processes for
these models would increase
administrative complexity for CMS and
model participants as well as create
confusion, especially given that we
proposed in section III.B.1. of the
proposed rule (81 FR 50813) that some
of the hospitals participating in CJR
would also participate in the proposed
EPMs. We requested comments on these
proposals, particularly regarding
possible ways, if any, to further align
our proposed policies with those
finalized under the CJR model, as well
as any appropriate bases for treating
these models differently.
The following is a summary of the
comments received and our responses.
Comment: Some commenters
requested that CMS explicitly encourage
the use of health IT to allow clinicians
to communicate across settings of care.
A commenter further suggested that
CMS encourage post-acute care
adoption of health information
technology through incentives. The
commenter stated that to date, there has
not been a focus on post-acute care
health information technology adoption
or any standardization of data sharing
platforms for clinical, financial or
patient experience data between acute
and post-acute care providers.
Response: While we do not explicitly
require the use of health information
exchange mechanisms in this final rule
for all proposed EPM tracks, we do
encourage EPM participants to
collaborate with their post-acute care
providers in their care redesign and to
the extent that health information
technology (health IT) is useful to that
end we would encourage its use.
Providing incentives for such use is
beyond the scope of this final rule but
in the evaluation of the EPMs we will
certainly look to see the impact that
health IT has on care coordination to the
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509
extent that participants use health IT to
communicate with their preferred postacute care providers.
2. Beneficiary Claims Data
As we stated in the proposed rule,
based on our experience with BPCI and
CJR participants, we recognize that EPM
participants could vary with respect to
the kinds of beneficiary claims
information that would be most helpful.
For example, we believe that while
many EPM participants might have the
ability to analyze raw claims data, other
EPM participants could find it more
useful to have a summary of these data.
Given this, we proposed to make
beneficiary claims information for AMI,
CABG, and SHFFT episodes available
through two formats both for the
baseline period and on an ongoing basis
during their participation in the model
as we do for CJR (81 FR 50944–50945).
First, for EPM participants that lack
the capacity to analyze raw claims data,
we proposed to provide summary
beneficiary claims data reports on
beneficiaries’ use of health care services
during the baseline and performance
periods upon request and in accordance
with applicable privacy and security
laws and established privacy and
security protections. Such summary
reports would provide tools to monitor,
understand, and manage utilization and
expenditure patterns as well as to
develop, target, and implement quality
improvement programs and initiatives.
For example, if the data provided by
CMS to a particular EPM participant
reflected that, relative to their peers, a
certain provider was associated with
significantly higher rates of inpatient
readmissions than the rates experienced
by other beneficiaries with similar care
needs, that may be evidence that the
EPM participant could consider, among
other things, the appropriateness of that
provider, whether other alternatives
might be more appropriate, and whether
there exist certain care interventions
that could be incorporated postdischarge to lower readmission rates.
Such reports would allow EPM
participants to assess summary data on
their relevant beneficiary population
without requiring a more complicated
analysis of raw claims data.
Therefore, for both the baseline period
and on a quarterly basis during an EPM
participant’s performance period, we
proposed to provide EPM participants
with an opportunity to request summary
claims data that would encompass the
total expenditures and claims for
episodes under the proposed AMI,
CABG, and SHFFT models in which
they are participating, including the
procedure, inpatient stay, and all related
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care covered under Medicare Parts A
and B within the 90 days after
discharge, including hospital care, postacute care, and physician services for
the EPM participant’s beneficiaries with
an anchor diagnosis at discharge that is
included under one of the proposed
AMI, CABG, or SHFFT models.
We also proposed that these summary
claims data reports, at a minimum,
would also contain payment
information, based upon the following
categories for each episode initiated
under the models:
• Inpatient.
• Outpatient.
• Skilled Nursing Facility.
• Home Health.
• Hospice.
• Carrier/Part-B.
• Durable Medical Equipment.
These files would provide summary
spending data such as episode counts,
total average spending for each episode,
and a breakdown of the episode counts
and spending averages by each of the
most common categories listed
previously (for example, Inpatient,
Outpatient, etc.). These reports should
allow participants to assess summary
data on their relevant beneficiary
population without requiring analysis of
raw claims data.
Alternatively, for EPM participants
with the capacity to analyze raw claims
data, we proposed to make more
detailed beneficiary-level information
available upon request and in
accordance with applicable privacy and
security laws and established privacy
and security protections. These files
would be much more detailed and
include all beneficiary-level raw claims
for all of the categories listed for each
episode payment model episode. In
addition, they would include episode
summaries, indicators for excluded
episodes, diagnosis and procedure
codes, and enrollment and dual
eligibility information for beneficiaries
that initiate AMI, CABG, and SHFFT
episodes. Through analysis, these
detailed claims data would provide
EPM participants with information to
improve their ability to coordinate and
target care strategies, as well as
information to monitor, understand, and
manage utilization and expenditure
patterns. Such data would also aid them
in developing, targeting, and
implementing quality improvement
programs and initiatives. We proposed
that the data files would be packaged
and sent to a data portal (to which the
EPM participants must request and be
granted access) in a ‘‘flat’’ or binary
format for the EPM participant to
retrieve. We would also note that, for
both the summary and more detailed
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claims data, information that is subject
to the regulations governing the
confidentiality of alcohol and drug
abuse patient records (42 CFR part 2)
would be excluded from the data shared
with an EPM participant. Our proposal
to make available to EPM participants,
through the most appropriate means,
data that CMS determines may be useful
to EPM participants to determine
appropriate ways to increase the
coordination of care, improve quality,
enhance efficiencies in the delivery
system, and otherwise achieve the goals
of the proposed episode payment
models was included in § 512.350.
Further, CMS would make beneficiaryidentifiable data available to an EPM
participant in accordance with
applicable privacy and security laws
and only in response to the EPM
participant’s request for such data for a
beneficiary who has been furnished a
billable service by the participant
corresponding to the episode definitions
for AMI, CABG, and SHFFT episodes.
We requested comments on this
proposal.
The following is a summary of the
comments received and our responses.
Comment: Commenters
overwhelmingly supported our proposal
to make data, in the form of raw claims
and summary format, available upon
request. Multiple commenters stated
that meaningful and accurate data is a
necessity for success under the CJR
model and will be critical to success
under the proposed EPMs. However,
some commenters had suggestions on
how to improve the data that we
proposed to provide based on their
experiences with other CMS models
such as CJR and BPCI. These
commenters stated that they have heard
from multiple BPCI and CJR participants
that there is a need for more
sophisticated data in order to better
understand performance and
opportunities for improvement. They
also stated that the data shared to date
in CJR is resource-intensive to interpret
and is not always actionable and that
improved claims data quality would
help EPM participants. Another
commenter agreed that CMS should
improve the quality of reports it
provides hospitals. They noted that
many hospitals do not have the
capability to manipulate claims level
data in house nor can they afford to
purchase that capability. The
commenters stated that CMS has clearly
indicated it is moving toward
longitudinal payment models and that
CMS contractors therefore need to
develop standardized reporting
capabilities (and reports) that will fully
support providers.
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Response: Based on our experience on
other CMS models like BPCI and CJR
and feedback we have received through
learning events, affinity groups, and
collaboration site discussion boards, we
generally believe we have proposed to
make available the relevant data needed
to succeed in the EPMs. However, we
will take these comments into
consideration when creating the data
feeds for the new models. We will also
work with our contractors to
standardize, refine, and improve the
data we disseminate to better inform
providers.
Comment: Multiple commenters
stressed the importance of data
reliability and accuracy. A few
commenters currently participating in
CJR stated that the data files they
receive are unwieldy to work with,
contain errors, and are not delivered in
a timely manner, further delaying
analysis and results calculation.
Another commenter stated that some of
the files were difficult for some smaller
hospitals to analyze and that the
hospitals that could analyze the data
found the data to be incomplete in many
cases and inconsistent with the
hospital’s own data. A commenter
further suggested that for the EPMs,
CMS should institute and enforce
service level agreements (SLA) with its
contractors that dictate acceptable time
frames in which to provide EPM
participants with accurate, complete
data files. In addition, they suggested
that CMS needs to create an EPM
ombudsman who will serve as the
conduit for complaints from providers
regarding data and that the ombudsman
should be responsible for determining
whether the contractor is in violation of
the SLA and subject to penalty.
Response: We appreciate the need for
accurate, complete, and timely data and
intend, to the extent feasible and
appropriate, to build quality assurance
tasks into the statement(s) of work for
the payment contractor(s) we engage to
perform the payment analysis, reporting
and data file preparation. We will also
work to enhance the underlying IT
structure and systems to assist in
resolving file load and transfer times.
We will work with our contractors to
ensure they are delivering accurate and
complete data in a timely manner
according to the terms of their contracts
and to ensure that they have quality
assurance protocols in place to run on
the data in advance of the file releases.
Likewise, consistent with the terms of
their contracts, we will take appropriate
corrective actions with contractors
where performance falls short of
expectations. While the models have not
yet been implemented, we have no
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reason to expect that contractor
performance should fall short of
expectations and thus do not anticipate
a need for a special ombudsman to
address data complaints and assess
penalties. We will establish an open
communication system with EPM
participants so that they can
immediately bring any issues
surrounding file or data quality to our
attention so that we can investigate and
resolve problems quickly should they
arise.
Comment: Another commenter
encouraged CMS to use master data
management technology to ensure
correct patient-provider alignment
across programs to ensure quality,
timeliness, and proper assigning of data.
Response: We appreciate this
comment and will explore options for
incorporating this technology with our
contractors.
Comment: A commenter requested
that CMS consider adding hierarchical
condition category (HCC) risk scores to
the data files, citing that they may help
EPM participants identify outliers and
patients requiring more intense services.
Response: At this time, we do not
plan to add HCC risk scores to the data
files we will provide because we do not
believe they are necessary data elements
for EPM participants to conduct day-today operations in the EPMs given the
current structure of the EPM models and
payment calculations. Therefore, those
data elements would not meet the
HIPAA Privacy Rule’s ‘‘minimum
necessary’’ standard, which applies to
‘‘health care operations’’ disclosures.
Comment: A commenter, who stated
that they are a current CJR participant,
noted the difficulties in mining the data
they received to exclude BPCI episodes
and other cancelled episodes. They
added that participants need to ensure
they are identifying every patient whose
care is included in the bundle and to
confirm those patients were moved into
cost-effective care coordination
pathways.
Response: We appreciate this
comment and we plan to explore adding
indicators to the beneficiary-identifiable
claims data supplied to EPM
participants that will provide
information about circumstances that
could result in EPM episode
cancellation, such as admission of a
beneficiary to a hospital that initiates
episodes under BPCI for care that could
potentially cancel an EPM episode. To
the extent that adding such indicators to
the claims data is feasible, providing
this information through the claims data
to EPM participants would ensure that
EPM participants are informed as
frequently as quarterly about
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circumstances that could result in EPM
episode cancellation. We also note that
at reconciliation, complete information
would be provided to EPM participants
about those episodes that were
ultimately included in the participant’s
reconciliation report as discussed in
section III.D.5. of this final rule.
Additional discussion on this can be
found in sections III.C.4. (EPM
Episodes) and III.D.6. (Adjustments for
Overlaps) of this final rule.
Comment: We received some
comments expressing concerns with the
logistics of receiving EPM data from
some participants with past experience
in CJR. A few of these commenters
recommended that CMS ensure
appropriate processes are in place for
the proposed EPMs to ensure that
providers will actually be able to access
data when needed. Another commenter
also provided some specific examples of
improvements that could be made to the
data delivery process to improve
efficiency for users that may work with
multiple EPM hospitals and models.
Some examples include a mechanism to
download multiple sets of files
simultaneously, delivering the data
through a secure FTP site, and
providing accurate file layouts before
data is released. In addition, they
requested specific points of contact for
hospital systems participating in EPM
for issues related to data dissemination.
Response: We appreciate these
comments and will take them into
consideration when developing the data
dissemination process and creating the
data portal for the EPMs. We will
provide EPM participants with specific
points of contact for data issues at the
time they register for their portal
account access.
Comment: Some commenters also
expressed that they are sensitive to the
increasing volume of requests that CMS
is likely experiencing in parallel with
expanding care and payment redesign
models, and they encouraged CMS to
carefully consider how potential
backlogs and delays in data availability
may impact the target implementation
date.
Response: We appreciate this
comment and understand this concern.
We realize that timely access to data
prior to model implementation is
important to model participants and
will work with our contractors and
other CMS components to disseminate
data as soon as feasible once the final
rule is published.
Comment: A commenter cited CMS’
interpretation of Section 105(b) of
MACRA (Pub. L. 114–10—see 81 FR
44471 for CMS interpretation) and
requested that CMS provide qualified
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511
clinical data registries (QCDRs) with
access to Medicare data for purposes of
linking such data with clinical
outcomes data and performing
scientifically valid analysis or research
to support quality improvement or
patient safety. In addition, they
encouraged CMS to indicate ‘‘fact of
death’’ by matching Medicare claims
data with Social Security Death
Masterfile (SSDMF) death data (or
another source of vital statistics) before
providing it to QCDRs.
Response: We believe these comments
are outside the scope of this final rule,
but we would encourage QCDRs to
contact ResDAC for more information
on requesting the files they desire at:
https://www.resdac.org/cms-data/
request/cms-data-request-center.
Comment: A few commenters also
remarked on CMS’ proposal to exclude
individually identifiable data related to
substance abuse from claims files as it
currently does in other programs.
Commenters noted that this information
is key for hospitals to understand the
full risk associated with patients and
identify appropriate care management.
Some comments suggested that CMS
should provide cost and claim data for
these services since hospitals will be
forced to bear risk for these patients. A
few commenters also requested that
CMS provide the de-identified cost and
claims data for these services and stated
that if this is not possible CMS should,
at a minimum, provide the aggregate
payment amount for these services.
Another commenter encouraged the
Innovation Center to use its waiver
authority to make beneficiary-specific
claims-level substance abuse
information available to hospitals. In
addition, they recommended that CMS
work with the Congress to create an
exception to 42 CFR part 2 to provide
beneficiary-specific claims level
substance abuse information.
Response: Section 1115A of the Act
does not authorize the waiver of the
requirements under 42 CFR part 2.
Moreover, our proposal to exclude this
information is consistent with our
treatment of these data in other similar
CMS programs and models where
providers must take on risk in managing
the care of their beneficiaries, such as
the Shared Savings Program and the
BPCI initiative. We would note that,
based on our experience to date, we are
unaware of this policy being a
significant impediment to the
operations of these efforts. We also
appreciate the suggestions to make these
data available in a de-identified manner.
We have considered this option and are
not currently aware of a means to make
de-identified beneficiary-specific data
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available in a way that would provide
useful information to participating
hospitals without potentially making it
possible to identify beneficiaries.
Similarly, we have also not identified a
way in which to make meaningful
aggregate data available on a limited
basis without potentially compromising
beneficiary confidentiality. However,
we will continue to consider these
comments and the feasibility of making
such data available in a way that is both
meaningful to participating hospitals
and in compliance with 42 CFR part 2.
Final Decision: After consideration of
the public comments received, we are
finalizing our proposals at § 512.350 (a)
to make available to EPM participants,
through the most appropriate means and
in the manner described previously,
summary and beneficiary-level claims
data that CMS determines may be useful
to EPM participants for purposes of the
EPMs. We are also finalizing our
proposal to exclude information that is
subject to the regulations governing the
confidentiality of alcohol and drug
abuse patient records (42 CFR part 2)
from any summary or beneficiary-level
claims data shared with an EPM
participant. CMS will make beneficiaryidentifiable data available to an EPM
participant in accordance with
applicable privacy and security laws
and established privacy and security
protections and only in response to the
EPM participant’s request for such data
for a beneficiary who has been
furnished a billable service by the
participant corresponding to the episode
definitions for AMI, CABG, and SHFFT
episodes.
3. Aggregate Regional Data
As discussed in section III.D.4.b.(6)
(81 FR 50855 and 50856) of the
proposed rule, we proposed to
incorporate regional pricing data when
establishing target prices for EPM
participants as we do in the CJR model
pricing methodology. As indicated in
the CJR final rule (80 FR 73510), we
finalized our proposal to share regional
pricing data with CJR participants
because it was a factor affecting target
prices. Given the similarities between
the CJR model and the proposed EPMs,
particularly our proposal to incorporate
regional pricing data when establishing
target prices under the model, we
proposed to provide aggregate
expenditure data available for all claims
associated with AMI, CABG, and SHFFT
episodes for the U.S. Census Division in
which the EPM participant is located, as
we similarly provide to hospitals
participating in the CJR model.
Specifically, we proposed to provide
EPM participants with aggregate data on
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the total expenditures during an acute
inpatient stay and 90-day post-discharge
period for all Medicare FFS
beneficiaries who would have initiated
an episode under our proposed episode
definitions in section III.C. of the
proposed rule (81 FR 50829). This data
would be provided at the regional level;
that is, we proposed that an EPM
participant would receive, if requested
from CMS, aggregate regional data for
potential episode payment model AMI,
CABG, and/or SHFFT episodes initiated
in the U.S. Census Division where the
EPM participant is located.
These regional data would be in a
format similar to the proposed summary
claims data reports and would provide
summary information on the average
episode spending for AMI, CABG, and
SHFFT episodes in the U.S. Census
Division in which the EPM participant
is located. We sought comments on our
proposal to provide these data to EPM
participants.
The following is a summary of the
comments received and our responses.
Coment: We received comments
supporting our proposal to provide the
opportunity to request aggregate
regional data that includes information
about average episode spending.
However, commenters also included
several suggestions for how this data
could be improved. A commenter stated
that they believe this data can be made
more actionable by including key
utilization metrics such as—
• Percent of episodes with at least
one readmission
• Percent of episodes that include
skilled nursing facility (SNF) care
• Percent of episodes that include
home health care
• Percent of episodes that include an
inpatient rehabilitation (IP rehab) stay
• Index hospitalization average length
of stay (ALOS)
• SNF ALOS for episodes that
include SNF
• IP rehab ALOS for episodes that
include IP rehab
They stated that these metrics would
serve as benchmarks for EPM
participants, and help identify
opportunities for improvement and
inform care intervention strategies.
Response: We appreciate the
comments supporting our proposal to
provide the opportunity to request
aggregate regional data. In addition, we
will continually work to improve the
data we provide to EPM participants
and we will explore the feasibility of
including the additional utilization
metrics suggested by the commenter in
the aggregate regional data files.
Final Decision: After consideration of
the public comments received, we are
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finalizing our proposal to provide EPM
participants with aggregate data on the
total expenditures during an acute
inpatient stay and 90-day post-discharge
period for all Medicare FFS
beneficiaries for potential episode
payment model AMI, CABG, and/or
SHFFT episodes initiated in the U.S.
Census Division where the EPM
participant is located.
4. Timing and Period of Baseline Data
We recognize that providing the
ability to request certain baseline data
will be important for EPM participants
to be able to estimate episode spending,
coordinate care, and identify areas for
practice transformation, and that early
release of this data can facilitate their
efforts to do so. Also, as discussed in
section III.D.4.b.(3) of the proposed rule
(81 FR 50854), episode benchmark
prices would be calculated using an
EPM participant’s historical episode
spending during their baseline period.
Further, we believe that EPM
participants will view the episode
payment model effort as one involving
continuous improvement. As a result,
changes initially contemplated by an
EPM participant could be subsequently
revised based on updated information
and experiences.
Therefore, as with CJR and BPCI, we
proposed to make 3 years of baseline
data available to EPM participants and
intend to make these data available
upon request prior to the start of the
first episode payment model
performance year and in accordance
with applicable privacy and security
laws and established privacy and
security protections. We believed that 3
years of baseline data is sufficient to
reflect both an EPM participant’s most
recent performance and recent
performance trends. Moreover, making
data available for a 3-year period aligns
with our proposal to set a target price
based on a 3-year period of baseline data
in section III.D. of this final rule. As we
stated in the proposed rule, we believe
that if an EPM participant has access to
baseline data for the 3-year period used
to set its episode benchmark and
quality-adjusted target prices, then it
would be better able to assess its
practice patterns, identify cost drivers,
and ultimately redesign its care
practices to improve efficiency and
quality.
Therefore, we proposed that the 3year period utilized for the baseline
period match the baseline data used to
create EPM participants episode
benchmark and quality-adjusted target
prices, as discussed in section III.D. of
this final rule. Specifically, we proposed
that the baseline beneficiary-level and
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summary data (both EPM participantlevel and regional summary data) would
be available for episodes that began
January 1, 2013 through December 31,
2015. We requested comments on these
proposals.
The following is a summary of the
comments received and our responses.
Comment: We received many
comments about the importance of
providing timely data prior to the start
of the model. Many commenters
requested that CMS make historical and
program design data available to EPM
participants as soon as CMS is able to
do so after the publication of the final
rule. The commenters stated that they
would need the data as early as possible
in order to allow for enough time to
review the data, to understand the needs
and utilization patterns of the
population, and to tailor interventions
based on findings. They also stated that
the data would help identify the
facilities and provider types most
frequently used by patients after
discharge. In addition, commenters
pointed out that early data would be
essential for EPM participants to
understand how their episodes compare
to others in the region and where they
stand at the start of the EPMs. A
commenter recommended that CMS
provide historical claims data a
minimum of 6 months prior to the
commencement of the models so as to
allow providers the opportunity to
analyze the data for care coordination
opportunities, evaluate post-acute care
providers for partnership opportunities,
and negotiate risk-sharing arrangements.
Another commenter further requested
all the historical data used to set the
target prices be provided to EPM
participants by December 31, 2016 for a
July 1, 2017 start date and that we also
provide guidance and technical support
to assist participants once this data is
shared.
Response: We appreciate comments
and understand the usefulness of these
data to EPM participants’ ability to
understand and adjust their
performance and partner with
collaborators. We will make every effort
to make this data available for request
as soon as possible after the final rule
is published while complying with
applicable privacy and security laws.
Additionally, we will provide guidance
and technical support during the
process to request, retrieve, and evaluate
the data received.
Comment: A few commenters cited
that data challenges, including the
significant financial investment, time
and complexities involved in
developing and using the necessary
infrastructure, along with substantial
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transaction fees for sharing health
information necessitate a delay in the
start of the EPMs. They went on to state
that EPM participants should be
provided data with at least as much
preparatory time as BPCI participants.
Response: We appreciate these
comments and again acknowledge the
importance of providing timely access
to data. As previously noted, we will
work to make this data available for
request as soon as feasible while
complying with applicable privacy and
security laws. To the extent that it may
be relevant, we note that we have
revised our proposal to begin downside
risk across the board as of April 1, 2018.
As discussed in detail in section
III.D.2.c. of this final rule, we are
finalizing an option to allow the
voluntary selection of downside risk for
performance year 2 and to extend our
proposed date for required downside
risk to performance year 3, which
should provide participants with more
lead time to understand their data prior
to taking on 2 sided risk under the
EPMs.
Final Decision: After consideration of
the public comments received, we are
finalizing our proposal, without
modification to make 3 years of baseline
data available to EPM participants and
intend to make these data available to
participants upon request prior to the
start of the first episode payment model
performance year (July 1, 2017) and in
accordance with applicable privacy and
security laws and established privacy
and security protections. The 3-year
period utilized for the baseline period
matches the baseline data used to create
EPM participants’ episode benchmark
prices. Specifically, the baseline
beneficiary-level and summary data
(both EPM participant-level and
regional summary data) will be available
for episodes that began January 1, 2013
through December 31, 2015.
5. Frequency and Period of Claims Data
Updates for Sharing BeneficiaryIdentifiable Claims Data During the
Performance Period
As we stated in the proposed rule (81
FR 50946), in addition to baseline data,
we believe that the availability of
periodically updated beneficiaryidentifiable claims data (both summary
and beneficiary-level) will assist EPM
participants in the proposed AMI,
CABG, and SHFFT models to identify
areas where they might wish to change
their care practice patterns, as well as
monitor the effects of any such changes.
With respect to these purposes, we have
considered what would be the most
appropriate period and frequency for
making updated claims information
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513
available to EPM participants, while
complying with the HIPAA Privacy
Rule’s ‘‘minimum necessary’’ standard.
As stated in the proposed rule, we
believe that, as is the case with CJR,
making claims data available that would
represent up to 6 quarters of information
upon receipt of a request for such
information that meets the requirements
of the HIPAA Privacy Rule, would be
representative of total spending and
useful to hospitals as they consider
long-term practice changes. We note
that we intend for the data for this
model to be consistent with our
proposed performance year of January 1
through December 31 (July 1 through
December 31 for performance year 1).
To accomplish this for the first year of
the models (2017), we proposed to
provide, upon request and in
accordance with the HIPAA Privacy
Rule, claims data from July 1, 2017 to
June 30, 2018 on as frequently as a
running quarterly basis, as claims were
available (81 FR 50946). For each
quarter and extending through June 30,
2018, we proposed that participants
during that first year would receive data
for up to the current quarter and all of
the previous quarters going back to July
1, 2017. These data sets would contain
all claims for all potential episodes that
were initiated on or after July 1, 2017
and capture a sufficient amount of time
for relevant claims to have been
processed. We noted that we would
limit the content of this data set to the
minimum data necessary for the
participating hospital to conduct quality
assessment and improvement activities
and effectively coordinate care of its
patient population.
Accordingly, we proposed to make
updated claims data available to EPM
participants, representing up to 6
quarters of data, upon receipt of a
request for such information that meets
CMS’ requirements to ensure the
applicable HIPAA conditions for
disclosure have been met. Also,
consistent with our procedures for CJR,
we proposed to make these data
available as frequently as on a quarterly
basis. Given that we have received
requests in other initiatives to make data
available on a more frequent basis, we
also proposed to eventually make these
data available on as frequently as a
monthly basis if practicable. In addition,
we proposed that for an EPM participant
to receive data on episode spending,
they would only need to make a single
initial request rather than multiple
periodic requests for data. CMS would
make data available to the EPM
participant for the duration of their
participation or until they notify CMS
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that they no longer wish to receive these
data.
Our proposal to make the minimum
data necessary for EPM participants to
conduct quality assessment and
improvement activities and effectively
coordinate care of its patient population
as frequently as on a quarterly basis
throughout the EPM participant’s
participation or until they notify CMS
that they no longer wish to receive these
data is included at § 512.350(b)(2). We
sought comments on this proposal.
The following is a summary of the
comments received and our responses.
Comment: Many commenters were
supportive of CMS’ proposal to make
data available as frequently as monthly
if practical, but strongly encouraged the
monthly release of the data to the EPM
participants as soon as the EPMs are
implemented, as opposed to quarterly.
A commenter stated that a quarterly
timeline would significantly delay EPM
participants in identifying inefficiencies
arising with regard to beneficiary
utilization and noted that issues could
occur in the continuum of care delivery
and coordination. Another commenter
indicated that monthly data is essential,
especially at the beginning of the EPMs,
and that the quarterly data has a lag so
the initial file will contain mostly
incomplete episodes. Other commenters
referenced the BPCI initiative which
currently provides monthly data to its
Awardees.
Response: We appreciate these
comments and realize that frequent data
will assist many EPM participants that
are selected for the EPMs. As proposed,
we will work with our contractors to
provide data monthly as opposed to
quarterly as soon as it is feasible for us
to do so.
Comment: We received some
comments on providing reconciliation
data and results more frequently than
annually. Commenters referenced the
quarterly reconciliation timelines in
BPCI and one commenter stated that the
quarterly results would allow providers
to assess their performance and
understand if care interventions are
working, or need to be altered. Another
commenter strongly encouraged CMS to
provide EPM participants with quarterly
updates for completed episodes through
a mechanism similar to other Innovation
Center initiatives.
Response: Based on our experience in
BPCI, quarterly reconciliation can lead
to large variation in NPRA and
uncertainty for providers, in addition to
being a very resource-intensive process
for providers and CMS. While we
understand that quarterly reconciliation
results and data could be helpful for
providers to assess their performance,
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we believe that the beneficiary claims
data we plan to disseminate will allow
providers to do this. Additionally we
note that we will be working with our
contractors to explore the feasibility of
providing a high-level interim report on
reconciliation status during the payment
year which should help EPM
participants assess how they are doing
under the model. Therefore, as stated in
section III.D.5. of this final rule, we plan
to finalize our policy for annual
reconciliation data and results in the
same way we have done this for CJR.
Additional discussion on this topic can
be found in section III.D.5. of this final
rule.
Comment: Commenters requested that
data be made available automatically
without a specific request for the data.
These commenters noted the potential
for additional administrative burden
associated with requesting the data. A
commenter recommended that an EPM
participant should only need to register
to receive data and provide the
appropriate contact.
Response: We want to limit
administrative burden for EPM
participants participating in these
models and wish to clarify that while
we will make data available to EPM
participants only upon request,
participants would be able to make a
single request for these data for each
model prior to the start of the
performance period and the data would
be available to them for the duration of
their participation or until they notify
CMS that they no longer wish to receive
these data. To be consistent with the
HIPAA Privacy Rule’s ‘‘minimum
necessary’’ standard, we will continue
to make data available only in response
to a request.
Comment: Other commenters
appreciated our proposal that EPM
participants only need to make an initial
single request rather than multiple
periodic requests for data as this will
impose less of an administrative burden
on hospitals.
Response: We appreciate these
comments.
Final Decision: After consideration of
the public comments received, we are
finalizing our proposal at § 512.350(b)(1)
to provide up to 6 quarters of claims
data (both summary and beneficiarylevel) to EPM participants upon request
and in accordance with applicable
privacy and security laws. We are also
finalizing our proposal that for an EPM
participant to receive data on episode
spending, they need only make a single
initial request rather than multiple
periodic requests. Additionally, we are
finalizing our proposal to make these
data available on a quarterly basis and
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as frequently as a monthly basis if
practicable. Consistent with our
proposal to make these data available as
frequently as monthly if practicable, we
are updating our proposal at
§ 512.350(b)(2) to provide that updated
claims data will be made available not
‘‘as frequently as on a quarterly basis
throughout the EPM participant’s
participation,’’ but instead ‘‘no less
frequently than on a quarterly basis.’’
6. Legal Permission To Share
Beneficiary-Identifiable Data
As we have stated previously (80 FR
73513), we recognize that there are a
number of issues and sensitivities
surrounding the disclosure of
beneficiary-identifiable health
information, and note that a number of
laws place constraints on sharing
individually identifiable health
information. For example, section 1106
of the Act bars the disclosure of
information collected under the Act
without consent unless a law (statute or
regulation) permits the disclosure. Here,
the HIPAA Privacy Rule allows for the
proposed disclosure of individually
identifiable health information by CMS.
In the proposed rule, we proposed to
make EPM participants financially
responsible for services that may have
occurred outside of the hospital during
the 90-day post-discharge period (81 FR
50946). Although we expect EPM
participants to be actively engaged in
post-discharge planning and other care
during the 90-day post-discharge period
for beneficiaries receiving services
under the proposed AMI, CABG, and
SHFFT models, we believe that it is
necessary for the purposes of these
models to provide EPM participants
with beneficiary-level claims data,
either in summary or line-level claim
formats for a 3-year historical period as
well as on a quarterly basis during the
performance period. We believe that
these data constitute the minimum
information necessary to enable the
participant hospital to understand
spending patterns during the episode,
appropriately coordinate care, and target
care strategies toward individual
beneficiaries furnished care by the
participant hospital and other providers
and suppliers.
Under the HIPAA Privacy Rule,
covered entities (defined as health care
plans, providers that conduct covered
transactions, including hospitals, and
health care clearinghouses) are barred
from using or disclosing individually
identifiable health information (called
‘‘protected health information’’ or PHI)
in a manner that is not explicitly
permitted or required under the HIPAA
Privacy Rule. The Medicare FFS
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program, a ‘‘health plan’’ function of the
Department, is subject to the HIPAA
Privacy Rule limitations on the
disclosure of PHI. The hospitals and
other Medicare providers and suppliers
are also covered entities, provided they
are health care providers as defined by
45 CFR 160.103 and they conduct (or
someone on their behalf conducts) one
or more HIPAA standard transactions
electronically, such as for claims
transactions. In light of these
relationships, we believe that the
proposed disclosure of the beneficiary
claims data for an acute inpatient stay
plus 90-day post-discharge for episodes
included under the proposed models
would be permitted by the HIPAA
Privacy Rule under the provisions that
permit disclosures of PHI for ‘‘health
care operations’’ purposes. Under those
provisions, a covered entity is permitted
to disclose PHI to another covered entity
for the recipient’s health care operations
purposes if both covered entities have or
had a relationship with the subject of
the PHI to be disclosed, the PHI pertains
to that relationship, and the recipient
will use the PHI for a ‘‘health care
operations’’ function that falls within
the first two paragraphs of the definition
of ‘‘health care operations’’ in the
HIPAA Privacy Rule (45 CFR
164.506(c)(4)).
The first paragraph of the definition of
health care operations includes
‘‘conducting quality assessment and
improvement activities, including
outcomes evaluation and development
of clinical guidelines,’’ and
‘‘population-based activities relating to
improving health or reducing health
costs, protocol development, case
management and care coordination’’ (45
CFR 164.501).
Under our proposal, EPM participants
would be using the data on their
patients to evaluate the performance of
the participant hospital and other
providers and suppliers that furnished
services to the patient, conduct quality
assessment and improvement activities,
and conduct population-based activities
relating to improved health for their
patients. When done by or on behalf of
a covered entity, these are covered
functions and activities that would
qualify as ‘‘health care operations’’
under the first and second paragraphs of
the definition of health care operations
at 45 CFR 164.501. Hence, as previously
discussed, we believe that this provision
is extensive enough to cover the uses we
would expect an EPM participant to
make of the beneficiary-identifiable data
and would be permissible under the
HIPAA Privacy Rule. Moreover, our
proposed disclosures would be made
only to HIPAA covered entities that
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have (or had) a relationship with the
subject of the information, the
information we would disclose would
pertain to such relationship, and those
disclosures would be for purposes listed
in the first two paragraphs of the
definition of ‘‘health care operations’’.
When using or disclosing PHI, or
when requesting this information from
another covered entity, covered entities
must make ’’reasonable efforts to limit’’
the information that is used, disclosed
or requested to the ’’minimum
necessary’’ to accomplish the intended
purpose of the use, disclosure or request
(45 CFR 164.502(b)). We believe that the
provision of the proposed data elements
listed previously would constitute the
minimum data necessary to accomplish
the EPM’s goals of the participant
hospital.
The Privacy Act of 1974 also places
limits on agency data disclosures. The
Privacy Act applies when the federal
government maintains a system of
records by which information about
individuals is retrieved by use of the
individual’s personal identifiers (names,
Social Security numbers, or any other
codes or identifiers that are assigned to
the individual). The Privacy Act
prohibits disclosure of information from
a system of records to any third party
without the prior written consent of the
individual to whom the records apply (5
U.S.C. 552a(b)).
‘‘Routine uses’’ are an exception to
this general principle. A routine use is
a disclosure outside of the agency that
is compatible with the purpose for
which the data was collected. Routine
uses are established by means of a
publication in the Federal Register
about the applicable system of records
describing to whom the disclosure will
be made and the purpose for the
disclosure. We believe that the proposed
data disclosures are consistent with the
purpose for which the data discussed in
the final rule was collected and may be
disclosed in accordance with the
routine uses applicable to those records.
We note that, as is the case with CJR,
in the proposed rule, we proposed to
disclose beneficiary-identifiable data to
only the hospitals that are bearing risk
for an AMI, CABG, or SHFFT episode
and not with their collaborators (81 FR
50947). As stated in the final CJR rule
(80 FR 73515), we believe that the
hospitals that are specifically held
financially responsible for an episode
should make the determination as to
which data are needed to manage care
and care processes with their
collaborators as well as which data they
might want to re-disclose, if any, to their
collaborators provided they are in
compliance with the HIPAA Privacy
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515
Rule. We note that beneficiaries have
the right to request restrictions on the
use of their data in accordance with the
HIPAA Privacy Rule, but covered
entities are not required to agree to such
requests. We believe our data sharing
proposals are permitted by and are
consistent with the authorities and
protections available under the
aforementioned statutes and regulations.
We sought comments on our proposals
regarding the authority to share
beneficiary-identifiable data.
The following is a summary of the
comments received and our responses.
Comment: Multiple commenters
agreed with our proposals to provide
EPM participants with the opportunity
to request 3 years of historical or
baseline data prior to the start of the
first EPM performance year. However,
some commenters requested that CMS
make this data available to all hospitals
regardless of whether they located in a
randomly selected MSA or not. A
commenter pointed out that because
there is not a voluntary avenue for
participation in these proposed models
by hospitals that are not included in the
selected MSAs, such hospitals could
face a competitive disadvantage by not
being provided the same kinds of
financial and performance data as
hospitals that are included in these
EPMs. Other commenters requested that
CMS begin providing data to all
hospitals so that they may begin to
understand their patients clinical care
paths, episode spending, and compare
themselves to their peers.
Response: We appreciate the
comments supporting our proposal to
make 3 years of historical or baseline
data available to EPM participants. For
hospitals that are not in selected MSAs,
we understand that this data would
assist in identifying opportunities for
improving efficiency and care
coordination, but we do not have the
authority to expand the availability of
these data beyond what we proposed.
We proposed to make EPM data
available under the HIPAA Privacy Rule
provision that permits the disclosure of
this information for ‘‘health care
operations’’ purposes and in accordance
with the ‘‘minimum necessary’’
standard.
We thank commenters for their input
on our proposals to provide beneficiarylevel data to EPM participants, upon
request, under the HIPAA Privacy Rule
provisions that permit disclosures of
PHI for ‘‘health care operations’’
purposes. We are not modifying our
proposals to provide hospitals that are
not located in the randomly selected
EPM MSAs with the opportunity to
request EPM data.
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7. Data Considerations With Respect to
EPM and CJR Collaborators
As noted earlier in this section and as
is the case with CJR (80 FR 73515), we
proposed to disclose beneficiaryidentifiable data to only the EPM
participants that are bearing risk for an
AMI, CABG, or SHFFT episode and not
with their collaborators because we
believed that the EPM participants that
are specifically held financially
responsible for an episode should make
the determination as to which data are
needed to manage care and care
processes with their collaborators as
well as which data they might redisclose in accordance with applicable
privacy and security laws. Based on our
experience in implementing CJR,
however, we understood that some CJR
collaborators under that model believed
that not having comparable data poses
challenges to their ability to assess their
own performance in the context of the
model and the region in which they
operate. As such, these collaborators
believed that it would be helpful to have
additional data with which they could
better assess their own performance,
including information about care
patterns within their region.
We are considering ways in which to
address the concerns raised by these CJR
collaborators and potentially similar
future concerns that could arise among
EPM collaborators as well as what
additional data might be helpful for
these purposes and which could be
disclosed in accordance with existing
statutory and regulatory requirements.
As previously discussed, EPM
participants, like CJR participants, may
share data with their EPM (or CJR)
collaborators provided they are
‘‘business associates’’ in compliance
with the HIPAA Privacy Rule, and we
encourage them to make data available
to their EPM collaborators to the extent
they deem it appropriate and in
compliance with these strictures.
In addition, given our view that the
HIPAA Privacy Rule limits our ability to
share beneficiary-identifiable data with
non-EPM (or non-CJR) participants, we
are considering whether it would be
feasible and appropriate to make
additional non-beneficiary-identifiable
aggregate data publicly available
through some means. For example, we
are exploring whether it would be
helpful to make available aggregate
summary data organized by anchor MS–
DRG, provider type, and region for care
that would be included in episodes that
would meet the criteria for inclusion in
the regional component of EPM (or CJR)
episode benchmark prices as described
in section III.D.4.b. of this final rule (or
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80 FR 73337 with respect to CJR),
assuming all IPPS hospitals nationally
were EPM (or CJR) participants. We will
refer to these episodes as simulated
episodes later in this section. We were
interested in whether information such
as the following would be helpful to
EPM (or CJR) collaborators:
• Number of simulated episodes and
number of hospitals with each anchor
MS–DRG at discharge in the simulated
episodes.
• For AMI model anchor MS–DRGs,
the number of simulated episodes with
chained anchor admissions by the price
MS–DRG that would have been assigned
to the simulated episode.
• For AMI model anchor MS–DRGs,
the number of simulated episodes with
readmissions resulting in discharge
under a CABG MS–DRG by the CABG
MS–DRG.
• Average (mean and median) and
standard deviation of total spending on
those simulated episodes.
• Number of simulated episodes with
and mean acute care payments for the
anchor hospitalization and readmission.
• Number of simulated episodes with
and mean Part B payments.
• Number of simulated episodes with
and mean inpatient rehabilitation
facility payments.
• Number of simulated episodes with
and mean skilled nursing facility
payments.
• Number of simulated episodes with
and mean home health payments.
• Proportion of total simulated
episode spending attributable to acute
care payments for the anchor
hospitalization and readmissions.
• Proportion of total simulated
episode spending attributable to Part B
payments.
• Proportion of total simulated
episode spending attributable to
inpatient rehabilitation facility
payments.
• Proportion of total simulated
episode spending attributable to skilled
nursing facility payments.
• Proportion of total simulated
episode spending attributable to home
health payments.
To assist us as we consider future
options for potentially increasing the
availability of data to collaborators
under the EPMs or similar models such
as CJR, we sought comments on what
kinds of actions and data would be most
helpful to EPM, or similar model (such
as CJR) collaborators, and which could
be disclosed in accordance with the
existing statutory and regulatory
requirements for sharing data. We note
that the number of simulated episodes
with chained anchor admissions by the
price MS–DRG on which we solicited
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comments for AMI model anchor MS–
DRGs is no longer relevant due to the
fact that we are not finalizing the AMI
transfer policy we proposed, as
discussed in detail in section III.C. of
this final rule.
The following is a summary of the
comments received and our responses.
Comment: Several commenters
supported our consideration of options
to potentially provide some publicly
available data to assist EPM and CJR
collaborators. However, commenters
specified that claims data should be
made available for all EPM collaborators
and providers affected by the
implementation of EPMs. In particular,
they stated that post-acute care
providers find it difficult to access the
data needed (for example, claims data
on readmissions) to support care
coordination capabilities. Another
commenter requested that any provider
who treats an EPM beneficiary during
the episode should also have access to
the claims data so that providers would
be able to analyze the data and develop
approaches to care redesign, especially
when the hospital has not expended the
resources to do such analytics. They
also commented that this analysis
would allow post-acute care providers
to demonstrate their value to a hospital
and would also allow post-acute care
providers to better position themselves
when entering into gainsharing
arrangements with a participating
hospital. Other comments suggested that
CMS should require that EPM data be
shared equitably among the
participating entities, regardless of
which entity is charged with
coordinating the fiscal arrangement
according to CMS.
Response: We appreciate the
suggestions commenters offered. While
we understand the commenters’ desire
for us to provide beneficiary-identifiable
claims data to collaborating post-acute
care providers, we note that we are
unable to do this as we do not have the
authority to expand the availability of
these data beyond what we proposed.
As with CJR, and as indicated earlier,
there are significant sensitivities and
constraints on our ability to make
beneficiary-identifiable data available.
We proposed to make these data
available to hospitals participating in
the model in recognition of and in
compliance with the HIPAA Privacy
Rule provision that permits the
disclosure of this information for
‘‘health care operations’’ purposes and
in accordance with the minimum
necessary standard. Requests for EPM
data from entities that are not officially
participating in the model would not
meet the required standards to receive
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these data. Although providers and
suppliers (physicians, post-acute care
providers, etc.) that are collaborators
with hospitals participating in the EPMs
might be eligible to receive data under
HIPAA, provided that they had a
‘‘business associate’’ relationship with
the beneficiary, we do not believe it is
appropriate for CMS to provide
collaborators these data directly because
hospitals are the entities designated
under the model to assume risk and
responsibility for a beneficiary’s episode
of care under the model. Accordingly, as
the responsible entity (and as a covered
entity under HIPAA), we believe that
hospitals should decide what data they
need to manage care and care processes
with their collaborators and, in
consultation with their own legal
counsel, what data they may or may not
wish to make available to those
collaborators provided they are in
compliance with the HIPAA Privacy
Rule.
Comment: Other commenters made
suggestions regarding the types of data
we considered to provide publicly to
EPM collaborators. They stated that the
data should include information
included in the Quality and Resource
Use Reports (QRUR) so that
collaborators will be able to understand
their own costs as well as those for
downstream providers in order to
effectively enter into these financial and
clinical arrangements.
Response: We appreciate the
suggestions, but do not plan to provide
QRUR data in our publicly available
files. We note that information and
instructions on obtaining QRURs can be
found at: https://www.cms.gov/
Medicare/Medicare-Fee-for-ServicePayment/PhysicianFeedbackProgram/
Obtain-2013-QRUR.html.
Comment: We received several
comments supporting the sharing of
beneficiary identifiable data by EPM
participants with entities with which
the hospital has a business associate
agreement (BAA). Commenters noted
that data sharing is an excellent strategy
for engaging providers and that data can
be a catalyst for change. Based on
experience in BPCI, commenters
pointed out that data sharing also
inspires collaboration as hospitals and
post-acute care providers are more
likely to come together to conduct root
cause analyses of adverse patient care
events so that both entities learn from
the bundled payment program data. A
commenter added that the BPCI model
recognized the need for a facilitator
convener—an entity that serves an
administrative and technical assistance
function for one or more designated
awardees/awardee conveners, and who
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would not have an agreement with
CMS, bear financial risk, or receive any
payment from CMS. Another
commenter requested that CMS consider
distributing the data to EPMs or their
designees under a data use agreement
(DUA) process similar to how
beneficiary-identifiable claims data are
currently distributed under the BPCI
program. They stated that this would
allow third-party entities to provide
data analysis services to EPM
participants who lack the capabilities
and infrastructure to do so.
Response: We appreciate the support
offered by these commenters. In
addition, we will require a data request
and attestation form and will have a
mechanism in place for business
associates, as defined under HIPAA, to
receive data directly from CMS on an
EPM participant’s behalf (if approved by
that EPM participant). This form would
also allow business associates of
selected hospitals to provide
administrative or technical assistance to
multiple hospitals.
L. Coordination With Other Agencies
Impacts created by payment changes
under this model are entirely internal to
HHS operations; coordination with
other agencies is not required outside of
the usual coordination involved in the
publication of all HHS regulatory
changes.
IV. Evaluation Approach
A. Background
As stated in the proposed rule, the
EPMs are intended to enable CMS to
better understand the effects of episode
payment approaches on a broader range
of Medicare providers and suppliers
than would choose to participate in a
model such as is currently being tested
under BPCI. Obtaining information that
is representative of a wide and diverse
group of episode initiators will best
inform us on how such a payment
model might function were it to be more
fully integrated within the Medicare
program. The CR incentive model is
intended to enable CMS to assess
whether the incentive improves patient
quality and access to this covered
benefit without increasing overall
payments. All CMS models, which
would include the EPMs and CR
incentive model, are rigorously
evaluated on their ability to improve
quality and reduce costs. In addition,
we routinely monitor CMS models for
potential unintended consequences of
the model that run counter to the stated
objective of lowering costs without
adversely affecting quality of care.
Outlined in the following section are the
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proposed design and evaluation
methods, the data collection methods,
key evaluation research questions, and
the evaluation period and anticipated
reports for the EPMs as well as our
response to comments received and our
final decisions.
B. Design and Evaluation Methods
As stated in the proposed rule, our
evaluation methodology for the EPMs
and CR incentive model is consistent
with the standard Innovation Center
evaluation approaches we have taken in
other projects such as the BPCI
initiative, the CJR model, the Acute Care
Episode (ACE) Demonstration, the
Pioneer ACO model, and other
Innovation Center models. Specifically,
the evaluation design and methodology
we proposed is designed to allow for a
comparison of historic patterns of care
among the participants to any changes
made in these patterns in response to
the models. In addition, the overall
design would include a comparison of
participants in EPM or CR areas with a
matched comparison group in areas not
participating in a specific episode to
help us discern simultaneous and
competing provider and market level
forces that could influence our findings.
Comparison group members for the
EPMs would be selected based on how
well they match the EPM participants
along a variety of measurable
dimensions, such as size, expenditures,
and other provider characteristics and
market characteristics. The random
method of selection for participating
MSAs will allow the evaluation to
observe the operation of the model in a
variety of circumstances and among
providers and suppliers who may not
otherwise choose to participate in an
alternative payment model.
As stated in the proposed rule, we
plan to use a range of analytic methods,
including regression and other
multivariate methods, and difference-indifferences methods to examine each of
our measures of interest. Measures of
interest could include, for example,
quality of and access to care, utilization
patterns, expenditures, and beneficiary
experience. With these methodologies,
we would be able to examine the
experience over time relative to those in
the comparison groups controlling for as
many of the relevant confounding
factors as is possible. The evaluation
would also include rigorous qualitative
analyses in order to capture the evolving
nature of the care model interventions.
In our design, as we stated in the
proposed rule, we plan to take into
account the impact of the models at the
geographic unit level, the hospital level,
and at the patient level. We will also
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consider various statistical methods to
address factors that could confound or
bias our results. For example, we would
use statistical techniques to account for
clustering of patients within hospitals
and markets. Clustering allows our
evaluation to compensate for
commonalities in beneficiary outcomes
by hospitals and by markets. Thus, in
our analysis, if a large hospital
consistently has poor performance,
clustering would allow us to still be able
to detect improved performance in the
other, smaller hospitals in a market
rather than place too much weight on
the results of one hospital and
potentially lead to biased estimates and
mistaken inferences. Finally, we plan to
use various statistical techniques to
examine the effects of the models while
also taking into account the effects of
other ongoing interventions such as
BPCI and the Shared Savings Program.
For example, we will consider
additional regression techniques to help
identify and evaluate the incremental
effects of adding the EPMs in areas
where patients and market areas are
already subject to these other
interventions as well as potential
interactions among these efforts.
C. Data Collection Methods
We will consider multiple sources of
data to evaluate the effects of the EPMs
and CR Incentive models. We expect to
base much of our analysis on secondary
data sources such as Medicare FFS
claims. The beneficiary claims data will
provide information such as use of CR,
expenditures in total and by type of
provider and service as well as whether
or not there was an inpatient hospital
readmission or a subsequent AMI. In
conjunction with the secondary data
sources mentioned previously, we will
consider a CMS-administered survey of
beneficiaries who received a qualifying
procedure during the performance
period in the EPMs’ evaluation. This
survey would be administered to
beneficiaries who were in the EPMs
qualifying episode or similar patients
selected as part of a control group. The
primary focus of this survey would be
to obtain information on the
beneficiary’s experience in EPMs’
episodes relative to usual care. The
administration of this beneficiary survey
would be coordinated with
administration of the HCAHPS survey
so as to not conflict with or compromise
HCAHPS efforts. For the evaluation of
both the EPMs and the CR incentive
model, we will consider a survey
administered by CMS and guided
interviews conducted by CMS with
providers and suppliers including, but
not limited to, initiating and transfer
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hospitals, physicians, and post-acute
care providers participating in the
models. These surveys would provide
insight on providers’ experience under
the model and further information on
the care redesign strategies undertaken.
In addition, we will consider CMS
evaluation contractor administered site
visits and focus groups with selected
hospitals, physicians, and post-acute
care providers in EPMs and CR
evaluation efforts. We believe that these
qualitative methods will provide
contextual information that would help
us better understand the dynamics and
interactions occurring among
participants. For example, these data
could help us better understand
hospitals’ intervention plans as well as
how they were implemented and what
they achieved. Moreover, in contrast to
relying on quantitative methods alone,
qualitative approaches would enable us
to view program nuances as well as
identify factors that are associated with
successful interventions and distinguish
the effects of multiple interventions that
may be occurring, such as simultaneous
ACO and bundled payment
participation.
We anticipated that secondary data
sources will be the source of most if not
all data collection for the FFS-non CR
control group; however, we may initiate
some data collection from primary data
sources for this group if warranted.
D. Key Evaluation Research Questions
Our evaluation would assess the
impact of the models on the aims of
improved care quality and efficiency as
well as reduced health care costs. This
would include assessments of patient
experience of care, utilization,
outcomes, Medicare expenditures,
quality, and access. Our key evaluation
questions would include, but would not
be limited to, the following:
• PAYMENT. Is there a reduction in
Medicare expenditures in absolute
terms? By subcategories? Do the
participants reduce or eliminate
variations in utilization and/or
expenditures that are not attributable to
differences in health status? If so, how
have they accomplished these changes?
• UTILIZATION. Are there changes
in Medicare utilization patterns overall
and for specific types of services? How
do these patterns compare to matched
comparators, historic patterns, regional
variations, and national patterns of care?
How are these patterns of changing
utilization associated with Medicare
payments, patient outcomes, and
general clinical judgment of appropriate
care? For example, in the AMI and
CABG episodes, what changes to
hospital transfer patterns, if any, could
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be seen under the models? Has there
been any changes to utilization of
cardiac rehabilitation services and does
this appear to be associated with access
to the cardiac rehabilitation incentive
payment, participation in the cardiac
EPMs or a combination of the two?
• REFERRAL PATTERNS AND
MARKET IMPACT. How has the
behavior in the selected MSAs changed
under the models? Have the referral
patterns of type and specific providers
changed?
• OUTCOMES/QUALITY. Is there
either a negative or positive impact on
quality of care and/or better patient
experiences of care? Did the incidence
of relevant clinical outcomes including
but not limited to complications,
mortality, readmissions and other
subsequent clinically relevant events,
and beneficiary pain, functioning, and
independence experiences remain
constant or decrease? Were there
changes in beneficiary outcomes under
the models compared to appropriate
comparison groups? Was there an
impact on quality during the episode/
CR care period or in the period
immediately preceding or following the
episode/CR care period? Was there an
impact on measures of relevant long
term quality such as mortality at one
year after the initiating event?
• UNINTENDED CONSEQUENCES.
Did the models result in any unintended
consequences, including adverse
selection of patients, access problems,
cost shifting beyond the episode/CR
care period, evidence of delay or
stinting of appropriate care, anticompetitive effects on local health care
markets, or evidence of inappropriate
referrals practices? Is so, how, to what
extent, and for which beneficiaries or
providers?
• POTENTIAL FOR
EXTRAPOLATION OF RESULTS. What
was the typical patient case mix and
how did this compare to regional and
national patient populations? What
were the characteristics of impacted
markets, providers, and patients and to
what extent were they reflective of the
national sample? Were EPMs and/or the
CR incentive model more successful in
reducing payments and improving
quality in certain types of markets,
providers, or patients? To what extent
would the results be able to be
extrapolated to similar markets and/or
nationally?
• EXPLANATIONS FOR
VARIATIONS IN IMPACT. What factors
are associated with the pattern of results
stated previously? Specifically, are they
related to—
++ Characteristics of the
administrative features of the models
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including variations by year and factors
such as presence of downside risk;
++ The EPM or CR participant’s
specific features and structure,
including such factors as the number of
relevant cases, whether they have ability
to handle complex cases, profit status,
proportion of dually eligibility patients
served, and other considerations;
++ The EPM or CR participant’s care
redesign or other interventions and their
ability to carry out their planned
interventions;
++ The characteristics of the
providers and suppliers serving patients
during the entirety of the episode or CR
care period and the nature of the
interaction of these providers and
suppliers with the EPM or CR
participants;
++ The characteristics of the markets
and MSAs, and
++ The clinical and sociodemographic characteristics associated
with the patient populations served.
E. Evaluation Period and Anticipated
Reports
The models have a 5-year
performance period and the evaluation
periods would encompass the entire 5year period and up to 2 years after. We
plan to evaluate the EPMs on an annual
basis. However, we recognize, that
interim results are subject to issues such
as sample size and random fluctuations
in practice patterns. Hence, while CMS
intends to have internal periodic
summaries to offer useful insight during
the course of the effort, a final analysis
after the end of the 5-year performance
period will be important for ultimately
synthesizing and validating results.
We sought comments on our design,
evaluation, data collection methods, and
research questions.
The following is a summary of the
comments received and our responses.
Comment: Several commenters
expressed concerns with the manner in
which quality is examined under the
EPMs. Specifically, there was concern
that the understanding of the impact on
quality for these models should include
a more comprehensive approach beyond
just those quality measures used in the
reconciliation methodology.
Commenters expressed the belief that
the quality measures used in
reconciliation were not adequate for the
purpose of determining if access and
clinical quality were adversely affected.
A commenter suggested that CMS
examine quality related to the
performance of providers aside from the
model participant hospitals and that
CMS should incorporate measures that
reflect the totality of care received in the
episode.
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Response: We thank the commenters
for their thoughts and acknowledge the
importance of examining the impact of
the EPMs on measures of quality of care
beyond what is used in the
reconciliation methodology. Our
intention in the evaluation is to conduct
a multifaceted and multi-pronged
examination of issues of quality, access,
and unintended consequences. The final
evaluation design plan for the
evaluation of the EPMs will be
developed at a future date and will
include quality as a key area of research
focus. CMS intends to examine issues of
quality of care using a variety of metrics
and for a variety of patient and provider
subgroups.
Comment: A few commenters
expressed concern with the possible
impact of the EPMs on reducing access
to new or to more expensive but higher
quality technology and devices. A
commenter requested that CMS conduct
a formal evaluation of the impact of the
EPMs on patient access to newer
technology and that CMS make
adjustments to care if patient access is
compromised. Similarly, another
commenter expressed concern that the
focus of the model on short-term costs
might cause a shift away from new
technologies such as angiography with
use of Fractional Flow Reserve (FFR).
The commenter encouraged CMS to use
incentives for newer technologies
shown to improve patient outcomes. In
addition, a commenter expressed
concern that the EPMs would induce
undue pressure to use device choices
based on considerations other than
quality in the treatment of SHFFT.
Response: We appreciate the
commenters’ concerns and will be
evaluating treatment patterns and shifts
in the evaluation of this mode. We
address the issue of new technology and
payment in section III.C.3.(b). of this
final rule. We note that we do not
anticipate data collection related to
device use or new technology beyond
what is currently available in claims
data. The issue of physician or other
providers’ perception of stinting of care
or unintended consequences is an issue
that may arise in qualitative data
collection efforts such as interviews and
focus groups. As with all evaluation
topics, CMS will strive to balance the
amount of burden placed on the sites
with regards to primary data collection
in choosing its areas of focus.
Comment: Two commenters
recommended that CMS increase the
frequency with which monitoring and
evaluation reports are made public.
Quarterly reporting was suggested as
commenters believed quarterly public
reports would be useful to both the
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519
public and the provider community and
would help to provide feedback to
providers as to what is occurring under
the model with respect to unintended
consequences so as to allow for
adjustments as needed.
Response: We appreciate the need for
frequent data updates for these models
and strive to provide at least quarterly
data feeds to model participants. We
refer readers to section III.K. of this final
rule for a detailed discussion on the
provision of data and claims to
participants under the EPMs. One of the
purposes for the distribution of this
quarterly claims information is to allow
for participants to conduct selfassessments of their performance under
the model. CMS will be conducting
regular interim assessments of the
results between the annual reports
which will be made publically
available. These interim reports
examine key metrics which are subject
to issues such as sample size and
random fluctuations in practice patterns
that may be more confusing than
illuminative to distribute. Their primary
purpose is to highlight possible trends
to examine and explore in the annual
reports. CMS will consider public
release of interim data points on a case
by case basis depending on the nature
of the findings and the degree of
certainty in the results but cannot
commit to providing publically
available reports on a quarterly basis.
Comment: A variety of commenters
expressed interest in the evaluation of
the impact of the EPMs on quality and
outcomes. Commenters suggested that
the CMS evaluation should incorporate
an assessment of whether EPMs had an
impact on issues such as:
• Overall procedure volume,
• Shifting of care beyond the 90-day
episode,
• Stinting of care and reduction in the
quality of devices used in SHFFT
procedures,
• Patient shared-decision making
related to device selection,
• Hospital to hospital transfers in the
Cardiac EPMs. The commenter was
particularly interested in the extent to
which transfers patterns between
participating and non-participating
hospitals were altered under the model,
• Process measures of quality such as
statin use or cardiac rehab referrals, and
• Over or inappropriate use of home
health services.
Response: The topic areas mentioned
by commenters are in alignment with
CMS’ intended research questions in the
evaluation. We appreciate the
contribution and insight behind these
comments and the focus they offer
towards refining the evaluation’s areas
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of emphasis in understanding the
impact of the EPM on the delivery of
care.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal, without
modification.
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V. Comprehensive Care for Joint
Replacement Model
A. Participant Hospitals in the CJR
Model
In the CJR proposed rule (80 FR
41207), we proposed to require that
almost all hospitals paid under the IPPS
that are physically located in a county
in an MSA selected for participation in
the CJR model would be required to
participate. In the final rule (80 FR
73288), we finalized this proposal,
noting that we would use the primary
physical address associated with a
hospital’s CCN to identify whether or
not a given hospital was physically
located in an MSA selected for
participation. In response to a
commenter’s inquiry as to whether all
hospitals under a CCN would be
required to participate in CJR if a CCN
included multiple hospital campuses
and some of these campuses were
physically located in the MSA while
others were not, we stated that since
CMS tracks and identifies hospitals
using the CCN, all hospital locations
associated with that CCN would be
required to participate in the model. In
order to identify hospitals located in the
MSAs selected to participate in the CJR
model, we will utilize the primary
physical address associated with the
CCN. In cases where a CCN is associated
with multiple hospital campuses, if the
primary CCN address is located in a
selected MSAs, all hospital campuses
associated with that CCN would be
required to participate in CJR unless
otherwise excluded. We also noted that
our initial analysis of the acute care
hospitals in the MSAs selected to
participate in CJR indicated that none of
the CCNs in the MSAs selected for CJR
included multiple campuses crossing
MSA boundaries. That is, none of the
CCNs with a primary physical address
in one of the selected MSAs had
multiple campuses physically located in
different MSAs that would result in
inclusion of a hospital campus not
physically located in a selected MSA.
We are not aware of any participant
hospitals currently in the CJR model
that are not physically located in one of
the 67 MSAs chosen to participate in
CJR. However, given the comments we
received from the public on the CJR
proposed rule (80 FR 41207) and
questions from stakeholders during our
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implementation of the CJR model, we
noted that if a hospital that is not
physically located in one of the 67
MSAs participating in CJR bills under a
CCN with a primary address in one of
the 67 CJR MSAs, whether through a
merger or other organizational change,
that hospital will be considered a CJR
participant as of the date in which the
hospital began to bill under the CCN
address located within the 67 MSAs.
This policy has been in effect since the
start of the CJR model on April 1, 2016
and is laid out at § 510.2 (definition of
participant hospital).
B. Inclusion of Reconciliation and
Repayment Amounts When Updating
Data for Quality-Adjusted Target Prices
In response to the CJR proposed rule,
commenters encouraged us to include
reconciliation payments in updated
historical episode spending totals when
calculating quality-adjusted target prices
for performance years 3 and 4 (based on
spending for episodes beginning in
years 2014 through 2016) and
performance year 5 (based on spending
for episodes beginning in 2016 through
2018). (Note that we proposed to replace
the term ‘‘target price’’ with the term
‘‘quality-adjusted target price,’’ as
described further in section V.C. of this
final rule.) Commenters were concerned
that if we excluded those payments, we
would not account for care coordination
services that are not paid for under
Medicare FFS, but that participant
hospitals paid for using reconciliation
payments. As a result, we would
underestimate hospital costs and prices
by not accounting for care coordination
services paid for with reconciliation
payments. We finalized our proposal to
exclude reconciliation payments from
expenditure data, noting our view that
including reconciliation payments
would result in Medicare paying
participant hospitals their qualityadjusted target price, regardless of
whether the participant hospital’s
expenditures were above or below that
price. We also noted that we had not
proposed an alternative in our proposed
rule, and that we might consider
including reconciliation payments in
updating the set of historical years used
to calculate quality-adjusted target
prices through future rulemaking (80 FR
73332).
Based upon our further consideration,
we proposed to include both
reconciliation payments and
repayments in our calculations when
updating quality-adjusted target prices
for performance years 3 and 4 and
performance year 5. We want to
encourage hospitals to invest in novel
ways of coordinating care and
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improving quality, and we recognize
that such activities are not directly
reimbursed by Medicare. We agree that
including reconciliation payments
would more fully recognize the total
costs of care under an episode payment
model than would excluding those
payments. The number of comments we
previously received on this topic
indicates that excluding reconciliation
payments could discourage such
investment, due to concerns that
quality-adjusted target prices would
underestimate the true cost of care.
Although including the entire
reconciliation payment in our updated
quality-adjusted target price
calculations could result in overpaying
for care coordination services, the
impact of including these payments on
quality-adjusted target prices will
decrease as we move to regional pricing.
In addition, we stated our belief that our
proposal to also include repayment
amounts when updating historical data
used to calculate quality-adjusted target
prices would mitigate any potential
overpayment for care coordination
services.
In addition, we proposed to include
in regional historical episode payments
any reconciliation payments and
repayment amounts from historical
BPCI LEJR episodes initiated at regional
hospitals in order to most fully capture
the total costs of care under episode
payment models. We stated that, if we
included reconciliation payments and
repayment amounts for CJR episodes but
not BPCI LEJR episodes, we would
likely underestimate the regional total
costs of care to hospitals, which would
result in artificially lowered qualityadjusted target prices for participant
hospitals, in effect penalizing
participant hospitals. By including these
amounts from both initiatives we will
avoid distorting the regional component
of historical LEJR episode spending,
which will be especially important once
we move to setting prices based on 100
percent regional episode data in
performance year 4 of the model. This
policy mirrors our proposal to include
these reconciliation payments and
repayment amounts when updating the
historical periods used for EPM qualityadjusted target prices; we refer readers
to section III.D.3.e. of this final rule for
further discussion of our rationale for
this approach.
We proposed to amend our
regulations to add a new subsection
§ 510.300(b)(8) to reflect this proposal.
We sought comment on our proposal.
The following is a summary of the
comments received and our responses.
Comment: A few commenters
expressed support for our proposal to
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include reconciliation payment and
repayment amounts in our calculations
for updating quality adjusted target
prices. One commenter stated that we
should apply this policy for calculating
quality adjusted target prices earlier
than performance year 3.
Response: We appreciate the
commenters’ support for our proposal.
We disagree with the comment
suggesting that we implement this
change prior to performance year 3. We
note that, because reconciliation takes
place 2 months after the completion of
a performance year, we will not have
calculated reconciliation and repayment
amount totals from performance year 1
in adequate time to incorporate them
into baseline spending totals used to
construct quality-adjusted target prices
for performance year 2, even if we were
to shift the historical baseline period
forward. Since we will not be recalculating historical baseline episode
spending until we set quality-adjusted
target prices for performance year 3
based on data from 2014 through 2016,
we will not implement this change prior
to performance year 3.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal, without
modification, to include CJR
reconciliation payment and repayment
amounts, as well as BPCI LEJR
reconciliation payment and repayment
amounts from regional hospitals, in the
historical episode spending amounts
used to calculate quality adjusted target
prices for Performance Years 3, 4, and
5 for CJR model participants.
C. Quality-Adjusted Target Price
We proposed to change the term we
use to refer to a CJR participant
hospital’s episode benchmark price
incorporating the effective discount
factor based on the participant
hospital’s quality category to ‘‘qualityadjusted target price.’’ This term will
replace our prior term, ‘‘episode target
price,’’ which referred to the episode
benchmark price with a 3 percent
discount applied. The term qualityadjusted target price would represent
the price used at reconciliation to
determine whether a CJR participant
hospital is eligible for a reconciliation
payment or repayment, and the amount
of the reconciliation payment or
repayment. To clarify, this change
would be a change of terminology to
more accurately reflect the impact of
quality scores on the reconciliation
process, and would not change the
actual data that hospitals receive. In
addition, our proposal to replace the
term ‘‘episode target price’’ with
‘‘quality-adjusted target price’’ mirrors
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the terminology for the proposed EPMs
and will reduce confusion for hospitals
participating in more than one model.
In accordance with 42 CFR
510.300(b)(7), CMS provides
prospective prices to CJR participant
hospitals prior to the performance
period in which they apply,
incorporating the 3 percent discount
that would apply if the hospital is
eligible for a reconciliation payment and
achieves an ‘‘Acceptable’’ composite
quality score category. As discussed in
the CJR final rule, a hospital’s effective
discount percentage may be reduced at
reconciliation to account for quality
performance (80 FR 73378). At the
conclusion of a performance year, CMS
will calculate a composite quality score
for each hospital, which determines the
effective discount percentage at
reconciliation. The CJR final rule
outlines the relationship between the
composite quality score and the
effective discount percentage (80 FR
73365). That is, a participant hospital
may be eligible to earn a greater
reconciliation payment or have a lower
repayment amount as a result of its
quality performance under the model
(80 FR 73378). Hospitals are therefore
aware that a different effective discount
factor, and thus different qualityadjusted target price, may be utilized at
reconciliation to reflect their quality
performance under the model, and they
could easily estimate the range of
potential quality-adjusted target prices
that could apply at reconciliation.
We also clarified the terminology we
use to describe the discount factor
included in the quality-adjusted target
price. The discount factor included in
the quality-adjusted target price based
on the quality score is referred to as the
‘‘effective discount factor.’’ In contrast,
the discount factor used to determine
repayment amounts in performance
years 2 and 3, during which repayment
responsibility is being phased in and a
lower discount factor applies for
purposes of calculating repayment
amounts will be referred to as the
‘‘applicable discount factor.’’ In
performance years 2 and 3, the effective
discount factor would continue to apply
for hospitals that qualify for and earn a
reconciliation payment; the applicable
discount factor would only be applied
in those cases where a hospital
exceeded expected episode spending
and would be responsible for
repayment.
We proposed to implement these
terminology changes in all
communications with participant
hospitals 60 days after the change is
finalized. We proposed to establish
these definitions in the regulations at
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§ 510.2 and update our regulations at
§ 510.300 and § 510.315 to reflect our
use of the term ‘‘quality-adjusted target
price’’ in lieu of ‘‘episode target price’’
and our use of the term ‘‘applicable
discount factor.’’ We received no
comments regarding our proposed
payment terminology changes.
Final Decision: We are finalizing the
proposal, without modification, to use
the term ‘‘quality-adjusted target price’’
in lieu of ‘‘episode target price,’’ and to
use the term ‘‘applicable discount
factor’’ to refer to the discount used to
determine repayment amounts in
performance years 2 and 3. We are
making one technical change to our
proposed regulations text to avoid
inadvertently deleting existing
§ 510.300(a)(5), by renumbering it to
(a)(6).
D. Reconciliation
In this final rule, in addition to the
changes we proposed, detailed later in
this section, we also want to correct an
example of a reconciliation calculation
that we included in the preamble to the
CJR final rule (80 FR 73399). This
example incorrectly suggested that stoploss and stop-gain limits would be
applied separately for each MS–DRG/
fracture level. In actuality, we will
apply stop-loss and stop-gain limits
after aggregating quality-adjusted target
prices at reconciliation and episode
spending across all MS–DRG/fracture
levels for a given hospital participant.
This methodology is correctly described
in the regulatory text of the CJR final
rule 42 CFR 510.305(e).
In addition, we are correcting the
definition of HCPCS in § 510.2 to read
Healthcare Common Procedure Coding
System.
1. Hospital Responsibility for Increased
Post-Episode Payments
As discussed in the CJR final rule,
participant hospitals will be responsible
for repaying Medicare for post-episode
spending that exceeds 3 standard
deviations from the regional mean (80
FR 73408). We refer readers to the CJR
final rule (80 FR 73407) for further
discussion of our rationale for holding
participant hospitals financially
accountable for significant increases in
Medicare Parts A and B spending during
the 30 days after a CJR episode ends. We
also finalized a policy to include the
result of our post-episode spending
calculation (the amount exceeding 3
standard deviations above the regional
mean) in a participant hospital’s NPRA
for a given performance year; as a result,
a hospital’s financial responsibility for
post-episode spending would be subject
to the stop-loss and stop-gain limits we
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finalized for the CJR model (80 FR
73398).
We proposed to modify our policy to
hold hospitals responsible for postepisode payments that exceed 3
standard deviations from the regional
mean. First, we proposed to calculate
post-episode payments using the same
timeframes we use for the subsequent
reconciliation calculation, not when we
conduct the initial reconciliation for a
performance year (80 FR 73383). Given
that we will begin reconciliation
calculations 2 months after the
conclusion of a performance year, we do
not believe there would be sufficient
time for claims run-out in order to set
a reliable regional threshold for
determining post-episode spending.
Since in all cases any responsibility for
post-episode payments would decrease
a participant hospital’s reconciliation
payment or increase its repayment
amount, our proposed change would
more accurately and fairly hold
hospitals accountable for increased
post-episode spending. We believe
instances in which a CJR participant
hospital is responsible for post-episode
spending repayment will be rare, given
our belief that hospitals in the CJR
model will focus on care redesign
during the LEJR episode and our other
monitoring efforts under the CJR model.
Our intent is to prevent hospitals from
delaying services or care until the
conclusion of a CJR episode by
monitoring for cases in which hospitals
have significantly increased spending in
the 30 days following the episode.
Assessing post-episode spending when
we have more complete claims
information would allow a more
accurate assessment of hospitals’
behavior under the model and prevent
potentially high fluctuations in results
that may occur if we calculate regional
thresholds and hold hospitals
responsible for post-episode spending
beginning 2 months after the conclusion
of a performance year. We proposed that
this modified timeline would be applied
to our reconciliation of the first CJR
performance year and all performance
years thereafter. We stated that we
would assess post-episode spending for
the first performance year (episodes
beginning and ending between April 1,
2016 and December 31, 2016) when we
conduct the reconciliation for the
second CJR performance year (2017) in
early 2018.
We also proposed that hospital
responsibility for post-episode spending
will not be subject to the stop-loss and
stop-gain limits. Although we believe,
as noted previously, that hospital
responsibility for post-episode spending
will be rare, we also believe that in
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those cases where a hospital has
financial responsibility for post-episode
spending, such hospitals should be
responsible in full for these amounts.
The CJR model includes stop-loss limits,
including more generous limits for
certain types of hospitals (80 FR 73403),
which are designed to limit a
participant hospital’s responsibility for
episode spending above the qualityadjusted target price during the anchor
hospitalization and 90-day postdischarge period. The stop-loss limits
are not intended to protect hospitals
that engage in inappropriate behavior or
shifting of care beyond the episode from
financial responsibility for such actions.
We proposed to implement this policy
change when we conduct the
subsequent reconciliation calculation
for performance year 1 of the model in
the first 2 quarters of 2018 and for all
performance years thereafter. That is,
when we conduct the reconciliation for
performance year 1 in early 2017, we
would not assess post-episode spending
for performance year 1 at that time.
Although hospitals would not have been
aware of these proposed changes to our
reconciliation process during
performance year 1 of the model, the
proposed changes will not impact the
performance year 1 NPRA.
We proposed to amend our
regulations at § 510.305(e),
§ 510.305(h)(6), and add a new
paragraph § 510.305(j)(2) to reflect these
proposals. We sought comment on our
proposals. We received no comments on
our proposal to calculate post-episode
spending at the time of the subsequent
reconciliation and to exempt postepisode spending from stop-loss limits.
Final Decision: We are finalizing the
proposal, without modification, to
calculate post-episode spending for each
performance year at the time of the
subsequent reconciliation for that
performance year, and to exempt postepisode spending from stop-loss limits.
2. ACO Overlap and Subsequent
Reconciliation Calculation
In the CJR final rule, we finalized a
policy to account for overlap in
situations where a portion of the CJR
discount percentage is paid out as
savings to an ACO participating in the
Shared Savings Program or specified
ACO models. We refer readers to the
CJR final rule for further discussion of
this policy and our rationale for this
approach (80 FR 73395–73398). We
proposed a modification to how we will
account for such cases of overlap in the
CJR model at reconciliation. In the final
CJR rule, we specified that the results of
this overlap calculation would be
included in the subsequent
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reconciliation calculation that occurs 14
months after the conclusion of a
performance year (80 FR 73383). We
proposed that the subsequent
reconciliation calculation not include
the results of this ACO overlap
calculation; that is, the subsequent
reconciliation calculation will only
include calculating the prior
performance year’s episode spending a
second time with more complete claims
data and comparing it to the qualityadjusted target price. The ACO overlap
calculation will be a separate
calculation from the subsequent
reconciliation (although both
calculations will occur concurrently)
and added with the NPRA, subsequent
reconciliation calculation, and postepisode spending calculation to
determine the reconciliation payment or
repayment amount at reconciliation.
The effect of this proposal will be that
these overlap amounts will not be
subject to the stop-loss or stop-gain
limits that apply to the calculation of
the NPRA and subsequent reconciliation
calculation. We believed this change
was appropriate because the subsequent
reconciliation calculation is intended to
account for claims run-out and canceled
episodes, and to reassess CJR episode
spending during the model performance
years. The stop-loss limit, therefore, is
intended to ensure that participant
hospitals that do not reduce actual
episode payments below the qualityadjusted target price have a limit on the
amount they must repay Medicare due
to spending during CJR episodes. The
stop-gain limit, conversely, is intended
to place judicious limits on the degree
to which hospitals can be rewarded
based on responsible stewardship of
CMS resources. In contrast, the ACO
overlap calculation is intended to
account for cases in which a portion of
the CJR discount percentage is paid out
to an ACO as shared savings, and does
not hinge upon a participant hospital’s
performance in the CJR model. If ACO
overlap amounts are included in
calculations of the stop-loss limit, CMS
could in some cases pay twice for the
same cost-reducing activities, thereby
skewing the model results. We believe
the stop-loss and stop-gains should
provide limits on the amount a hospital
could earn or lose due to episode
spending, not limit CMS’s ability to
adjust for overlap between models. For
these reasons, we do not believe our
policy to avoid paying out savings twice
for the same beneficiary during the same
period should be subject to the stop-loss
or stop-gain limits. More details on how
the proposed modification will impact
the steps involved in the reconciliation
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process are provided further in this
section.
We proposed to implement the policy
change when we conduct the
subsequent reconciliation calculation
for performance year 1 of the model in
the first 2 quarters of 2018 and for all
performance years thereafter. Although
hospitals would not have been aware of
these proposed changes to our
reconciliation process during
performance year 1 of the model, we
believed this timeframe was reasonable
for the following reasons. First, if CMS
must recoup a portion of the CJR
discount percentage paid out as shared
savings, this calculation must occur
during the same timeframe as the
subsequent reconciliation calculation
for a given performance year to ensure
that the ACO models and program have
already completed their financial
reconciliation for a given performance
year. Second, this policy change (that is,
not including the ACO overlap
calculation in assessing whether a
hospital has met the stop-loss or stopgain limit for a given year) will not
impact the performance year 1 NPRA.
We proposed to add a new paragraph
to our regulations at § 510.305(i). We
sought comment on our proposal. We
received no comments on our proposal
to calculate ACO overlap amounts
separately from the subsequent
reconciliation, so that ACO overlap
amounts will not be subject to stop-loss
limits.
Final Decision: We are finalizing the
proposal, without modification, to
perform ACO overlap calculations
separately from the subsequent
reconciliation, so that ACO overlap
amounts will not be subject to stop-loss
limits.
3. Stop-Loss and Stop-Gain Limits
In the CJR final rule, we finalized our
proposal to limit the amount a CJR
participant hospital will be required to
repay Medicare or could earn as a
reconciliation payment under the CJR
model. Specifically, we stated that CJR
participant hospitals would be subject
to the following stop-loss limits: 5
percent in performance year 2, 10
percent in performance year 3, and 20
percent in performance years 4 and 5.
Similarly, we finalized symmetrical
stop-gain limits: 5 percent in
performance years 1 and 2, 10 percent
in performance year 3, and 20 percent
in performance years 4 and 5 (80 FR
73401 through 73402). We finalized
separate limits to provide additional
financial protections for rural hospitals,
Medicare-dependent hospitals, rural
referral centers, and sole community
hospitals (80 FR 73406). These limits
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are intended to provide financial
protections for CJR participant
hospitals, who may have varying levels
of experience with episode payment
models. We finalized symmetrical stopgain limits to ensure hospitals do not
have an incentive to excessively reduce
services provided during episodes or
shift services outside the CJR episode
(80 FR 73398). As noted previously in
this section, we proposed a modification
to our application of the stop-loss and
stop-gain limits for the CJR model by
excluding the post-episode spending
amount and situations in which the CJR
discount percentage is paid out to an
ACO as shared savings.
In light of our proposal to exclude the
ACO overlap and post-episode spending
adjustments from the stop-loss and stopgain limits, to calculate the stop-loss
and stop-gain limits, we would use a
hospital’s quality-adjusted target price
at reconciliation. For example, a
hospital with benchmark episode
spending of $30,000 and a composite
quality score of ‘‘excellent,’’ would have
an effective discount percentage of 1.5
percent and a quality-adjusted target
price of $29,550 at reconciliation. The
hospital’s stop-loss and stop-gain limits
for year 2 (assuming for simplicity that
the hospital has only 1 episode) would
be 5 percent of the quality-adjusted
target price, or $1,477.50. This is
consistent with our proposed
calculation of stop-loss and stop-gain
limits for the proposed EPMs described
in section III.C. of this final rule. This
approach is also consistent with our
regulations at § 510.305(e)(1)(v)(A) and
§ 510.305(e)(1)(v)(B) to calculate stoploss and stop-gain based on the effective
discount factor at reconciliation.
In order to determine whether a
participant hospital has reached the
stop-loss or stop-gain limits, we would
compare actual episode payments
during the performance year to the
quality-adjusted target price to calculate
the NPRA. In the example previously
noted, if the participant hospital had
actual episode spending of $35,000
during performance year 2, this would
be compared against its quality-adjusted
target price of $29,550. The difference
between the quality-adjusted target
price and actual episode spending is
$5,450, but since the applicable stoploss limit is $1,477.50, the hospital
would need to repay Medicare
$1,477.50. In this example, any postepisode spending amount or adjustment
for ACO overlap from the prior
performance year (performance year 1 in
this example) would not be included in
determining whether a hospital has met
the stop-loss or stop-gain limit for a
performance year, but rather would be
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added, unadjusted, to the performance
year 2 NPRA in order to calculate the
reconciliation payment or repayment
amount. Therefore, if the hospital in this
example owed $1,000 due to postepisode spending in performance year 1,
and we determined that $2000
represented the CJR discount percentage
that was paid out as shared savings for
performance year 1, the full $3000
would be added to the hospital’s
performance year 2 NPRA regardless of
stop-loss, resulting in a repayment of
$4,477.50. In addition, when performing
the subsequent reconciliation
calculation for performance year 2,
which would be done simultaneously
with the calculation of NPRA for
performance year 3, we would apply the
results of the performance year 2
subsequent reconciliation calculation to
the year 2 stop-loss limit of $1,477.50 to
ensure that, aggregated across all
episodes in the performance year, the
participant hospital is not responsible
for repaying Medicare more for episode
spending above the quality-adjusted
target price than the stop-loss limit for
that performance year. Thus, if the
subsequent reconciliation calculation
determined that the hospital in our
example had actually spent $36,000
during performance year 2, resulting in
a larger difference between actual
spending and the quality-adjusted target
price, the higher amount of $6,450
would still be subject to the stop-loss
limit of $1,477.50, so the hospital would
not be responsible for the additional
$1,000 of episode spending beyond the
quality-adjusted target price.
As discussed previously in this
section, we proposed to implement
these changes to our reconciliation
process beginning with the
reconciliation for performance year 1.
We proposed to amend our
regulations at § 510.305(e), § 510.305(f),
and add a new paragraph (j) to reflect
these proposals. We also proposed to
streamline § 510.305(i)(2) for clarity.
We sought comment on our proposal.
The following is a summary of the
comments received and our responses.
Comment: One commenter requested
that stop-loss be capped at 10 percent
for all years of the model.
Response: While we appreciate the
commenter’s thoughts on capping stop
loss, we note that we did not propose to
change the stop-loss and stop-gain
limits. As we noted in the CJR final rule
(80 FR 73401), we believe that we have
taken sufficient steps to limit downside
risk by capping high cost episodes and
phasing in downside risk more
gradually than originally proposed over
performance years 2 and 3. Our
proposal here was limited to the manner
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in which the stop-loss and stop-gain
limits are applied and therefore we
decline to adopt the commenter’s
suggested approach.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal, without
modification to apply the stop-loss or
stop-gain amount calculated in the first
reconciliation to the NPRA of both the
first reconciliation and the subsequent
reconciliation NPRA, but not to postepisode spending or ACO overlap
adjustments.
4. Modifications to Reconciliation
Process
As previously discussed in this
section, we proposed several
modifications to how we conduct the
reconciliation process for participant
hospitals in the CJR model for all
performance years. We proposed how
these steps would modify the CJR
reconciliation process we finalized in
the CJR final rule (80 FR 73383).
The following example illustrates our
proposed modifications to the
reconciliation process, reflecting our
proposals to compare actual episode
payments to the quality-adjusted target
price; calculate post-episode spending
beginning 14 months after the
conclusion of a performance year;
calculate post-episode spending
amounts and the ACO overlap
calculation separately from the NPRA
and subsequent reconciliation
calculation; and apply the stop-loss and
stop-gain limits only to calculations of
NPRA and the subsequent reconciliation
calculation (that is, exclude postepisode spending amounts and the ACO
overlap calculation) for a given
performance year:
Beginning 2 months after the
conclusion of performance year 2, CMS
would compare actual episode
payments to the quality-adjusted target
prices for the episodes at a CJR
participant hospital. The qualityadjusted target price that applies at
reconciliation would be based on a
participant hospital’s composite quality
score for performance year 2. We would
aggregate episodes at each CJR
participant hospital and calculate the
hospital’s NPRA. The NPRA would be
the difference between the qualityadjusted target price times the number
of episodes and actual episode
payments times the number of episodes
during the performance year. We would
apply the stop-gain and stop-loss limits
of 5 percent of the quality-adjusted
target price to determine if a hospital
reached the limit.
We would simultaneously perform
the subsequent reconciliation
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calculation for performance year 1, to
account for claims run-out and canceled
episodes from performance year 1. We
would reapply the stop-gain limit for
performance year 1, by summing the
result of the subsequent reconciliation
calculation for performance year 1 and
the performance year 1 NPRA (which
was calculated during the prior
reconciliation). For example, if the
participant hospital’s NPRA for
performance year 1 was greater than the
stop-gain limit and the result of the
subsequent reconciliation calculation
for performance year 1 was positive, the
subsequent reconciliation calculation
would not be added to the
reconciliation payment made to the
participant hospital in the second
quarter of 2018, because the stop-gain
limit had already been reached for
performance year 1.
Concurrently with our subsequent
reconciliation calculation, we would
also determine if a participant hospital
is responsible for post-episode spending
from performance year 1, as well as
determine any potential amount of the
CJR discount percentage that was paid
out as savings to an ACO entity as
previously described in this section
during performance year 1. In this
example, the results of all three
calculations (the subsequent
reconciliation calculation for
performance year 1—subject to the stoploss and stop-gain limits—and the postepisode spending calculation and ACO
overlap calculation) would be added to
the NPRA calculated for performance
year 2 in order to create the
reconciliation payment or repayment
amount. (The exception to this pattern
will be performance year 5, as the
subsequent reconciliation, post-episode
spending, and ACO overlap calculations
will occur in 2022 without a concurrent
NPRA calculation.)
We note that this approach mirrors
the reconciliation process we proposed
for the AMI, CABG, and SHFFT models
at III.D.5. of this final rule. We refer
readers to that section for additional
discussion of our approach. The
following is a summary of the comments
received and our responses.
Comment: One commenter requested
that reconciliation be performed on a
quarterly basis, in order to provide
faster feedback to help hospitals
improve their overall quality and cost
performance.
Response: As we did not propose to
change the frequency of reconciliation,
we decline to adopt this change. As we
noted in the CJR final rule (80 FR
73385), our experience with the BPCI
quarterly reconciliation process has
shown that, because providers and
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suppliers have a calendar year to submit
FFS claims for payment, many claims
are incomplete at the time of an initial
quarterly reconciliation, leading to
significant fluctuation between initial
and subsequent reconciliation
calculations. Time spent in such
frequent reconciliation and appeals
processes can detract from participants’
efforts focusing on care redesign and
coordination with providers and
suppliers engaged in furnishing care for
beneficiaries under the model. While
quarterly data feeds are subject to
similar limitations with respect to the
completeness of claims, we believe the
quarterly data feeds that hospitals
receive, which include both line-level
and summary claims data, provide
sufficiently detailed and timely
feedback to guide quality improvement
efforts.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposals to the CJR
pricing and reconciliation process
without modification.
E. Use of Quality Measures and the
Composite Quality Score
1. Hospitals Included in Quality
Performance Distribution
As finalized in the CJR final rule,
CMS computes quality performance
points for each quality measure based
on the participant hospital’s
performance percentile relative to the
national distribution of all hospitals’
performance on that measure. We
proposed to compute quality
performance points for each quality
measure based on the participant
hospital’s performance relative to the
distribution of performance of all
‘‘subsection (d)’’ hospitals reporting the
measure that are eligible for payment
under IPPS and meet the minimum
patient case or survey count for that
measure. This approach is similar to the
methodologies of other CMS programs,
such as the HVBP Program. In addition,
comparing CJR participant hospitals’
quality performance to IPPS-eligible
subsection (d) hospitals’ quality
performance on the same measures is a
fairer comparison of quality
performance, as CJR participant
hospitals are all IPPS-eligible subsection
(d) hospitals. Defining and limiting the
relative distribution in this way will
minimize variability due to factors that
are unrelated to quality, thereby
increasing the validity of the quality
performance score.
We proposed to amend the
regulations at § 510.315(c) to reflect this
change. We also proposed a technical
change to the regulations to renumber
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certain subparagraphs. We sought
comment on our proposals.
Final Decision: We did not receive
any comments on this section.
Therefore, we are finalizing the proposal
without modification.
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2. Quality Improvement Points
As finalized in the CJR final rule,
quality improvement points for each
measure are added to the composite
quality score if the hospital’s score on
that quality measure increases by at
least 3 deciles on the performance
percentile scale compared to the
previous performance year. We
proposed to clarify that, for performance
year 1, we will compare the hospital’s
performance percentile with the
corresponding time period in the
previous year, not the previous
performance year. We proposed this
clarification because there is no
performance year preceding
performance year 1. For performance
years 2 through 5, we will still compare
the hospital’s performance percentile
with the previous performance year. We
also proposed to modify this policy to
define quality measure improvement as
an increase of at least 2 deciles on the
performance percentile scale compared
to the previous performance year.
Reducing the threshold for
improvement from 3 deciles to 2 deciles
will increase the number of CJR
participant hospitals eligible for quality
improvement points and provide CJR
participant hospitals at all current levels
of quality performance, including those
historically lagging, with significant
incentives to achieve improvement in
the quality of care. Quality
improvement points can contribute up
to 1.8 points toward a CJR participant
hospital’s composite quality score, so
increasing the number of CJR
participant hospitals that are eligible for
these points may also increase the
number of CJR participant hospitals that
are eligible for a reduced qualityadjusted target price. As defined in
section V.C. of this final rule, the
quality-adjusted target price is the price
used at reconciliation to determine
whether a CJR participant hospital is
eligible for a reconciliation payment or
repayment and the amount of the
reconciliation payment or repayment.
This mirrors the approach we proposed
for the proposed EPMs as discussed in
section III.E.3.c. of this final rule.
We proposed to amend our
regulations at § 510.315(d) to reflect
these changes. We sought comment on
our proposal.
Final Decision: We did not receive
any comments on this section.
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Therefore, we are finalizing the proposal
without modification.
3. Relationship of Composite Quality
Score to Quality Categories
As finalized in the CJR final rule,
CMS will place participant hospitals
into one of four quality categories to
determine reconciliation payment
eligibility and, if applicable, the value of
the effective discount percentage at
reconciliation. We refer readers to the
CJR final rule for a full discussion of our
approach (80 FR 73363–73381). We
described a technical correction to our
composite quality scores that will
determine reconciliation payment
eligibility and the effective discount
percentage at reconciliation. We noted
that this technical correction does not
affect our estimation of savings due to
the CJR model, because the measure
distribution used for such calculations
in the CJR final rule was the correct one
we describe in this section.
As we stated in the proposed rule,
participant hospitals will be required to
achieve a minimum composite quality
score of greater than or equal to 5.0 to
be eligible for a reconciliation payment
if actual episode spending is less than
the target price. Participant hospitals
with a composite quality score less than
5.0 will be assigned to the ‘‘Below
Acceptable’’ quality category and will
not be eligible for a reconciliation
payment if actual episode spending is
less than the target price. Participant
hospitals with a composite quality score
greater than or equal to 5.0 and less than
6.9 will be assigned to the ‘‘Acceptable’’
quality category and will be eligible for
a reconciliation payment if actual
episode spending is less than the target
price. Participant hospitals in the
‘‘Acceptable’’ quality category will not
be eligible to receive a reduced effective
discount percentage at reconciliation.
Participant hospitals with a composite
quality score greater than or equal to 6.9
and less or equal to 15.0 will be
assigned to the ‘‘Good’’ quality category
and will be eligible for a reconciliation
payment if actual episode spending is
less than the target price. Participant
hospitals in the ‘‘Good’’ quality category
will be eligible to receive a reduced
effective discount percentage (80 FR
73378). Participant hospitals with a
composite quality score greater than
15.0 will be assigned to the ‘‘Excellent’’
quality category and will be eligible for
a reconciliation payment if actual
episode spending is less than the target
price. Participant hospitals in the
‘‘Excellent’’ quality category will be
eligible to receive a reduced effective
discount percentage (80 FR 73378).
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The following is a summary of the
comments received and our responses.
Comment: Several commenters
expressed concern that this technical
correction would penalize hospitals
because fewer hospitals would fall into
the ‘‘Acceptable’’ category and, as a
result, fewer hospitals would be eligible
for a reconciliation payment.
Commenters stated that CJR participant
hospitals have been modeling savings
based on the composite quality scores
and corresponding quality categories
published in the CJR final rule, and,
thus, changing these values would
result in a funding shortfall for hospitals
that have budgeted for savings based on
the original values. Some of these
commenters suggested that CMS ensure
that all the hospitals that fell into the
‘‘Acceptable’’ category based on
composite quality scores and
corresponding quality categories in the
final rule would also fall in the
‘‘Acceptable’’ category using the
proposed corrected values.
Response: We appreciate the
commenters’ concern that the proposed
technical correction to the composite
quality scores and corresponding
quality categories would penalize CJR
participant hospitals. In the CJR final
rule, we described calculating the
quality improvement points separately
from the quality performance points for
each measure. For example, as finalized
in the CJR final rule, hospitals could
earn a maximum of 8.0 quality
performance points (80 FR 73376) and
a maximum of 0.8 quality improvement
points (80 FR 73380) for the HCAHPS
Survey measure. Instead, we should
have calculated improvement points as
part of the total composite quality score
points for a measure. For example,
assigning a maximum of 7.2 quality
performance points for the HCAHPS
Survey measure would have allowed for
the addition of a maximum of 0.8
quality improvement points, for a total
of 8.0 maximum composite quality score
points for the HCAHPS Survey measure.
This correct method—calculating
improvement points as part of the total
composite quality score points for a
measure—was the method used to
estimate savings for the CJR model.
To correct this error, we are finalizing
our proposal to change the composite
quality scores and corresponding
quality categories. We appreciate that
this could present a challenge for some
hospitals that were expecting to fall into
a certain category based on modeling
their own composite quality score
values. Similar to the method used to
estimate savings for the CJR model, the
composite quality scores and
corresponding quality categories we are
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finalizing in this rule will place over 90
percent of participant hospitals in the
‘‘Acceptable’’ category or better. In
addition, the changes made to the
quality performance distribution and
quality improvement points in sections
V.E.1. and V.E.2. of this final rule,
respectively, will also affect estimations
of a hospital’s composite quality score.
As stated in section V.E.2. of this final
rule, reducing the threshold for
improvement from 3 deciles to 2 deciles
will increase the number of CJR
participant hospitals eligible for quality
improvement points and, thus, provide
more opportunities for hospitals to earn
a higher composite quality score.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal, without
modification, to correct the composite
quality scores that will determine
reconciliation payment eligibility and
the effective discount percentage at
reconciliation. We also are making
conforming changes to the other
provisions in § 510.305 to reflect the
new composite quality score ranges for
the quality categories.
4. Maximum Composite Quality Score
As finalized in the CJR final rule, a
participant hospital could be awarded a
maximum composite quality score of
21.8 if the hospital received maximum
quality performance points for each
quality measure, maximum quality
improvement points for each quality
measure, and successfully submitted
voluntary patient-reported outcomes
and limited risk variable data. We
proposed to award up to 10 percent of
the maximum measure performance
score on the THA/TKA Complications
and HCAHPS Survey measures, and to
impose a cap on the CJR model
composite quality score at 20 points.
This change would bring the calculation
of the CJR composite quality score into
greater alignment with existing CMS
programs, such as the HVBP Program,
by reducing the number of participants
who receive both the highest quality
performance score on a measure and the
maximum points for measure
improvement.
We proposed to amend our
regulations at § 510.315(d) to reflect this
change. We sought comment on our
proposal.
Final Decision: CMS did not receive
any comments on this section.
Therefore, we are finalizing the proposal
without modification.
5. Acknowledgement of Voluntary Data
Submission
Our regulations at § 510.400(c)(3) state
that although we do not publicly report
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the voluntary patient-reported outcomes
and limited risk variable data during the
CJR model, we do indicate whether a
hospital has voluntarily submitted such
data. We proposed to amend
§ 510.400(c)(3) to clarify that we would
acknowledge only CJR participant
hospitals that successfully submit
voluntary patient-reported outcomes
and limited risk variable data, in
accordance with § 510.400(b). We
sought comment on our proposal.
Final Decision: CMS did not receive
any comments on this section.
Therefore, we are finalizing the proposal
without modification.
6. Calculation of the HCAHPS Linear
Mean Roll-Up (HLMR) Score
We proposed to calculate the
HCAHPS Linear Mean Roll-up (HLMR)
score by taking the average of the linear
mean scores (LMS) for 10 of the 11
publicly reported HCAHPS measures for
IPPS hospitals with 100 or more
completed HCAHPS surveys in a 4quarter period. The HLMR will
summarize HCAHPS performance on all
of the publicly reported measures,
except for Pain Management. We
proposed this change because removal
of Pain Management from the HVBP
Program was proposed in the Hospital
Outpatient Prospective Payment System
and Ambulatory Surgical Center
Payment System Proposed Rule (81 FR
45603).
This mirrors the approach we
proposed for the proposed EPMs as
discussed in section III.E.4.d.(1)(f) of
this final rule. Our regulations do not
include the methods to calculate the
HLMR, so we refer readers to section
III.E.4.d.(1)(f) of this final rule for
additional discussion of our approach.
We proposed to implement the
proposed changes to hospitals included
in the quality performance distribution,
the maximum number of points in the
composite quality score, the change
from 3 to 2 deciles for assessing quality
improvement, and the calculation of the
HLMR score starting with the
reconciliation for performance year 1 of
the CJR model, when we calculate each
participant hospital’s composite quality
score for year 1.
Final Decision: CMS did not receive
any comments on this section.
Therefore, we are finalizing the proposal
without modification.
F. Accounting for Overlap With CMS
ACO Models and the Shared Savings
Program
The CJR final rule details our policies
to address cases of overlap in which
beneficiaries that are aligned or
attributed to an ACO model or Shared
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Savings Program participant are also
included in a CJR episode. We recognize
that there will be circumstances in
which a Medicare beneficiary in a CJR
episode is also aligned or attributed to
an ACO participating in the Shared
Savings Program or a CMS ACO model.
In the CJR final rule, we finalized an
approach to allow for such cases of
overlap and minimize any double
counting of savings through the
following policies. We will conduct our
annual reconciliation prior to the ACO
reconciliation process, and make our
reconciliation payments and repayment
amounts available for the ACO models
and program to take into account when
performing their reconciliation, as their
financial methodologies permit. In
addition, in cases where a portion of the
CJR discount percentage is paid out as
shared savings to a participant hospital
that participates in an ACO as a
participant or provider/supplier, we
would make an adjustment to the
participant hospital’s reconciliation
results. We refer readers to the CJR final
rule for a full discussion of our
approach and the options we considered
(80 FR 73387).
Given commenters’ concerns about
our approach, which are summarized in
the final rule (80 FR 73387) we have
continued to consider alternative
options for accounting for overlap
between the ACO models and program
and the CJR model. Specifically, we
considered, as some commenters
suggested, attributing savings achieved
during CJR episodes in which
beneficiaries are also aligned or
attributed to an ACO accepting
downside risk to the ACO entity, not the
participant hospital. We recognize that
ACOs are engaged in care management
activities for beneficiaries across the
spectrum of care, which may also
include care redesign during acute
episodes. As a result, we proposed to
cancel (or never initiate) a CJR episode
for beneficiaries that are prospectively
aligned to a Next Generation ACO or
ESRD Seamless Care Organization
(ESCO) in the Comprehensive ESRD
Care initiative in tracks with downside
risk for financial losses. While the CJR
model excludes beneficiaries whose
eligibility for Medicare is on the basis of
end stage renal disease, not all
beneficiaries aligned to ESCOs meet this
criterion. Thus, some beneficiaries
aligned to ESCOs could be included in
the CJR model.
We proposed to implement this policy
for episodes beginning on or after July
1, 2017, to align with the timeframe for
implementation of the proposed AMI,
CABG, and SHFFT models which
proposed the same exclusion of
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beneficiaries aligned to Next Generation
ACOs and ESCOs in downside risk
tracks. We proposed this change to how
we determine episodes included in CJR
because these ACOs and ESCOs are
accepting a high level of financial risk
for the total cost of care for their aligned
beneficiaries; for example, Next
Generation ACOs are held to as much as
80 percent to 100 percent of first dollar
losses. In addition, beneficiaries are
prospectively aligned to ACOs in both
initiatives. We believe that if we were to
implement a policy where we would
cancel CJR episodes based on a given
beneficiary’s ACO alignment status, we
would do so only in those cases where
the ACO alignment is prospective and
does not change during a performance
year. In such cases, CJR model
participant hospitals could be aware of
a beneficiary’s ACO alignment status,
reducing uncertainty as to whether a
given beneficiary is included in the CJR
model. We note that we proposed
elsewhere in this final rule to exclude
beneficiaries prospectively aligned to a
Next Generation ACO model participant
or an ESCO in the Comprehensive ESRD
Care Initiative in a downside risk track
from the proposed AMI, CABG, and
SHFFT model episodes because we
wish to test this alternative approach to
ACO overlap. We did not propose to
exclude beneficiaries assigned to Shared
Savings Program Track 3 ACOs,
however, because we intended to test
the approach of excluding
prospectively-aligned ACO beneficiaries
from the CJR model with the limited
number of beneficiaries assigned to Next
Generation ACOs and ESCOs in a
downside risk track. We did not seek to
disrupt the operations of our large,
permanent ACO program to test this
novel approach for accounting for
overlap. The Shared Savings Program is
a national program; we did not believe
that testing a new approach to
addressing overlap in a national
program would be appropriate prior to
testing such an approach with a smaller
population. However, we sought
comment on whether we should extend
this proposed policy—that is, excluding
from the CJR model beneficiaries who
are prospectively assigned to an ACO—
to beneficiaries who are assigned to a
Track 3 Shared Savings Program ACO.
We refer readers to section III.D.6.c. of
this final rule for further discussion of
our proposed approach and rationale,
including details on how we would
operationalize the approach if finalized
for CJR or the proposed EPMs.
In cases where a beneficiary is in a
CJR episode and also aligned to a
Pioneer ACO, Medicare Shared Savings
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Program ACO, or ESCO not
participating in a downside risk track,
we would not cancel the CJR episode.
The policies we previously finalized for
accounting for such overlap would
continue to apply. We refer readers to
the CJR final rule (80 FR 73391 through
73398) for additional discussion of our
policies. Because the Pioneer ACO
model ends on December 31, 2016, no
adjustments are necessary to account for
overlap between beneficiaries in the
proposed AMI, CABG, and SHFFT
models and the Pioneer ACO model.
However, since the first CJR
performance year began in April 2016,
we will make an adjustment for overlap
between the two models during the first
performance year of the CJR model.
Finally, we note that we proposed
elsewhere in this final rule to allow
certain ACOs to be CJR collaborators.
Our proposal, which is discussed in
detail in section V.J.1.a. of this final
rule, would allow for gainsharing
arrangements between ACOs (as defined
in the CJR rule) and CJR participant
hospitals. The proposal would allow
such partnerships in regions where such
relationships could be mutually
beneficial for ACOs and CJR participant
hospitals. We believe these proposals
will mitigate concerns about the limited
opportunities for collaboration between
ACOs and CJR participant hospitals that
are often caring for the same
beneficiaries. We refer readers to section
V.J.1.a. of this final rule for additional
detail on the proposed and final policy.
The proposal for addressing overlap
between the CJR model and CMS’s ACO
models and program is included in
§ 510.305(j)(1). We sought comment on
our proposal to exclude beneficiaries
aligned to a Next Generation ACO or
ESCO downside risk track from the CJR
model beginning with episodes that are
initiated on or after July 1, 2017. The
following is a summary of the comments
received and our responses.
Comment: Several commenters
expressed support for the proposed
exclusion of beneficiaries attributed to
ACOs in either the Next Generation
ACO or Comprehensive ESRD Care
models. A substantial number of these
commenters also supported extending
the exclusion to beneficiaries attributed
to Medicare Shared Savings Program
Track 3 ACOs, as Medicare Shared
Savings Program Track 3 ACOs include
downside risk as well. A number of
these commenters recommended
extending the exclusion even further to
include more ACO related exclusions
from the CJR model and expressed
concern that the current approach to
model overlaps undermines ACOs. One
commenter noted that ACOs have
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invested significant resources in
managing acute and post-acute care
already and overlap with the CJR model
deprives them of a key source of savings
and of a return on their investment. In
support of this perspective, several
commenters recommended the ACO
exclusions from CJR should be extended
to include beneficiaries attributed to any
ACO unless a collaborative agreement is
in place. If there is no collaborative
agreement in place between a CJR model
participant and an ACO that it is not
part of, then beneficiaries attributed to
that ACO should be excluded from the
CJR model episodes.
Response: We acknowledge the range
of perspectives expressed by
commenters and appreciate the many
specific suggestions for handling these
overlaps. We also acknowledge the
operational challenge both ACOs and
CJR hospital participants face and the
financial implications for both when
there are overlaps. We believe the level
and range of comments reflect the
challenge in balancing multiple
perspectives that we discussed in the
proposed rule. The predominance of
commenters supported our proposal to
exclude from the CJR model those
beneficiaries attributed to Next
Generation ACOs and the downside risk
track of Comprehensive ESRD Care
models, and a significant number of
commenters made compelling
arguments for extending it to Shared
Savings Program Track 3 ACOs. These
comments have convinced us that the
best way to balance the interests of both
ACOs and CJR participant hospitals, as
well as CMS’s interest in maximizing
population health and lowering total
costs of care, is to finalize our original
proposal with the addition of Shared
Savings Program Track 3 ACO
beneficiaries.
As we describe more fully in section
III.D.6.c of this final rule, we believe
that existing ACO models that assume
downside risk and prospectively
commit to coordinating a beneficiary’s
overall care for the entire year should
not be deprived of the opportunity to
benefit from cost savings achieved
during an LEJR episode of care. Postacute care, in particular, is an area in
which ACOs have made significant
investments, and existing ACOs that
assume both downside risk and
prospective responsibility for a
beneficiary’s care should have the
opportunity to share in the cost savings
achieved in the post-acute phase of an
LEJR episode. However, we continue to
be concerned about depleting the
eligible population of CJR participants,
which would not only diminish the
power of the model test and potentially
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exclude patients who would not
ultimately be assigned to an ACO, but
would also deprive CJR participant
hospitals of opportunities to save under
the model.
For these reasons, we are finalizing
our proposal with the one modification;
that is, we are excluding from the CJR
model those beneficiaries that are
assigned to a Shared Savings Program
ACO participating in Track 3. In order
to accurately reflect these changes and
align beneficiary inclusion criteria with
EPMs, we are also incorporating these
changes into the CJR model beneficiary
inclusion criteria, which will apply to
CJR episodes that begin on or after July
1, 2017.
Comment: Many commenters
expressed concern about the challenge
of having accurate and timely
information on patient attribution with
multiple models. They believed it was
unrealistic to expect hospital staff and
others to be able to accurately identify
patients in excluded ACO models and
questioned how CJR participants and
their partners would be able verify a
patient’s status.
Response: We appreciate the
operational challenges that CJR
participants and their collaborating
partners face in an environment where
there are many, potentially overlapping
models in place. We are actively looking
for opportunities to reduce operational
barriers where we can practically and
effectively do so. To this end, we are in
the process of developing a web portal
where CJR participant hospitals can, at
the point of care, look up and identify
beneficiaries prospectively assigned to
ACOs who will be excluded from the
CJR model. This system, which is being
developed consistent with the
requirements of the Privacy Act and is
currently in testing, is expected to be
operational when EPMs are
implemented in July of 2017. Model
participants will be provided with more
specific information on this portal
project as it is rolled out.
Final Decision: After consideration of
the public comments received, we are
finalizing our proposal with the one
modification; that is, we are excluding
from the CJR model those beneficiaries
that are assigned to a Medicare Shared
Savings Program ACO participating in
Track 3. As discussed in the proposed
rule (81 FR 50955), these exclusions
would apply for episodes that begin on
or after July 1, 2017. We also note that
CMS will implement an on-line system
for verification of attribution to support
CJR participant hospitals in their ability
to identify such excluded beneficiaries.
We are also finalizing modifications
to the beneficiary inclusion criteria at
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§ 510.205 to indicate that, for episodes
beginning on or after July 1, 2017, the
CJR model will include Medicare
beneficiaries not prospectively assigned
to—
• An ACO in the Next Generation
ACO model;
• An ACO in a track of the
Comprehensive ESRD Care Model
incorporating downside risk for
financial losses; or
• A Shared Savings Program ACO in
Track 3.
G. Appeals Process
Currently, the CJR model provides
that participant hospitals may dispute a
calculation that involves a matter
related to payment, reconciliation
amounts, repayment amounts, or
determinations associated with quality
measures affecting payment. The
hospital is required to provide written
notice of the error, in a form and
manner specified by CMS, if the
hospital wishes to dispute such
calculation. Unless the participant
hospital provides a written notice of the
error, the CJR reconciliation report is
deemed final 45 calendar days after it is
issued, and CMS will then proceed with
the payment or repayment process as
applicable. In order to further specify
our timeline for this process, we
proposed that a timely notice of a
calculation error means a notice
received by CMS within 45 calendar
days of CMS issuing a participant
hospital’s reconciliation report.
In continuing our efforts to be clear
and concise, we proposed to add
language to our regulations highlighting
the available appeals process for a
participant hospital that receives a
notice of termination from the CJR
model. We previously described the
appeals process for notice of
termination in the CJR final rule at
§ 510.310(c), by using the notice of
termination as an example of an
exception to a participant hospital
having to provide CMS with notice of
calculation error. A notice of calculation
error continues not to be required by
participant hospitals that receive a
notice of termination, as this matter
does not involve an issue contained in,
or a calculation that contributes to, a
CJR reconciliation report. We proposed
that if a participant hospital receives
notification that it has been terminated
from the CJR model and wishes to
appeal such termination, it must
provide a written request for
reconsideration to CMS requesting
review of the termination within 10
calendar days of the notice. Following
receipt of the participant hospital’s
timely written request, CMS would have
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30 days to respond to the participant
hospital’s request for review. If the
participant hospital fails to notify CMS,
the termination would be deemed final.
We proposed to amend the
regulations at § 510.310 to reflect the
proposals, and to correct a technical
error in paragraph (d)(6) (which would
be renumbered (e)(6)). We also proposed
to delete § 510.310(a)(3) in the current
regulations as it is duplicative with
§ 510.310(a)(1). We sought comment on
our proposal.
Comment: No comments unique to
the CJR model were submitted in
response to our proposed amendments
to the appeals process in the CJR model.
Response: We appreciate the
comments surrounding the appeals
processes for the CJR model and EPMs.
We refer to section III.C.8 of this final
rule for a detailed discussion of
comments and responses in regards to
the appeal processes for these models.
Final Decision: In current CJR
regulations at § 510.310(a), a participant
hospital may dispute a calculation that
involves a matter related to
’determinations associated with quality
measures affecting payment.’ We
explain in the preamble of the CJR final
rule that determinations associated with
quality measures affecting payment may
include the calculation of the
percentiles of quality measure
performance to determine eligibility to
receive a reconciliation payment (80 FR.
73411). For consistency with the final
EPM regulation text in § 512.310(a) that
was modified in response to comments
in order to more fully identify those
determinations associated with quality
measures affecting payment that may be
disputed under this provision, we are
making a technical change in this final
rule to the regulation text at
§ 510.310(a), that a participant hospital
may dispute a calculation that involves
a matter related to the use of quality
measure results in determining the
composite quality score, or the
application of the composite quality
score during reconciliation. This does
not change the substantive standard that
we proposed and finalized in the CJR
final rule, but rather refines the
regulatory text to better reflect our final
policy. Therefore, § 510.310(a) is
finalized as follows:
• Notice of calculation error (first
level of appeal). Subject to the
limitations on review in subpart D of
Part 510, if a participant hospital wishes
to dispute calculations involving a
matter related to payment,
reconciliation amounts, repayment
amounts, the use of quality measure
results in determining the composite
quality score, or the application of the
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composite quality score during
reconciliation, the participant hospital
is required to provide written notice of
the calculation error, in a form and
manner specified by CMS.
H. Beneficiary Notification
As stated in the proposed rule, CMS
currently requires participant hospitals
and CJR collaborators to provide written
notice to any Medicare beneficiary that
meets certain criteria in § 510.205 of his
or her inclusion in the CJR model. The
notification must detail the structure of
the model, the existence of providers
and suppliers with whom the
participant hospital has a sharing
arrangement, and the fact that the
beneficiary retains the freedom of
choice. We refer readers to the CJR final
rule (80 FR 73516–73521) for further
discussion of these requirements, which
are codified under § 510.405. Although
we did not propose specific changes to
§ 510.405(a)(1), which requires that
participant hospitals provide CJR
beneficiaries with lists of all post-acute
care providers in an area, we did
proposed a parallel beneficiary
notification provision for the EPMs. As
discussed in detail in section III.G.2 of
this final rule, we received comments
on both the EPM beneficiary notification
proposals and the existing CJR provision
and we are making changes to the EPM
beneficiary notification regulations in
response to these comments. Since we
proposed to maintain alignment
between the CJR model and the EPMs to
the extent possible as referenced in
sections V.C; V.I.1; V.J.1 through V.J.4;
and V.K. of the proposed rule, we are
also making conforming changes to
§ 510.405(a)(1) for the CJR model to
match the modifications we are
finalizing for the EPMs in
§ 512.450(a)(1). Specifically, we are
revising § 510.405(a)(1) to state that as
part of discharge planning and referral,
participant hospitals must provide a
complete list of HHAs, SNFs, IRFs, or
LTCHs that are participating in the
Medicare program, and that serve the
geographic area (as defined by the HHA)
in which the patient resides, or in the
case of the SNF, IRF, or LTCH, the
geographic area requested by the
patient. This list must be presented to
CJR beneficiaries for whom home health
care, SNF, IRF, or LTCH services are
medically necessary. In addition, we are
adding the definition of area to the CJR
model definitions under § 510.2. The
definition we are adding is the same
definition that is used in the Conditions
of Participation (CoP) for discharge
planning. Area means ‘‘as defined in
§ 400.200 of this chapter, the
geographical area within the boundaries
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of a State, or a State or other
jurisdiction, designated as constituting
an area with respect to which a
Professional Standards Review
Organization or a Utilization and
Quality Control Peer Review
Organization has been or may be
designated.’’ We note that we expect the
SNF list provided to a CJR beneficiary
would also include all rural hospital
providers of SNF-level care in swing
beds in the geographic area requested by
the patient. We believe that these
changes will clarify and streamline the
requirements for the provision of the list
of post-acute care providers, as well as
reduce the burden on participant
hospitals.
In the proposed rule, we proposed to
amend § 510.405 to include all CJR
collaborators in the requirements for
delivery of beneficiary notices and to
streamline our current regulations. We
also proposed to require participant
hospitals and CJR collaborators to be
able to generate and provide to CMS
upon request a list of all beneficiaries
who received a notice, including the
type of notice and the date it was
delivered. We sought comments on all
aspects of this proposal. We also note
that we proposed, but did not
summarize in the preamble, new
language for § 510.405(b) that would
permit delivery of the hospital detailed
beneficiary notice as soon as reasonably
practicable after admission, but during
the stay and prior to discharge, when a
beneficiary’s medical condition makes
notice on admission infeasible.
The following is a summary of the
comments received and our responses.
Comment: Commenters expressed
concern that the multiple beneficiary
notifications required under CMS’
proposal would create an overload for
CJR beneficiaries, would result in
administrative burden on providers, and
would be infeasible in some cases.
Several commenters also expressed
concern about the times at which
beneficiaries must receive beneficiary
notifications from participant hospitals
or CJR collaborators, the requirement
that beneficiary notifications must be in
writing, and a participant hospital’s
ability to generate lists of all
beneficiaries that received beneficiary
notifications.
Response: We appreciate the
commenters’ feedback on our proposals.
We received similar comments for the
proposed EPM regulations for
beneficiary notification and refer
readers to III.G.3. for a detailed
summary of comments we received and
our responses on beneficiary
notification as applicable to the CJR
model. In response to these comments,
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we are modifying the notice provisions
to, among other things, permit flexibility
in the timing of notice delivery as a
result of a beneficiary’s condition and
delay until July 1, 2017 implementation
of the requirement that participant
hospitals and CJR collaborators be able
to generate a list of beneficiaries to
whom the notices have been delivered.
Comment: Several commenters
expressed concern with the current
beneficiary notification form provided
by CMS on the CJR model’s Web site.
Commenters requested that we simplify
the wording of our current forms as they
believe the notifications as written are
more sophisticated than a sixth grade
reading level, and that beneficiaries find
the policy terms discussed throughout
the beneficiary notifications confusing.
Response: We appreciate the
commenters’ feedback on the
beneficiary notification forms we have
made available for use by participant
hospitals to assist in compliance with
the regulations under § 510.405. We will
work to find ways to revise and simplify
the language in the beneficiary
notification template so that
beneficiaries can more easily
understand the model. Revised versions
of the template will be made available
on the CMS Web site soon after the
publication of this final rule.
Comment: Commenters recommended
the hospital beneficiary notification
clarify for beneficiaries that all hospitals
within the metropolitan area are
required to participate in the CJR model,
as they believe the current beneficiary
notification template implies that CJR
beneficiaries who do not want to
participate in the CJR model are able to
seek care at another provider not
participating in the CJR model.
Response: We appreciate the
commenter’s feedback. We disagree
with the commenter’s suggestion to
require that the notification state that all
hospitals within the applicable
metropolitan area are required to
participate in the CJR model, because
some hospitals in the MSA are not
required to participate in light of the
exception in § 510.100(b). Moreover,
other than participant hospitals, no
providers or suppliers are required to
participate in the CJR model or enter
into a sharing arrangement; therefore,
the CJR model does not restrict
Medicare beneficiaries’ ability to choose
any other Medicare enrolled provider or
supplier. However, to address the
commenter’s concern about what the
notice template implies, as part of our
update to the templates we will explore
making changes to provide further
information about the scope of the
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model and the hospitals that are
required to participate.
Comment: One commenter voiced
concern that the current beneficiary
notification omits outpatient therapy
providers in the list of post-acute care
options, noting that this omission could
influence a Medicare beneficiary to
believe certain treatments or services,
such as outpatient physical therapy, are
not an option for them in this model.
The commenter recommended that at a
minimum, beneficiaries should be
provided a written list of all of the local
providers from whom they can choose
to receive their rehabilitation therapy.
Response: Under current CJR
regulation in § 510.405(a)(1) which
complement the discharge planning
CoP, participant hospitals must inform
beneficiaries of all Medicare
participating post-acute care providers
in an area and must identify those postacute care providers with whom they
have sharing arrangements. By postacute care providers we do not mean
providers of outpatient therapy services,
which are unlikely to be the initial
provider/supplier that furnishes
rehabilitation services to a CJR
beneficiary immediately following
discharge from the anchor
hospitalization. We mean HHAs, SNFs,
IRFs, and LTCHs where post-acute care
services may be covered under Part A
following hospital discharge. Similar to
the discharge planning CoP, we believe
the lists provided to CJR beneficiaries at
discharge should be of those
institutional post-acute providers that
provide Part A-covered services if
institutional post-acute care is
medically necessary for the beneficiary
immediately following hospital
discharge in order to specifically
safeguard beneficiary freedom of choice
of post-acute care providers under the
CJR model and establish transparency
about financial relationships between
post-acute care providers and CJR
hospital participants. Under the CJR
model, we do not require complete lists
of other providers or suppliers of
outpatient therapy or any other Part B
services that a beneficiary might need
during the 90-day post-discharge
episode duration to be provided by the
CJR participant hospital to the
beneficiary, just as the discharge
planning CoP does not require lists of
other providers or suppliers for follow
up Part B-covered services to be
provided to a patient.
However, as discussed in this section,
in response to comments, we are
modifying the requirements of
§ 510.405(a)(1) to provide greater clarity
about the complete list of post-acute
care providers to be provided to a CJR
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beneficiary. Under revised
§ 510.405(a)(1), participant hospitals
will be required to provide, to
beneficiaries for whom home health
care, SNF, IRF, or LTCH services are
medically necessary, a complete list of
participating HHAs, SNFs, IRFs, or
LTCHs that serve the geographic area in
which the patient resides (as defined by
the HHA) or in the case of SNFs, IRFs,
or LTCS, the area requested by the
patient. This revised provision makes
clear that CJR participant hospitals need
only provide a complete list of HHAs,
SNFs, IRFs, or LTCHs to a CJR
beneficiary if one of these types of postacute care services is medically
necessary and, in that case, only a list
of those post-acute care providers that
furnish the medically necessary level of
services. In situations where home
health care, SNF, IRF, or LTCH services
are not medically necessary
immediately following discharge, CJR
participant hospitals may provide
recommendations to CJR beneficiaries
about follow up services immediately
following discharge and thereafter
during the CJR episode, including
outpatient therapy services, consistent
with all existing laws and regulations.
However, we believe it is unlikely that
outpatient therapy services immediately
following hospital discharge would be a
medically appropriate option for most
CJR beneficiaries, who would likely be
homebound for a period of time and
require more comprehensive post-acute
care services rather than outpatient
therapy services.
Comment: A commenter currently
participating in the CJR model stated
that in cases of emergent fracture, the
requirement to provide the beneficiary
notification at the time of admission has
presented significant operational
hurdles, in that these patients upon
admission are unable to comprehend
the notification and that providing the
notification to accompanying family
members has resulted in confusion. This
commenter recommended that in cases
of emergent fracture, the notification
should be provided to patients after the
surgery, to avoid causing additional
confusion and distress for patients
experiencing a traumatic event.
Response: We appreciate the
commenter’s feedback. We note that in
the case of an emergent patient
immediate notification of model
participation is not always appropriate,
and we note that the first priority of the
participant hospital should be providing
medical care to the beneficiary. For this
reason, we proposed to modify the
regulation at § 510.405(b) to permit the
notification to be provided to the
beneficiary or his or her representative
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as soon as is reasonably practicable but
no later than discharge from the
participant hospital accountable for the
CJR episode, in cases where the
patient’s condition makes it infeasible to
deliver the notice at admission. We
believe that providing the participant
hospital this flexibility will avoid
causing additional confusion for the
beneficiaries and his or her family
members. For the same reasons, we are
modifying the proposed requirements
for CJR collaborator delivery of notices
to permit similar flexibility in
consideration of a patient’s condition.
Final Decision: After consideration of
the public comments received on EPM
and CJR beneficiary notification
policies, we are finalizing our proposal
to modify § 510.405, with additional
modifications. Specifically, we are
finalizing changes to § 510.405(a)(1) to
specify when a complete list of certain
post-acute care providers must be
provided to the CJR beneficiary as part
of discharge planning and referral. We
are also finalizing changes to
§ 510.405(b) to streamline the
requirements for required beneficiary
notification and to reduce provider
burden and provide additional
flexibilities. These changes are effective
as of the effective date of this final rule.
Since we are adding to the list of CJR
collaborators, as discussed in section
V.J.1.a. of the proposed rule and in this
final rule, we proposed to amend the
beneficiary notifications requirements at
§ 510.405(b) to account for these
additional types of CJR collaborators.
We are finalizing these proposals with
modifications to clarify when
beneficiary notifications must be
provided to beneficiaries, and to address
specific requirements for PGPs,
NPPGPs, TGPs, members of the PGP,
members of the NPPGP, members of the
TGP, ACOs, ACO participants, and ACO
providers/suppliers. These
modifications are made in response to
comments on the proposed changes to
§ 510.405(b) and the corresponding
proposals for the EPMs that are
discussed in section III.G.3. However,
because elsewhere in this final rule we
are finalizing our proposals to permit
these new types of CJR collaborators
effective July 1, 2017, we are similarly
delaying the effective date of the
beneficiary notice requirements that
would apply to these types of CJR
collaborators. We believe this approach
will reduce confusion that could result
from imposing requirements with
respect to entities that cannot be CJR
collaborators until July 1, 2017.
We proposed to amend § 510.405(b)(4)
to reflect changes to the SNF waiver. We
did not receive any comments on this
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proposal, so we are finalizing the text as
proposed, but renumbering to
§ 510.410(b)(3). We note that we are
making conforming changes for related
cross-references in § 510.610. These
changes are effective as of the effective
date of this final rule.
To provide CJR hospitals and their
collaborators with more time to come
into compliance and to provide
consistency with the EPMs, we are
delaying until July 1, 2017 the effective
date of the requirement proposed as
§ 510.405(b)(5) to generate a list of
beneficiaries who have received
notifications upon request until July 1,
2017 and are renumbering to
§ 510.410(b)(4). Effective July 1, 2017 we
also will make certain conforming
changes to other provisions of
§ 510.405(b) to reflect this requirement.
Please refer to the Regulations Text
section at the end of this final rule for
the final regulation text language.
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I. Compliance Enforcement
We proposed numerous amendments
to the regulations in § 510.410. The
amendments are largely to address the
revisions to the CJR model to allow for
additional financial relationships and to
align terminology so that the CJR model
regulations mirror the proposed EPM
regulations at § 512.460 in order to
avoid confusion for hospitals that are
participating in CJR and one or more of
the proposed EPMs. Although our
proposed changes reflect an intent that
compliance enforcement under the CJR
model would stay mostly the same, we
proposed changes in § 510.410 to adapt
it to our proposal to amend the
regulations at § 510.500 and § 510.505,
as well as to reflect the addition of
§ 510.506. For example, we proposed to
remove the term ’collaborator
agreement’ from § 510.410 in keeping
with the proposed deletion of this
concept from § 510.500.
1. Failure To Comply
Currently, CMS may take remedial
action against a participant hospital if a
participant hospital or any of the
hospital’s CJR collaborators are
noncompliant in any of the ways listed
in § 510.410(b)(1). We proposed that
CMS may also take remedial action
against a participant hospital if any of
hospital’s related collaboration agents
and downstream collaboration agents
were noncompliant in order for CMS to
have the ability to address any
noncompliance of these collaboration
agents or downstream collaboration
agents. As discussed in section V.J.1.a.
of this final rule, the proposed addition
of ACOs as CJR collaborators, combined
with the proposed modifications of the
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financial arrangements available under
the CJR model, would allow for many
additional entities and individuals to
have financial arrangements under the
CJR model as collaborators,
collaboration agents, or downstream
collaboration agent. We believe our
compliance enforcement must give us
the authority to ensure that all such
entities and individuals are advancing
the goals of the CJR model, such as
maintaining access to care. We believe
that CJR participant hospitals should
ensure that their sharing arrangements,
the distribution arrangements of their
collaborators, and the downstream
distribution arrangements of their
collaboration agents comply with the
model requirements and safeguard
program integrity. Therefore, we
proposed that CMS may take remedial
actions against the participant hospital
if any collaboration agent of such
participant hospital’s CJR collaborators,
or any downstream collaboration agent
of such CJR collaboration agent is not
compliant with applicable requirements
in any of the ways listed in
§ 510.410(b)(1). Further, we proposed
that CMS may take remedial actions
against a participant hospital if a
participant hospital or any of the
participant hospital’s CJR collaborators,
any collaboration agent of such CJR
collaborators or any downstream
collaboration agent has signed a sharing
arrangement, distribution arrangement,
or downstream distribution arrangement
that is noncompliant with the
requirements of part 510.
We proposed to amend the
regulations at § 510.410 to include these
requirements. We sought comment on
our proposal. The following is a
summary of the comments received and
our response.
Comments: Commenters generally
supported the amendments to the
regulations concerning compliance
enforcement. However, some
commenters expressed concerns
regarding the proposal that participant
hospitals are responsible for compliance
of CJR collaborators’ collaboration
agents, and collaboration agents’
downstream collaboration agents, and
believe these requirements are
burdensome for the participant hospital,
in that participant hospitals do not have
direct contractual relationships with
collaboration agents or downstream
collaboration agents. Additionally, one
commenter expressed concern about the
proposal in § 510.410(b)(1)(ix) that CMS
may take remedial action when the
participant hospital or its related CJR
collaborator, collaboration agent, or
downstream collaboration is subject to
action involving violations of the
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531
physician self-referral law, civil
monetary penalties law, Federal antikickback statute, antitrust laws, or any
other applicable Medicare laws, rules,
or regulations that are relevant to the
CJR model. The commenter stated that
violations of any other applicable
Medicare laws, rules, or regulations that
are relevant to CJR model is overly
broad and instead, CMS should apply a
reasonable knowledge standard to the
participant hospital’s awareness of a
collaborator’s involvement in such
matters. Commenters also requested that
CMS provide in the final rule examples
of actions that are not clear violations of
existing health care fraud and abuse
statutes.
Response: We received similar
comments and recommendations from
commenters for the proposed EPMs
compliance enforcement section. Given
the proposed amendments to the CJR
model regulations for compliance
enforcement at § 510.410 mirror the
proposed EPM regulations at § 512.460,
we refer readers to section III.F.2. for a
detailed explanation of our responses as
they relate to the CJR model as well as
the EPMs.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposals in § 510.410 for
compliance enforcement, with
modifications to delete as redundant the
proposal to amend § 510.410(b)(vi) to
separately authorize CMS to take
remedial action based on noncompliance with requirements specified
in § 510.120(b). We are also clarifying
that the 25 percent that CMS may add
to the repayment amount under certain
conditions as set forth in existing
§ 510.410(b)(3) is a penalty.
Additionally, since changes to the
financial arrangement provisions
discussed in V.J. will not be effective
until July 1, 2017, we are also making
the amendments to related sections
effective July 1, 2017 to avoid confusion
and preserve the existing CJR
regulations until these changes take
effect.
J. Financial Arrangements Under the
CJR Model
Currently, participant hospitals may
engage in financial arrangements under
the CJR model. The arrangements
published in the CJR final rule (80 FR
73412 through 73437) allow participant
hospitals and providers and suppliers
caring for CJR beneficiaries to share in
the financial risks and rewards under
the CJR model, to engage in care
redesign and CJR beneficiary care
management, and to establish close
partnerships with these individuals and
entities to promote accountability for
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the quality, cost, and overall care for
CJR beneficiaries. In order to ensure that
goals of the CJR model are met, and to
ensure program integrity and protect
from abuse, the CJR model has many
requirements for financial arrangements.
We proposed a full replacement for the
prior CJR regulations for financial
arrangements §§ 510.500 and § 510.505
in order to streamline and consolidate
our regulations in line with the
proposed financial arrangements for the
EPMs at § 512.500 and § 512.505. Our
proposals reflected changes from the
current CJR model regulations that
generally fell into the following four
categories:
• Removing duplication of
requirements in similar provisions.
• Streamlining and reorganizing the
provisions for clarity and consistency.
• Providing additional flexibility in
response to feedback from CJR
participant hospitals and other
stakeholders.
• Expanding the scope of financial
arrangements available under the
model.
Many of our proposed changes were
largely organizational in nature, not
changes to policy or requirements;
however, in several cases we proposed
new financial arrangements policies
and/or requirements for the CJR model.
We discuss these policies in detail later
in this section and we also refer readers
to section III.I. of this final rule for
further discussion and rationale behind
our proposed approach.
We proposed that all amendments to
regulations discussed in this section V.J.
would be effective beginning July 1,
2017, in order to align with the
beginning of the first performance year
of the proposed EPMs. We sought
comment on all proposals discussed
further in this section.
The following is a summary of the
comments received and our responses.
Comment: We received several
comments for both the CJR model and
EPM in regards to the immediate need
for waivers of existing fraud and abuse
laws as well as the need for revisions to
fraud and abuse.
Response: We appreciate the
commenters’ perspectives on fraud and
abuse law reform and specific
suggestions about fraud and abuse law
waivers for CMS-led bundled payment
models, including the CJR model and
the EPM. As we explain in section
III.I.2, these issues are beyond the scope
of this rulemaking.
Comment: One commenter requested
that CMS provide a mechanism for EPM
participants and CJR participant
hospitals to ask questions about fraud
and abuse law waivers.
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Response: As we noted, section III.I.2,
waivers of fraud and abuse laws are
outside the scope of this rulemaking.
We note that the public may contact
CMS with programmatic questions
related to the EPM and CJR model by
emailing epm@cms.hhs.gov and cjr@
cms.hhs.gov, respectively.
We did not receive any comments on
our proposal that all amendments to
regulations discussed in this section V.J.
would be effective beginning July 1,
2017, in order to align with the
beginning of the first performance year
of the proposed EPMs. Therefore, we are
finalizing this proposal without
modification. In addition, we note that
the July 1, 2017 effective date provides
CJR participants with additional time to
come into compliance with the revised
requirements and preserves the existing
CJR regulations until these changes take
effect. We refer readers to § 510.2 for
effective dates of definitions discussed
in section V.J.
1. Definitions Related to Financial
Arrangements
a. Addition to the Definition of CJR
Collaborators
In order to align with the proposed
financial arrangements for the EPMs and
to provide further opportunity for
coordination between participant
hospitals and their partners in care
redesign, we proposed to allow the
following entities to be CJR
collaborators: ACOs (with the
limitations discussed later in this
section), hospitals, and CAHs. We
believe the proposal would allow for
increased care coordination
opportunities across the spectrum of
care for beneficiaries in CJR episodes.
Given that the proposals in this section
mirror those proposed for the EPMs in
section III.I.3. of this final rule, we refer
readers to that section for further
discussion of our rationale for allowing
ACOs, hospitals, and CAHs to be
collaborators.
Many ACOs and other stakeholders
have expressed strong interest in being
collaborators in episode payment
models such as CJR. In the CJR final
rule, we did not include ACOs in the
definition of CJR collaborators,
responding that we decided to limit the
testing of gainsharing relationships to
solely those between hospitals and
providers and suppliers enrolled in
Medicare because we expected enrolled
providers and suppliers to be most
directly and specifically engaged with
the CJR participant hospital in care
redesign and episode care for
beneficiaries who had surgery at the
participant hospitals (80 FR 73417). We
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also noted that a number of scenarios
discussed by commenters to support
their request to allow ACOs to be CJR
collaborators could be achieved outside
of the context of gainsharing
relationships between the participant
hospital and ACOs. However, with the
steady growth in the number of ACOs
and ACO-attributed beneficiaries, we
have further considered the potential for
ACOs to be CJR collaborators, especially
given ACO expertise in care
coordination and accountability for the
quality and expenditures for health care
for ACO-attributed beneficiaries over an
annual period. In addition, we note that
the challenges of attributing savings and
changes in the quality of care for
beneficiaries simultaneously in CJR and
total cost-of-care models or programs,
such as ACOs, remain not fully
resolved, as discussed in section III.D.6.
of this final rule.
We proposed that ‘‘ACOs,’’ meaning
accountable care organizations, as
defined at § 425.20, that participate in
the Medicare Shared Savings Program
and is not in Track 3, be permitted to
be CJR collaborators. The proposal
would allow locally variable financial
arrangements that could account for the
way CJR episode care is coordinated and
managed in communities, and ensure
that entities with appropriate skills and
experience are permitted to share in the
risks and rewards with participant
hospitals. Our proposal would not allow
any entities that are not providers or
suppliers to be CJR collaborators other
than ACOs. Like providers and
suppliers, ACOs are regulated by CMS.
We can verify that these ACOs meet
current Shared Savings Program
requirements such that they are suitable
for a role as CJR collaborators.
We also proposed to allow participant
hospitals to enter into financial
arrangements with other hospitals and
CAHs that care for CJR beneficiaries. We
believe it is important to allow
participant hospitals to enter into
financial arrangements with other
hospitals and CAHs that care for CJR
beneficiaries, in order to align the
financial incentives of such other
hospitals and CAHs with the CJR
model’s goals of improving the quality
and efficiency of CJR episodes and to
align with the proposed financial
arrangements for the EPMs.
In summary, we proposed that the
following providers, suppliers, and
other entities be added to the list of
permissible CJR collaborators: ACOs,
hospitals, and CAHs.
We sought comment on our proposal
to include ACOs, hospitals, and CAHs
in the definition of CJR collaborators.
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The following is a summary of the
comments received and our responses.
Comment: Several commenters
requested clarification about whether
certain groups of health care
professionals that do not include
physicians could be CJR collaborators.
The commenters requested that, in
addition to PGPs, groups of certified
registered nurse anesthetists (CRNAs),
advanced practice registered nurses
(APRNs), outpatient speech-language
pathologists, physical therapists, and
other qualified licensed healthcare
professionals who are not physicians, be
permitted to be CJR collaborators. One
commenter explained that these groups
are identified by a TIN.
A number of commenters pointed out
that while the proposed rule specifically
listed PGPs as eligible to be CJR
collaborators, CMS’ proposal did not
separately list groups of physical
therapists or other therapists as eligible
to be CJR collaborators. One commenter
asserted that allowing only individual
therapists to be CJR collaborators and
excluding therapy practice groups from
entering into sharing arrangements with
EPM participants is shortsighted
because rehabilitation therapy practices
and independent therapists are likely to
be significant contributors to SHFFT
episodes. The commenters requested
that CMS clarify the regulations to
explicitly permit groups of therapists to
enter into sharing arrangements with
participant hospitals. One commenter
further proposed that once a therapy
practice group contracts with a hospital
as a collaborator, it should be up to the
practice group to ensure that financial
exchanges with the participant hospital
were attributed to the physical
therapists who directly furnished
services to CJR beneficiaries.
Response: We appreciate the interest
of the commenters in ensuring groups of
nonphysician practitioners and groups
of therapists have the same
opportunities to be CJR collaborators
that we proposed for PGPs, as well as
their interest in allowing financial
exchanges with their members who
furnished services to CJR beneficiaries.
Under our current regulation,
individual nonphysician practitioners
are permitted to be CJR collaborators.
Individual therapists are also permitted
to be collaborators to the extent that
they fall within the collaborator
category in the current CJR regulations
for provider or supplier of outpatient
therapy services. As collaborators, these
individuals would be eligible to receive
gainsharing payments from participant
hospitals. Moreover, our existing
definition of proposal defined a PGP
member includes a physician,
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nonphysician practitioner or therapist
who is an owner or employee of a PGP
who has reassigned to the PGP his or
her right to receive Medicare payments.
Accordingly, as PGP members, these
nonphysician practitioners and
therapists would be eligible for
distribution payments and downstream
distribution payments from a PGP. We
agree with the commenters that because
the CJR regulations and our proposed
revisions to these regulations addressed
the role of PGPs without reference to
other types of groups, we left some
uncertainty about whether groups
without a physician owner or employee
are eligible to be CJR collaborators and
whether under our proposals such
groups would be permitted to enter into
distribution arrangements or
downstream distribution arrangements
with their members. We also agree with
the commenters that our provision
allowing providers and suppliers of
outpatient therapy services to be CJR
collaborators is potentially unclear,
because this term does separately
identify therapists in private practice or
groups of therapists in private practice
on the list of CJR collaborators, as does
our regulatory provision regarding
physicians and PGPs. We also
appreciate the commenters’ uncertainty
associated with the fact that we did not
address whether a collaborator that was
a therapy group practice would be
permitted to enter into distribution
arrangements or downstream
distribution arrangements with their
members, given that we did specify this
in the language that we proposed for
PGPs.
We do not believe it would be
appropriate to allow a group of licensed
health care professionals to be CJR
collaborators if that group consists
solely of individuals who are not among
the categories of individuals that may be
CJR collaborators. However, we believe
that if a category of individuals is
eligible to be CJR collaborators, then
Medicare-enrolled groups that include
such individuals should also be
permitted to be collaborators. Further,
we believe that such groups should also
be permitted to enter into distribution
arrangements or downstream
distribution arrangements with their
members. We clarify these policies
through this final rule.
Groups of nonphysician practitioners
that do not include a physician are not
included in the category of PGPs that
are on the current list of CJR
collaborators. However, we believe
these groups of nonphysician
practitioners should be permitted to be
CJR collaborators, just as we allow both
individual physicians and nonphysician
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practitioners to be CJR collaborators. We
also believe these groups of
nonphysician practitioners should be
treated similarly to PGPs with regard to
their ability to engage in distribution
arrangements and downstream
distribution arrangements with their
members, consistent with our treatment
of nonphysician practitioners who are
PGP members. Therefore, we are adding
to the list of entities that are eligible to
be CJR collaborators a nonphysician
practitioner group practice (NPPGP),
defined as ‘‘an entity that is enrolled in
Medicare as a group practice, includes
at least one owner or employee who is
a nonphysician practitioner, does not
include a physician owner or employee,
and has a valid and active TIN.’’ The
requirements for sharing arrangements,
distribution arrangements, and
downstream distribution arrangements
for NPPGPs and NPPGP members are
discussed in the sections of this final
rule that address our policies for these
arrangements.
We further believe that our provisions
allowing a provider or supplier of
outpatient therapy services to be a CJR
collaborator should be modified to
provide greater clarity about the
providers and suppliers of outpatient
therapy services that can be CJR
collaborators. The Medicare Claims
Processing Manual, Chapter 5, Part B
Outpatient Rehabilitation and CORF/
OPT Services, Section 10 lists the
following Medicare-enrolled providers
and suppliers that can submit claims for
outpatient therapy services: SNF;
outpatient hospital; CAH; HHA;
outpatient physical therapy provider
(OPT), otherwise known as
rehabilitation agency; comprehensive
outpatient rehabilitation facility (CORF);
physician; nonphysician practitioner;
and physical or occupational therapist
or speech-language pathologist in
private practice.136 We note that the list
of CJR collaborators in the current
regulations already includes, SNFs,
HHAs, physicians, and nonphysician
practitioners so their inclusion as
collaborators under the definition of
provider or supplier of outpatient
therapy services is duplicative.
Therefore, rather than maintaining a
definition of provider of outpatient
therapy services which would have
included all providers and suppliers of
outpatient therapy services, we believe
it is clearer to specify individually on
the list of CJR collaborators all the types
of Medicare-enrolled providers and
suppliers that can bill Medicare for
136 https://www.cms.gov/Regulations-andGuidance/Guidance/Manuals/downloads/
clm104c05.pdf.
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outpatient therapy services. Thus, we
are defining a new term therapist in
private practice as ‘‘a therapist that
either: complies with the special
provisions for services furnished by
physical therapists in private practice in
§ 410.60(c) of this chapter; or complies
with the special provisions for services
furnished by occupational therapists in
private practice in § 410.59(c) of this
chapter; or complies with the special
provisions for services furnished by
speech-language pathologists in private
practice in § 410.62(c) of this chapter.’’
We are adding therapist in private
practice to the list of CJR collaborators,
which ensures that all individual
suppliers of outpatient therapy services
are on the CJR collaborator list. In
addition, we are revising our definition
of provider of outpatient therapy
services to mean ‘‘an entity that is
enrolled in Medicare as a provider of
therapy services and furnishes one or
more of the following: outpatient
physical therapy services as defined in
§ 410.60 of this chapter; outpatient
occupational therapy services as defined
in § 410.59 of this chapter; outpatient
speech-language pathology services as
defined in § 410.62 of this chapter.’’
Under this revised definition, provider
of outpatient therapy services now
includes only those entities that enroll
in Medicare specifically as a provider of
outpatient physical therapy/
occupational therapy/speech-language
pathology services, and we are revising
the list of CJR collaborators to use this
defined term in place of ‘‘provider or
supplier of outpatient therapy services.’’
Finally, in addition to finalizing our
proposal to add hospitals and CAHs to
the list of CJR collaborators, we are
adding CORFs to the list of CJR
collaborators because it is the only other
type of provider that can furnish
outpatient therapy services that is not
included on the CJR collaborator list
under our new and revised terms. Thus,
with the addition of therapy group
practices as discussed specifically
below, in total, these changes to the
definitions and supplements to the list
of CJR collaborators clarify which
individuals and entities may be CJR
collaborators by separately specifying
each type of supplier and provider of
outpatient therapy services that is
eligible to be a CJR collaborator.
With respect to the specific interest of
commenters in therapy practice groups
being eligible to be CJR collaborators
that can share payments under CJR
financial arrangements with their
members, we agree with the
commenters that such groups should be
permitted to be CJR collaborators and to
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enter into distribution arrangements and
downstream distribution arrangements
with their members, consistent with our
treatment of PGPs and NPPGPs. Thus,
we are defining therapy group practice
(TGP) as ‘‘an entity that is enrolled in
Medicare as a therapy group in private
practice, includes at least one owner or
employee that is a therapist in private
practice, does not include an owner or
employee who is a physician or
nonphysician practitioner, and has a
valid and active TIN’’ and adding TGP
to the list of CJR collaborators. The
requirements for sharing arrangements,
distribution arrangements, and
downstream distribution arrangements
for TGPs and TGP members are
discussed in the sections of this final
rule that address our policies for these
arrangements.
We are finalizing, with the
modifications discussed, the definition
of CJR collaborator in § 512.2 to mean an
ACO or one of the following Medicareenrolled individuals or entities that
enters into a sharing arrangement:
(1) SNF.
(2) HHA.
(3) LTCH.
(4) IRF.
(5) Physician.
(6) Nonphysician practitioner.
(7) Therapist in private practice.
(8) CORF.
(9) Provider of outpatient therapy
services.
(10) PGP.
(11) Hospital.
(12) CAH.
(13) NPPGP.
(14) TGP.
Comment: A number of commenters
expressed support for CMS’ proposed
definition of ‘‘CJR collaborators,’’
including the proposed addition of
ACOs, hospitals, and CAHs to the types
of collaborators that were previously
adopted for the CJR model. The
commenters claimed that allowing
additional health care providers,
suppliers, and ACOs to be CJR
collaborators would further encourage
robust care coordination across the CJR
episode. Several commenters asserted
that by recognizing the expertise that
ACOs may offer participant hospitals as
CJR collaborators with regard to
managing the cost and quality of care
that Medicare beneficiaries receive,
ACOs will be able to use their
substantial expertise and resources to
contribute to the CJR model’s dual goals
of limiting spending and increasing
quality. One commenter further
commended CMS for making the list of
CJR collaborators exhaustive and not
including third party conveners, who
the commenter believes lack a
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commitment to patients, local providers,
or their community.
In contrast, some commenters
expressed disappointment that the list
of CJR collaborators did not include
entities such as pharmaceutical
companies; medical device companies;
medical technology companies; social
services aging networks; and other third
parties, such as the types of convening
organizations participating in other
CMMI models. Several commenters
believe that were medical device and
pharmaceutical manufacturers allowed
to be CJR collaborators, those
manufacturers may make meaningful
contributions to the success of the CJR
model by ensuring their products are
used appropriately; aligning financial
and other incentives to improve patient
outcomes; demonstrating the value of
their products; and reducing costs.
Other commenters who favored adding
medical technology companies as CJR
collaborators asserted that medical
technology companies can make a
significant, positive impact on care
redesign and cost containment as well
as provide integrated data analytic
infrastructure and services to optimize
care and to achieve quality goals. A few
commenters suggested that CMS should
expand the list of potential CJR
collaborators to include non-provider or
non-supplier entities that have a track
record of providing Medicare providers
and suppliers participating in other
models with support services such as
care redesign, data analytics, and
general program support, as well as
community-based organizations that are
well-equipped and efficient in
providing social and supportive services
that help beneficiaries stay out of the
hospital. Several commenters also
encouraged CMS to include all APM
entities as CJR collaborators, reasoning
that APM entities are similar to ACOs in
that they are a legal entity that is
separate from its participants.
Additionally, one commenter
recommended that Next Generation
ACOs be included in the definition of
ACOs that are on list on CJR
collaborators, so the Next Generation
ACO may act on behalf of its providers
to enter into financial arrangements
with participant hospitals for
beneficiaries not assigned to the ACO.
The commenter explained that not
including Next Generation ACOs in the
definition of ACOs that CMS proposed
could be CJR collaborators will require
ACO participants and ACO providers/
suppliers of the Next Generation ACO to
enter in CJR sharing arrangements on
their own without the Next Generation
ACO to represent them.
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Finally, one commenter shared its
perspective that CMS should not restrict
the definition of CJR collaborators
because such an approach discourages
the introduction of new entities and
individuals in the healthcare market.
The commenter requested that CMS
allow market forces to shape the
innovation of CJR participants and their
community partners in order to
determine the financial partnerships
that would be most beneficial to
achieving the overarching goals of the
CJR model. The commenter asserted that
being too prescriptive regarding the
individuals and entities that can and
cannot enter into financial arrangements
under the CJR model would not allow
for new organizations to develop in the
market that may have the potential to
generate substantial cost savings for
participant hospitals.
Response: We appreciate the support
of the commenters for our proposed list
of the types of individuals and entities
that can be CJR collaborators, including
our proposal to include hospitals,
CAHs, and ACOs that would expand the
list beyond current CJR collaborators
adopted in the CJR Final Rule (80 FR
73418).
We note that some of the potential
contributions, such as integrating the
data analytic infrastructure and services
to optimize care to achieve quality
goals, that were suggested by
commenters as reasons to allow third
parties, such as pharmaceutical, medical
device, and medical technology
companies as well as other types of
convening organizations participating in
other CMMI models, to be CJR
collaborators can be achieved outside of
the context of sharing arrangements
through other relationships between the
participant hospital and those entities.
In response to the specific requests that
we include APM entities on the list of
CJR collaborators, given that an APM
entity, as defined in § 414.1305, means
an entity that participates in an APM or
payment arrangement with a nonMedicare payer through a direct
agreement or through Federal or State
law or regulation, we believe that
adding all APM entities to the list of CJR
collaborators would be overly expansive
and risk loosening the clinical link
between the CJR collaborator,
participant hospital, and beneficiary
that we believe is important for
improving the quality and reducing the
cost of care under the model. With the
exception of ACOs, PGPs, NPPGPs, and
TGPs, we continue to believe that any
CJR collaborator that receives a
gainsharing payment must have
furnished a billable service included in
the episode to a CJR beneficiary and that
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the payment arrangements for
gainsharing payments must be
substantially based on the quality of
care and the provision of CJR activities.
In the case of ACOs, PGP, NPPGPs, and
TGPs that are CJR collaborators, we
require that the entity itself must have
contributed to CJR activities and been
clinically involved in the care of
beneficiaries in order to be eligible to
receive a gainsharing payment or be
required to make an alignment payment.
At this point we are not convinced any
APM entities could meet these
eligibility criteria, other than ACOs. We
also do not agree with the commenter
who recommended that we not restrict
the definition of CJR collaborators to
any specific individuals or entities. We
believe it is important for participant
hospitals to engage CJR collaborators
that have a commitment to their local
communities, local providers, and
Medicare beneficiaries in order to create
the greatest potential for sustained
improvements in quality and reductions
in cost under the CJR.
We appreciate the commenter’s
suggestion that Next Generation ACOs
be included in the definition of ACOs
that are on the list of CJR collaborators,
so the Next Generation ACO may act on
behalf of its ACO participants and ACO
providers/suppliers to establish sharing
arrangements with participant hospitals
for beneficiaries not assigned to the
ACO. While we understand that the
Next Generation ACO would like to
enter into a CJR sharing arrangement as
a CJR collaborator on behalf of its
providers and suppliers, to be eligible to
receive a gainsharing payment or be
required to make an alignment payment
under the sharing arrangement the Next
Generation ACO itself must have
contributed to CJR activities and been
clinically involved in the care of
beneficiaries through activities such as
providing care coordination services to
beneficiaries during and/or after
inpatient admission; engaging with a
participant hospital in care redesign
strategies, and actually performing a
role in implementing such strategies,
that are designed to improve the quality
of care and reduce spending for the CJR
episodes; or in coordination with
providers and suppliers (such as ACO
participants, ACO providers/suppliers,
the participant hospital, and post-acute
care providers) implementing strategies
designed to address and manage the
comorbidities of beneficiaries. We are
unclear of the role the Next Generation
ACO itself would play in the care of
beneficiaries that are not assigned to the
ACO, beyond serving as a contracting
agent for its ACO participants and ACO
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providers/suppliers. We further believe
that such an arrangement would require
distinguishing activities on behalf of
beneficiaries assigned to the ACO who
are excluded from CJR episodes and
beneficiaries not assigned to the ACO
who are included in CJR episodes, and
such distinctions could create confusion
for beneficiaries, providers, and
suppliers, as well as administrative
complexity for the Next Generation
ACO. Therefore, we do not believe it
would be appropriate to include Next
Generation ACOs in the definition of
ACOs that may be CJR collaborators.
Finally, we note that as discussed in
section III.D.6.c.(3) of this final rule, we
are additionally finalizing the exclusion
of beneficiaries from CJR episodes who
are prospectively assigned to a Shared
Savings Program ACO in Track 3.
Therefore, for consistency with our
policy for Next Generation ACOs whose
assigned beneficiaries are also excluded
from CJR episodes, we are excluding
Shared Savings Program ACOs in Track
3 from the definition of ACOs that may
be CJR collaborators. Thus, we are
modifying our definition of ACO to read
‘‘ACO means an accountable care
organization, as defined at § 425.20 of
this chapter, that participates in the
Shared Savings Program and is not in
Track 3.’’ We emphasize that no CJR
policy precludes providers or suppliers
who are ACO participants or ACO
providers/suppliers in a Next
Generation ACO from entering into a
sharing arrangement with a participant
hospital on their own, provided they are
on the list of CJR collaborators.
In summary, at this time we will not
adopt a final policy that includes
additional entities or individuals that
are not providers or suppliers beyond
those we proposed to be CJR
collaborators. We selected acute care
hospitals as the financially responsible
entity for the CJR model because we are
interested in evaluating the impact of
bundled payment and care redesign
across a broad spectrum of hospitals
with varying levels of infrastructure and
experience in entering into risk-based
payment arrangements. We believe that
it is most appropriate to identify a single
type of provider to bear financial
responsibility for making repayment to
CMS under the CJR model. Given that
hospitals perform a central role in
coordinating episode-related care and
ensuring smooth transitions for
beneficiaries, this role factored in our
decision to select IPPS hospitals as the
financially responsible entity for this
model. Under this structure, we believe
that limiting the testing of gainsharing
relationships to solely those between
participant hospitals, certain Shared
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Savings Program ACOs, and providers
and suppliers enrolled in Medicare is
most appropriate because we expect
enrolled providers and suppliers to be
most directly and specifically engaged
with the participant hospitals in care
redesign and CJR episode care for
beneficiaries. While we recognize that
Shared Savings Program ACOs are not
providers or suppliers, Medicare has a
close relationship with such ACOs,
which are regulated by CMS, so we can
verify that these ACOs meet current
Shared Savings Program requirements
that make them suitable for a role as CJR
collaborators. Further, by including
such ACOs on the list of CJR
collaborators, we are permitting locally
variable financial arrangements that
could account for the way care in CJR
episodes is coordinated and managed in
communities, and ensure that entities
with appropriate skills and experience
are permitted to share the CJR’s risks
and rewards with participant hospitals.
We are finalizing in § 510.2 the
definition of ACO, with modification to
mean an accountable care organization,
as defined at § 425.20 of this chapter,
that participates in the Shared Savings
Program and is not in Track 3.
Comment: One commenter requested
clarification about whether outpatient
speech-language pathologists are
considered providers of outpatient
therapy services and, therefore, eligible
to be CJR collaborators.
Response: We appreciate the
opportunity to clarify that speechlanguage pathologists are eligible to be
CJR collaborators under the existing CJR
regulations if they meet the definition of
provider of outpatient therapy.
Moreover, as discussed previously in
this section, speech-language
pathologists in private practice are
included under the new definition of
therapist in private practice when they
are therapists that comply with the
special provisions for services furnished
by speech-language pathologists in
private practice in § 410.62(c). In
addition, a group of speech-language
pathologists in private practice is
included under the new definition of
TGP when the group is entity that is
enrolled in Medicare as a therapy group
in private practice, includes at least one
owner or employee that is a therapist in
private practice, does not include an
owner or employee who is a physician
or nonphysician practitioner, and has a
valid and active TIN. Therefore, under
the revisions that will take effect on July
1, 2017, we will clarify that both
therapists in private practice and TGPs
may be CJR collaborators and therefore
make clearer that individual speechlanguage pathologists in private
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practice, as well as speech-language
pathology groups in private practice, are
eligible to be CJR collaborators.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposals in § 510.2 for
the definition of CJR collaborator and
other terms used in that definition, with
modification to revise the definitions of
provider of outpatient therapy services;
and ACO; create new definitions for
CORF, therapist in private practice,
NPPGP, and TGP; and include these
additional individuals and entities on
the list of CJR collaborators. With the
exception of the new definition of
therapist in private practice, these
revised definitions will be effective July
1, 2017. CJR collaborator means an ACO
(as defined in § 510.2) or one of the
following Medicare-enrolled individuals
or entities that enters into a sharing
arrangement:
(1) SNF.
(2) HHA.
(3) LTCH.
(4) IRF.
(5) Physician.
(6) Nonphysician practitioner.
(7) Therapist in private practice.
(8) CORF.
(9) Provider of outpatient therapy
services.
(10) PGP.
(11) Hospital.
(12) CAH.
(13) NPPGP.
(14) TGP.
b. Deletion of Term ‘Collaborator
Agreements’
In order to reduce duplicative
language in § 510.500 and streamline
the regulations for financial
arrangements between CJR participant
hospitals and CJR collaborators, we
proposed to delete the term
‘‘collaborator agreement’’ in § 510.2 and
transition the requirements of
collaborator agreements to requirements
of sharing arrangements. Overall, the
proposal would simplify and streamline
the requirements for sharing
arrangements under CJR, allow CMS to
align the CJR financial arrangements
with those of the proposed EPMs, and
provide consistent regulations to
potential parties that may participate in
both the CJR model and the EPMs.
We recognize that current participant
hospitals and CJR collaborators already
have existing collaborator agreements.
However, as noted further in this
section, although we proposed to
change several terms, the proposed
sharing arrangements policies are
largely similar to the current policies
regarding collaborator agreements.
We sought to amend the regulations at
§ 510.2 by deleting the term collaborator
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agreement in Part 510. We sought
comment on our proposals.
The following is a summary of the
comments received and our responses.
Comment: Several commenters
requested clarification as to whether the
proposed changes to financial
arrangements in the CJR model would
require CJR participant hospitals to
review their current financial
arrangements and modify the
terminology to reflect the changes if
they are finalized. One commenter
acknowledged CMS’ efforts to providing
consistency between the CJR model and
the EPM, but claimed that requiring CJR
participant hospitals to review their
financial arrangements would constitute
a significant burden on CJR participant
hospitals.
Response: The proposed changes to
CJR financial arrangements in
§§ 510.500 and 510.505 would require
CJR participant hospitals, and any other
individual or entity involved in a
financial arrangement under these
regulations, to review the changes to the
requirements of the CJR model, and to
revise their financial arrangements and
applicable terminology if necessary.
While we acknowledge that the
amendments to the financial
arrangements requirements in the CJR
model will create some short-term
administrative burden on CJR
participants and other parties involved
in these arrangements, we believe that
the revised CJR model regulations
streamline and clarify the requirements
for all parties and will help facilitate
compliance with the requirements of the
CJR model. In addition, the major policy
changes, such as allowing ACOs to be
collaborators and adopting the term CJR
activities as the comprehensive
framework for capturing both direct
patient care and care redesign for CJR
episodes, received widespread support
from commenters. We recognize the
time that CJR participant hospitals and
CJR collaborators with financial
arrangements under the existing
requirements will need to review the
amended requirements finalized in this
final rule and revise their existing
financial arrangements in order to be
compliant. As such, the amended
requirements for financial arrangements
in the CJR model will be effective on
July 1, 2017, the same date when the
first performance year for the EPM
begins. Therefore, CJR participant
hospitals and CJR collaborators will
have knowledge of the federal
requirements for CJR financial
arrangements approximately 6 months
prior to their effective date in the CJR
model, which we believe is sufficient to
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review and revise their existing
financial arrangements if necessary.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal without
modification to delete the term
collaborator agreement effective July 1,
2017.
c. Addition of CJR Activities
We proposed to use the term ‘‘CJR
activities’’ to identify certain obligations
of parties in a sharing arrangement that
are currently described as ‘‘changes in
care coordination or delivery’’ in the
CJR regulations governing the contents
of the written agreement memorializing
the sharing arrangement. In addition to
the quality of care provided during
episodes, we believe the activities that
would fall under this proposed
definition of CJR activities would
encompass the totality of activities upon
which it would be appropriate for
certain financial arrangements under the
CJR model to be based in order to value
the contributions of providers,
suppliers, and other entities toward
meeting the CJR model’s goals of
improving the quality and efficiency of
episodes. Therefore, for purposes of
financial arrangements under the CJR
model, we proposed to define CJR
activities as activities related to
promoting accountability for the quality,
cost, and overall care for CJR
beneficiaries, including managing and
coordinating care; encouraging
investment in infrastructure, enabling
technologies, and redesigned care
processes for high quality and efficient
service delivery; the provision of items
and services during a CJR episode in a
manner that reduces costs and improves
quality; or carrying out any other
obligation or duty under the CJR
models. Sections V.J.2. through V.J.4. of
this final rule provide more detail as to
how the addition of CJR activities affect
other proposals in this part.
We proposed to amend § 510.2 by
adding the term ‘CJR activities.’ We
sought comment on our proposal to add
CJR activities as an inclusive and
comprehensive framework for capturing
direct care and care redesign for CJR
episodes that contribute to improving
the quality and efficiency of these
episodes. We received comments
regarding both CJR activities and EPM
activities and refer readers to section
III.I.4.b. of this final rule for a detailed
explanation of the comments and our
responses.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal to add the term
CJR activities, without modifications,
effective July 1, 2017.
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2. Sharing Arrangements
We believe the proposed amendments
to this section will provide participant
hospitals and CJR collaborators with
more organized, and streamlined
regulations.
a. General
With the exception of adding ‘‘past or
anticipated’’ to the selection criteria for
CJR collaborators, and replacing
‘‘collaborator agreement’’ with ‘‘sharing
arrangement’’ the following proposed
criteria are similar to the current
requirements of the CJR model as
finalized in prior regulations at
§ 510.500. In the proposed rule, we
discussed the proposed requirements for
sharing arrangements, including both
our continuation of policies we
finalized in the CJR final rule, and
several new proposals. We proposed
that participant hospitals must develop,
maintain, and use a set of written
policies for selecting individuals and
entities to be CJR collaborators, and that
such policies must include the quality
of care delivered by the potential CJR
collaborator. The selection criteria
cannot be based directly or indirectly on
the volume or value of past or
anticipated referrals or business
otherwise generated by, between or
among the participant hospital, any CJR
collaborator, any collaboration agent,
any downstream collaboration agent, or
any individual or entity affiliated with
a participant hospital, CJR collaborator,
collaboration agent, or downstream
collaboration agent. Our proposed
addition of ‘‘past or anticipated’’ does
not effect a substantive change, but
merely conforms the way the volume or
value standard is articulated in this
provision with the way that the volume
or value standard is articulated in other
provisions at § 510.500. However, by
adding ‘‘past or anticipated,’’ we make
clear that all previous and future
referrals between or among participant
hospital, any CJR collaborator, any
collaboration agent, any downstream
collaboration agent, or any individual or
entity affiliated with a participant
hospital, CJR collaborator, collaboration
agent, or downstream collaboration
agent would be encompassed. We do
not believe it would be appropriate for
sharing arrangements to be based on
criteria that include the volume or value
of past or anticipated referrals because
the sole purpose of sharing
arrangements is to create financial
alignment between participant hospitals
and CJR collaborators toward the CJR
model’s goals of improving the quality
and efficiency of episode care. Thus, we
continue to require that CJR participant
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537
hospitals select CJR collaborators based
on criteria that include the quality of
care furnished by the potential CJR
collaborator to ensure that the selection
of CJR collaborators takes into
consideration the likelihood of their
future performance in improving the
quality of episode care.
In summary, we proposed to amend
§ 510.500(a) as follows:
• A participant hospital may enter
into a sharing arrangement with a CJR
collaborator to make a gainsharing
payment, or to receive an alignment
payment, or both.
• A participant hospital must not
make a gainsharing payment or receive
an alignment payment except in
accordance with a sharing arrangement.
• A sharing arrangement must
comply with the provisions of this
section and all other applicable laws
and regulations, including the
applicable fraud and abuse laws and all
applicable payment and coverage
requirements.
• Participant hospitals must develop,
maintain, and use a set of written
policies for selecting individuals and
entities to be CJR collaborators. These
policies must contain criteria related to,
and inclusive of, the quality of care
delivered by the potential CJR
collaborator. The selection criteria
cannot be based directly or indirectly on
the volume or value of past or
anticipated referrals or business
otherwise generated by, between or
among the participant hospital, any CJR
collaborator, any collaboration agent,
any downstream collaboration agent, or
any individual or entity affiliated with
a participant hospital, CJR collaborator,
collaboration agent, or downstream
collaboration agent.
• If a participant hospital enters into
a sharing arrangement, its compliance
program must include oversight of
sharing arrangements and compliance
with the applicable requirements of the
CJR model.
We sought comment on our proposal.
We received a number of comments on
our proposal. Because the comments
and responses to our proposal for CJR
were not substantively different from
the comments and responses on
proposed § 512.500(a), we refer readers
to section III.I.4.a for a discussion of the
comments and our responses to them
Additionally, we note that the CJR
model and the EPMs’ policies
surrounding the various requirements of
financial arrangements mirror one
another. We provided in Table 46 in
section III.I.4.a. of this final rule to list
the standards related to ‘‘volume and
value’’ for EPM financial arrangements,
and here provide Table 51 below with
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the parallel information for the CJR
model.
TABLE 51—STANDARDS RELATED TO ‘‘VOLUME OR VALUE’’ FOR CJR FINANCIAL ARRANGEMENTS
Scope of volume/value
prohibition
Collaborator selection
criteria.
Yes .................
Opportunity to make or
receive a payment.
Yes .................
Cannot be based directly or indirectly on past or
anticipated referrals or business otherwise
generated by, between or among:
vi. Participant hospital
vii. Collaborator
viii. Collaboration agent
ix. Downstream collaboration agent
x. Any individual or entity affiliated with (i)–(iv)
Same as for collaborator selection criteria ..........
Alignment payment
methodology.
Yes .................
Gainsharing payment
methodology.
No ..................
Distribution and downstream distribution
payment methodologies.
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Volume/value
prohibition?
No ..................
Cannot directly account for volume or value of
past or anticipated referrals or business otherwise generated by, between or among (i)–(v)
above.
N/A—methodology must be substantially based
on quality of care and the provision of CJR activities; may consider relative amount of CJR
activities provided.
N/A—same methodology standard as for
gainsharing payments, except that amounts
distributed by a PGP to a PGP member can
also be determined in a manner that complies
with § 411.352(g) of the physician self–referral
regulations.
Final Decision: After consideration of
the public comments received, we are
finalizing effective July 1, 2017, the
proposals in § 510.500(a) for the general
requirements for CJR sharing
arrangements, with modification to
clarify that a CJR collaborator selection
criterion that considers whether a
potential collaborator has performed a
reasonable minimum number of services
that would qualify as CJR activities will
be deemed not to violate the volume or
value standard if the purpose of the
requirement is to ensure the quality of
care furnished to CJR beneficiaries. CJR
sharing arrangements must comply with
the following general provisions:
• A participant hospital may enter
into a sharing arrangement with a CJR
collaborator to make a gainsharing
payment, or to receive an alignment
payment, or both. A participant hospital
must not make a gainsharing payment or
receive an alignment payment except in
accordance with a sharing arrangement.
• A sharing arrangement must
comply with the provisions of this
section and all other applicable laws
and regulations, including the
applicable fraud and abuse laws and all
applicable payment and coverage
requirements.
• The participant hospital must
develop, maintain, and use a set of
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Citation
written policies for selecting individuals
and entities to be CJR collaborators.
These policies must contain criteria
related to, and inclusive of, the quality
of care delivered by the potential CJR
collaborator. The selection criteria
cannot be based directly or indirectly on
the volume or value of past or
anticipated referrals or business
otherwise generated by, between or
among the participant hospital, any CJR
collaborator, any collaboration agent,
any downstream collaboration agent, or
any individual or entity affiliated with
a participant hospital, CJR collaborator,
collaboration agent, or downstream
collaboration agent. A selection
criterion that considers whether a
potential CJR collaborator has
performed a reasonable minimum
number of services that would qualify as
CJR activities will be deemed not to
violate the volume or value standard if
the purpose of the criterion is to ensure
the quality of care furnished to CJR
beneficiaries.
• If a participant hospital enters into
a sharing arrangement, its compliance
program must include oversight of
sharing arrangements and compliance
with the applicable requirements of the
CJR model.
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§ 510.500(a)(3).
§ 510.500(c)(7) (gainsharing or alignment payments).
§ 510.505(b)(4) (distribution payment).
§ 510.510(b)(4) (downstream distribution payment).
§ 510.500(c)(14).
§ 510.500(c)(5) (gainsharing payments).
§ 510.505(b)(5), (6) (distribution payments).
§ 510.510(b)(5), (6) (downstream distribution
payments).
b. Requirements
Currently, there are a number of
specific requirements for sharing
arrangements under the CJR model. We
proposed to delete the term
‘‘collaborator agreements’’ and to
incorporate many of the requirements
from the existing CJR provision at
§ 510.500(c) into a streamlined
provision regarding the requirements for
‘‘sharing arrangements.’’ We discuss the
proposal in detail further in this section
in order to ensure current and future
participant hospitals and CJR
collaborators are aware of all
requirements that would apply under
these proposed revisions.
We proposed that the sharing
arrangement must be in writing, signed
by the parties, and entered into before
care is furnished to CJR beneficiaries
under the sharing arrangement. In
addition, participation in a sharing
arrangement must be voluntary and
without penalty for nonparticipation.
We proposed that the sharing
arrangement must require the CJR
collaborator and its employees,
contractors, and subcontractors to
comply with certain requirements that
are important for program integrity
protections under the arrangement. We
noted that the terms contractors and
subcontractors, respectively, include
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collaboration agents and downstream
collaboration agents as defined later in
this section.
The sharing arrangement must require
all of the individuals and entities in this
group to comply with the applicable
provisions of Part 510, including
requirements regarding beneficiary
notifications, access to records, record
retention, and participation in any
evaluation, monitoring, compliance, and
enforcement activities performed by
CMS or its designees, because these
individuals and entities all would play
a role in CJR care redesign and be part
of financial arrangements under the CJR
model. The sharing arrangement must
also require all individuals and entities
in the group to comply with the
applicable Medicare provider
enrollment requirement at § 424.500,
including having a valid and active TIN
or NPI, during the term of the sharing
arrangement. This is to ensure that the
individuals and entities have the
required enrollment relationship with
CMS under the Medicare program,
although we note that they are not
responsible for complying with
requirements that do not apply to them.
Finally, the sharing arrangement must
require individuals and entities to
comply with all other applicable laws
and regulations.
We proposed that the sharing
arrangement must not pose a risk to
beneficiary access, beneficiary freedom
of choice, or quality of care so that
financial relationships between
participant hospitals and CJR
collaborators do not negatively impact
beneficiary protections under the CJR.
Further we proposed that sharing
arrangements must require the CJR
collaborator to have a compliance
program that includes oversight of the
sharing arrangement and compliance
with the requirements of the CJR, just as
we would require participant hospitals
to have a compliance plan for this
purpose as a program integrity
safeguard. We noted that the CJR
compliance program requirement does
not mandate that a CJR collaborator’s
compliance program take a particular
form or include particular components.
It is necessary that participant
hospitals have adequate oversight over
sharing arrangements to ensure that all
arrangements meet the requirements of
this section and provide program
integrity protections. Therefore, we
proposed that the board or other
governing body of the CJR participant
hospital have responsibility for
overseeing the participant hospital’s
participation in the CJR model, its
arrangements with CJR collaborators, its
payment of gainsharing payments, its
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receipt of alignment payments, and its
use of beneficiary incentives in the CJR.
We proposed that the written agreement
memorializing a sharing arrangement
must specify a number of parameters of
the arrangement, including the
following:
• The purpose and scope of the
sharing arrangement.
• The identities and obligations of the
parties, including specified CJR
activities and other services to be
performed by the parties under the
sharing arrangement.
• Management and staffing
information, including type of
personnel or contractors that will be
primarily responsible for carrying out
CJR activities.
• The date of the sharing
arrangement.
• The financial or economic terms for
payment, including—
++ Eligibility criteria for a
gainsharing payment;
++ Eligibility criteria for an
alignment payment;
++ Frequency of gainsharing or
alignment payment;
++ Methodology and accounting
formula for determining the amount of
a gainsharing payment that is
substantially based on quality of care
and the provision of CJR activities; and
++ Methodology and accounting
formula for determining the amount of
an alignment payment.
Finally, we proposed to require that
the terms of the sharing arrangement
must not induce the participant
hospital, CJR collaborator, or any
employees, contractors, or
subcontractors of the participant
hospital or CJR collaborator to reduce or
limit medically necessary services to
any Medicare beneficiary or restrict the
ability of a CJR collaborator to make
decisions in the best interests of its
patients, including the selection of
devices, supplies, and treatments. These
requirements are to ensure that the
quality of care for CJR beneficiaries is
not negatively affected by sharing
arrangements under the CJR.
We proposed the requirements for
sharing arrangements at § 510.500(b).
We sought comment on our proposals.
Because this proposal mirrors what we
proposed for the EPM and the
comments on these proposals and our
responses are substantially the same, we
refer readers to section III.I.4.b for a
detailed explanation of the comments
and our responses to them.
Final Decision: After consideration of
the public comments received, we are
finalizing effective July 1, 2017, the
proposals in § 510.500(b) for the
requirements for CJR sharing
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539
arrangements, with modifications. We
are modifying our proposal at
§ 510.500(b)(4) to specify that the CJR
collaborator must have or be covered by
a compliance program which must
include oversight of the sharing
arrangement and compliance with the
requirements of the CJR model that
apply to its role as a CJR collaborator,
including any distribution
arrangements. We are also modifying
our proposal to remove the requirement
that the written agreement
memorializing a sharing arrangement
include management and staffing
information, a change which results in
renumbering proposed
§ 510.500(b)(7)(v) (requiring the
financial or economic terms for payment
be specified in the written agreement
about the sharing arrangement) to
§ 510.500(b)(7)(iv). CJR sharing
arrangements must meet the following
requirements:
• A sharing arrangement must be in
writing and signed by the parties, and
entered into before care is furnished to
CJR beneficiaries under the sharing
arrangement.
• Participation in a sharing
arrangement must be voluntary and
without penalty for nonparticipation.
• The sharing arrangement must
require the CJR collaborator and its
employees, contractors (including
collaboration agents), and
subcontractors (including downstream
collaboration agents) to comply with the
following:
++ The applicable provisions of this
part (including requirements regarding
beneficiary notifications, access to
records, record retention, and
participation in any evaluation,
monitoring, compliance, and
enforcement activities performed by
CMS or its designees);
++ All applicable Medicare provider
enrollment requirements at § 424.500 of
this chapter, including having a valid
and active TIN or NPI, during the term
of the sharing arrangement; and
++ All other applicable laws and
regulations.
• The sharing arrangement must
require the CJR collaborator to have or
be covered by a compliance program
that includes oversight of the sharing
arrangement and compliance with the
requirements of the CJR model that
apply to its role as a CJR collaborator,
including any distribution
arrangements.
• The sharing arrangement must not
pose a risk to beneficiary access,
beneficiary freedom of choice, or quality
of care.
• The board or other governing body
of the participant hospital must have
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responsibility for overseeing the
participant hospital’s participation in
the CJR model, its arrangements with
CJR collaborators, its payment of
gainsharing payments, its receipt of
alignment payments, and its use of
beneficiary incentives in the CJR model.
• The written agreement
memorializing a sharing arrangement
must specify the following:
++ The purpose and scope of the
sharing arrangement.
++ The obligations of the parties,
including specified CJR activities and
other services to be performed by the
parties under the sharing arrangement;
++ The date of the sharing
arrangement.
++ The financial or economic terms
for payment, including the following:
—Eligibility criteria for a gainsharing
payment.
—Eligibility criteria for an alignment
payment.
—Frequency of gainsharing or
alignment payment.
—Methodology and accounting formula
for determining the amount of a
gainsharing payment or alignment
payment.
• The sharing arrangement must
not—
++ Induce the participant hospital,
CJR collaborator, or any employees,
contractors, or subcontractors of the
participant hospital or CJR collaborator
to reduce or limit medically necessary
services to any Medicare beneficiary; or
++ Restrict the ability of a CJR
collaborator to make decisions in the
best interests of its patients, including
the selection of devices, supplies, and
treatments.
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c. Gainsharing Payment, Alignment
Payment, and Internal Cost Savings
Conditions and Restrictions
Under the CJR model, we placed a
number of conditions and limitations on
gainsharing payments, alignment
payments, and internal cost savings.
Our proposal to amend the limitations
and conditions would allow us to
reorganize and clarify current policies,
account for the addition of ACOs, CAHs,
and hospitals as CJR collaborators, and
align the CJR model with the proposed
financial arrangements for the EPMs.
Though many of the proposed
requirements under sharing
arrangements are largely similar to the
current requirements under gainsharing
payments, alignment payments, and
internal cost savings conditions and
restrictions, we discuss these
requirements in detail further in this
section in order to ensure current and
future participant hospitals and CJR
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collaborators are aware of such
requirements, in particular those that
we proposed to change.
We proposed that to be eligible to
receive a gainsharing payment, or to be
required to make an alignment payment,
a CJR collaborator other than a PGP or
an ACO must have directly furnished a
billable item or service to a CJR
beneficiary during a CJR episode that
occurred in the same performance year
for which the participant hospital has
calculated a gainsharing payment or
been assessed a repayment amount. For
purposes of this requirement, we
consider a hospital, CAH, or post-acute
care provider to have ‘‘directly
furnished’’ a billable service if one of
these entities billed for an item or
service for a CJR beneficiary during a
CJR episode that occurred in the same
performance year for which the CJR
participant hospital accrued the internal
cost savings or earned the reconciliation
payment that comprises the gainsharing
payment or was assessed a repayment
amount. The phrase ‘‘performance year
for which the EPM participant accrued
the internal cost savings or earned the
reconciliation payment that comprises
the gainsharing payment or was
assessed a repayment amount’’ does not
mean the year in which the gainsharing
payment was made. These requirements
ensure that there is a required
relationship between eligibility for a
gainsharing payment and the quality of
direct care for CJR beneficiaries during
CJR episodes for these CJR collaborators.
We believe the provision of direct care
is essential to the implementation of
effective care redesign, and the
requirement provides a safeguard
against payments to CJR collaborators
other than a PGP or an ACO that are
unrelated to direct care for CJR
beneficiaries during CJR episodes.
Further, we proposed to establish
similar requirements for PGPs and
ACOs that vary because these entities do
not themselves directly furnish billable
services. To be eligible to receive a
gainsharing payment or required to
make an alignment payment, a PGP
must have billed for an item or service
that was rendered by one or more
members of the PGP to a CJR beneficiary
during a CJR episode that occurred
during the same performance year for
which the participant hospital accrued
the internal cost savings or earned the
reconciliation payment that comprises
the gainsharing payment or was
assessed a repayment amount. Further,
we proposed that to be eligible to
receive a gainsharing payment or
required to make an alignment payment,
an ACO must have had an ACO
provider/supplier that directly
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furnished, or an ACO participant that
billed for, an item or service that was
rendered to a CJR beneficiary during a
CJR episode that occurred during the
same performance year for which the
participant hospital accrued the internal
cost savings or earned the reconciliation
payment that comprises the gainsharing
payment or was assessed a repayment
amount. With respect to ACOs, an
‘‘ACO participant’’ and ‘‘ACO provider/
supplier’’ have the meaning set forth in
§ 425.20 of regulations. Like the
proposal for CJR collaborators that are
not PGPs or ACOs, these proposals also
require a linkage between the CJR
collaborator that is the PGP or ACO and
the provision of items and services to
CJR beneficiaries during CJR episodes
by PGP members or ACO participants or
ACO providers/suppliers, respectively.
Moreover, we further proposed that
because PGPs and ACOs do not directly
furnish items and services to
beneficiaries, in order to be eligible to
receive a gainsharing payment or be
required to make an alignment payment,
the PGP or ACO must have contributed
to CJR activities and been clinically
involved in the care of CJR beneficiaries
during the same performance year for
which the participant hospital accrued
the internal cost savings or earned the
reconciliation payment that comprises
the gainsharing payment or was
assessed a repayment amount. For
example, a PGP or ACO or might have
been clinically involved in the care of
CJR beneficiaries by providing care
coordination services to CJR
beneficiaries during and/or after
inpatient admission; engaging with a
participant hospital in care redesign
strategies, and actually performing a
role in implementing such strategies
that are designed to improve the quality
of care for CJR episodes and reduce CJR
episode spending; or in coordination
with providers and suppliers (such as
members of the PGP, ACO participants,
ACO providers/suppliers, the
participant hospital, and post-acute care
providers), implementing strategies
designed to address and manage the
comorbidities of CJR beneficiaries.
Because internal cost savings may be
shared through gainsharing payments
with CJR collaborators, we have certain
requirements for their calculation as a
safeguard against fraud and abuse. We
proposed that the internal cost savings
reflect care redesign under the CJR in
order to be eligible to be shared through
gainsharing payments. We also
proposed that the methodology used to
calculate internal cost savings must
reflect the actual, internal cost savings
achieved by the participant hospital
through the documented
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implementation of CJR activities
identified by the participant hospital
and must exclude any savings realized
by any individual or entity that is not
the participant hospital and ‘‘paper’’
savings from accounting conventions or
past investment in fixed costs. Unlike
the current CJR model policy where we
require that sharing arrangements
document the methodology for accruing,
calculating, and verifying the internal
cost savings generated by the participant
hospital based on the care redesign
elements specifically associated with
the particular collaborator, we proposed
a revised policy to not require in the CJR
model that the calculation of internal
cost savings be tied to the activities of
a specific CJR collaborator. We believe
the proposed change recognizes that
multiple collaborators and collaboration
agents contribute to internal cost
savings and provide participant
hospitals with flexibility to focus on
overall internal cost savings due to
model activities, rather than the
activities of any specific collaborator or
collaboration agent. Rather, we believe
it is appropriate for participant hospitals
to calculate internal cost savings based
on the implementation of CJR activities
and then provide gainsharing payments
to CJR collaborators that may include
internal cost savings, reconciliation
payments, or both, based on a
methodology that meets the
requirements described later in this
section.
We proposed that the amount of any
gainsharing payments must be
determined in accordance with a
methodology that is substantially based
on quality of care and the provision of
CJR activities. Further, we proposed the
methodology may take into account the
amount of such CJR activities provided
by a CJR collaborator relative to other
CJR collaborators. While we emphasized
that financial arrangements may not be
conditioned directly or indirectly on the
volume or value of past or anticipated
referrals or other so that their sole
purpose is to align the financial
incentives of the participant hospital
and CJR collaborators toward the CJR
goals of improved CJR episode care
quality and efficiency. We believe that
accounting for the relative amount of
CJR activities by CJR collaborators in the
determination of gainsharing payments
does not undermine this objective.
Rather, the proposed requirement
recognizes that the relative amount of
CJR activities (including direct care)
furnished by a CJR collaborator to CJR
beneficiaries during CJR episodes may
contribute relatively more or less to both
the internal cost savings and participant
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hospital’s reconciliation payment that
may be available for making a
gainsharing payment. We refer readers
to section III.I.4. of this final rule for
additional discussion of our rationale.
We sought comment on this proposal for
gainsharing payments, where the
methodology could take into account
the amount of CJR activities provided by
a CJR collaborator relative to other CJR
collaborators. In addition we invited
comment on whether additional
safeguards or a different standard was
needed to allow for greater flexibility to
provide certain performance-based
payments consistent with the goals of
program integrity, protecting against
abuse and ensuring the goals of the
model are met.
In the CJR model, we continue to have
certain limitations on alignment
payments. Currently for a performance
year, the aggregate amount of all
alignment payments received by the
participant hospital must not exceed 50
percent of the participant hospital’s
repayment amount. In addition, the
aggregate amount of all alignment
payments from a CJR collaborator to the
participant hospital may not be greater
than 25 percent of the participant
hospital’s repayment amount for a CJR
collaborator that is not an ACO and we
proposed 50 percent of the participant
hospital’s repayment amount for a CJR
collaborator that is an ACO. We
proposed to allow a higher percentage of
the participant hospital’s repayment
amount to be paid by an ACO than by
CJR collaborators that are not ACOs in
recognition that some ACOs are sizable
organizations with significant financial
and other resources. In addition, their
expertise in managing the cost and
quality of care for Medicare
beneficiaries over a period of time may
make some ACOs uniquely capable of
sharing a higher percentage of downside
risk under the CJR with the participant
hospital under a sharing arrangement
between the ACO and CJR participant
hospital that meets all requirements for
such arrangements, including that
participation in the sharing arrangement
must be voluntary and without penalty
for nonparticipation as discussed
previously. We sought comment on the
proposed limitation that would apply to
ACOs that are CJR collaborators.
Additionally, we proposed that all
gainsharing payments and alignment
payments must be made by check,
electronic funds transfer, or another
traceable cash transaction. This is
different from the current CJR model
policy which requires gainsharing
payments and alignment payments to be
made by electronic funds transfer. We
proposed to revise this requirement in
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541
the CJR model in order to provide
additional flexibility for entities making
gainsharing payments and alignment
payments. We believe our proposal
would mitigate the administrative
burden that the EFT requirement would
place on the financial arrangements
between certain participant hospitals
and CJR collaborators, especially
individual physicians and nonphysician
practitioners and small PGPs, which
could discourage participation of those
suppliers as CJR collaborators. We
sought comment on the effect of this
proposal on reducing the administrative
barriers to individual physician and
nonphysician practitioner and small
PGP participation in the CJR as CJR
collaborators.
In summary, we proposed the
following conditions and restrictions on
gainsharing payments, alignment
payments, and internal cost savings:
• Gainsharing payments, if any,
must—
++ Be derived solely from
reconciliation payments, or internal cost
savings, or both;
++ Be distributed on an annual basis
(not more than once per calendar year);
++ Not be a loan, advance payment,
or payment for referrals or other
business; and
++ Be clearly identified as a
gainsharing payment at the time it is
paid.
• To be eligible to receive a
gainsharing payment, a CJR collaborator
must meet quality of care criteria for the
performance year for which the CJR
participant hospital accrued the internal
cost savings or earned the reconciliation
payment that comprises the gainsharing
payment. The quality of care criteria
must be established by the participant
hospital and directly related to the CJR
episode.
• To be eligible to receive a
gainsharing payment, or to be required
to make an alignment payment, a CJR
collaborator other than a PGP or an ACO
must have directly furnished a billable
item or service to a CJR beneficiary
during a CJR episode that occurred in
the same performance year for which
the CJR participant hospital accrued the
internal cost savings or earned the
reconciliation payment that comprises
the gainsharing payment or was
assessed a repayment amount.
• To be eligible to receive a
gainsharing payment, or to be required
to make an alignment payment, a CJR
collaborator that is a PGP must meet the
following criteria:
++ The PGP must have billed for an
item or service that was rendered by one
or more members of the PGP to a CJR
beneficiary during a CJR episode that
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occurred during the same performance
year for which the participant hospital
has calculated a gainsharing payment or
been assessed a repayment amount.
++ The PGP must have contributed to
CJR activities and been clinically
involved in the care of CJR beneficiaries
during the same performance year for
which the participant hospital has
calculated a gainsharing payment or
been assessed a repayment amount. For
example, a PGP might have been
clinically involved in the care of CJR
beneficiaries by—
—Providing care coordination services
to beneficiaries during and/or after
inpatient admission;
—Engaging with a participant hospital
in care redesign strategies, and
actually performing a role in
implementing such strategies, that are
designed to improve the quality of
care for CJR episodes and reduce CJR
episode spending; or
—In coordination with other providers
and suppliers (such as members of the
PGP, the participant hospital, and
post-acute care providers),
implementing strategies designed to
address and manage the comorbidities
of CJR beneficiaries.
• To be eligible to receive a
gainsharing payment, or to be required
to make an alignment payment, a CJR
collaborator that is an ACO must meet
the following criteria:
++ The ACO must have had an ACO
provider/supplier that directly
furnished, or an ACO participant that
billed for, an item or service that was
rendered to a CJR beneficiary during a
CJR episode that occurred during the
same performance year for which the
participant hospital has calculated a
gainsharing payment or been assessed a
repayment amount.
++ The ACO must have contributed
to CJR activities and been clinically
involved in the care of CJR beneficiaries.
For example, an ACO might be have
been clinically involved in the care of
CJR beneficiaries by—
—Providing care coordination services
to CJR beneficiaries during and/or
after inpatient admission;
—Engaging with a participant hospital
in care redesign strategies, and
actually performing a role in
implementing such strategies, that are
designed to improve the quality of
care and reduce spending for CJR
episodes; or
—In coordination with providers and
suppliers (such as ACO participants,
ACO providers/suppliers, the
participant hospital, and post-acute
care providers), implementing
strategies designed to address and
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manage the comorbidities of CJR
beneficiaries.
• The methodology for accruing,
calculating and verifying internal cost
savings must be transparent,
measurable, and verifiable in
accordance with generally accepted
accounting principles (GAAP) and
Government Auditing Standards (The
Yellow Book).
• The methodology used to calculate
internal cost savings must reflect the
actual, internal cost savings achieved by
the participant hospital through the
documented implementation of CJR
activities identified by the participant
hospital and must exclude—
++ Any savings realized by any
individual or entity that is not the
participant hospital; and
++ ‘‘Paper’’ savings from accounting
conventions or past investment in fixed
costs.
• The total amount of a gainsharing
payment for a performance year paid to
a CJR collaborator must not exceed the
following:
++ In the case of a CJR collaborator
who is a physician or nonphysician
practitioner, 50 percent of the Medicareapproved amounts under the PFS for
items and services furnished by that
physician or nonphysician practitioner
to the participant hospital’s CJR
beneficiaries during CJR episodes that
occurred during the same performance
year in which the participant hospital
accrued the internal cost savings or
earned the reconciliation payment that
comprises the gainsharing payment
being made.
++ In the case of a CJR collaborator
that is a PGP, 50 percent of the
Medicare-approved amounts under the
PFS for items and services billed by the
PGP and furnished to the participant
hospital’s CJR beneficiaries by members
of the PGP during CJR episodes that
occurred during the same performance
year in which the participant hospital
accrued the internal cost savings or
earned the reconciliation payment that
comprises the gainsharing payment
being made.
• The amount of any gainsharing
payments must be determined in
accordance with a methodology that is
substantially based on quality of care
and the provision of CJR activities. The
methodology may take into account the
amount of such CJR activities provided
by a CJR collaborator relative to other
CJR collaborators.
• For a performance year, the
aggregate amount of all gainsharing
payments that are derived from a
reconciliation payment must not exceed
the amount of the reconciliation
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payment the participant hospital
receives from CMS.
• No entity or individual, whether a
party to a sharing arrangement or not,
may condition the opportunity to make
or receive gainsharing payments or to
make or receive alignment payments on
the volume or value of past or
anticipated referrals or business
otherwise generated by, between or
among the participant hospital, any CJR
collaborator, any collaboration agent,
any downstream collaboration agent, or
any individual or entity affiliated with
a participant hospital, CJR collaborator,
collaboration agent, or downstream
collaboration agent.
• A participant hospital must not
make a gainsharing payment to a CJR
collaborator that is subject to any action
for noncompliance with this part or the
fraud and abuse laws, or for the
provision of substandard care in CJR
episodes or other integrity problems.
• The sharing arrangement must
require the participant hospital to
recoup any gainsharing payment that
contained funds derived from a CMS
overpayment on a reconciliation report
or was based on the submission of false
or fraudulent data.
• Alignment payments from a CJR
collaborator to a participant hospital
may be made at any interval that is
agreed upon by both parties, and must
not be—
++ Issued, distributed, or paid prior
to the calculation by CMS of a
repayment amount reflected in a
reconciliation report;
++ Loans, advance payments, or
payments for referrals or other business;
or
++ Assessed by a participant hospital
if it does not owe a repayment amount.
• The participant hospital must not
receive any amounts from a CJR
collaborator under a sharing
arrangement that are not alignment
payments.
• For a performance year, the
aggregate amount of all alignment
payments received by the participant
hospital must not exceed 50 percent of
the participant hospital’s repayment
amount.
• The aggregate amount of all
alignment payments from a CJR
collaborator to the participant hospital
may not be greater than—
++ With respect to a CJR collaborator
other than an ACO, 25 percent of the
participant hospital’s repayment
amount; and
++ With respect to a CJR collaborator
that is an ACO, 50 percent of the
participant hospital’s repayment
amount.
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• The methodology for determining
alignment payments must not directly
account for the volume or value of past
or anticipated referrals or business
otherwise generated by, between or
among the participant hospital, any CJR
collaborator, any collaboration agent,
any downstream collaboration agent, or
any individual or entity affiliated with
a participant hospital, CJR collaborator,
collaboration agent, or downstream
collaboration agent.
• All gainsharing payments and any
alignment payments must be
administered by the participant hospital
in accordance with generally accepted
accounting principles.
• All gainsharing payments and
alignment payments must be made by
check, electronic funds transfer, or
another traceable cash transaction.
We proposed to amend the
regulations at § 510.500(c) as described
previously. We sought comment on our
proposal, including the feasibility of
implementing the proposed safeguards
in the context of the current regulatory
framework applicable to ACOs and
whether additional or different
safeguards were reasonable, necessary
or appropriate to ensure the goals of
program integrity, protecting against
abuse and ensuring the goals of the
model are met.
Because this proposal mirrors what
was proposed for the EPM and the
comments on these proposals and our
responses are substantially the same, we
refer readers to section III.I.4.c for a
detailed explanation of the comments
and our responses to them.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposals, with
modifications, for gainsharing
payments, alignment payments, and
internal cost savings conditions and
restrictions, in § 510.500(c). In addition
to the modifications discussed in our
responses in section III.I.4.c, we are
specifying that to be eligible to receive
a gainsharing payment or to be required
to make an alignment payment, an
NPPGP or TGP (like PGPs) must have
billed for an item or service that was
rendered by one or more NPPGP
members or TGP members respectively
to a CJR beneficiary during a CJR
episode that occurred during the same
performance year for which the CJR
participant accrued the internal cost
savings or earned the reconciliation
payment that comprises the gainsharing
payment or was assessed a repayment
amount. In addition, like PGPs, the
NPPGP or TGP must have contributed to
CJR activities and been clinically
involved in the care of CJR beneficiaries
during the same performance year for
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Jkt 241001
which the CJR participant hospital
accrued the internal cost savings or
earned the reconciliation payment that
comprises the gainsharing payment or
was assessed a repayment amount.
As finalized, effective July 1, 2017
gainsharing payments, alignment
payments, and internal cost savings
must meet the following conditions and
restrictions:
• Gainsharing payments, if any,
must—
++ Be derived solely from
reconciliation payments, or internal cost
savings, or both;
++ Be distributed on an annual basis
(not more than once per calendar year);
++ Not be a loan, advance payment,
or payment for referrals or other
business; and
++ Be clearly identified as a
gainsharing payment at the time it is
paid.
++ To be eligible to receive a
gainsharing payment, a CJR collaborator
must meet quality of care criteria for the
performance year for which the
participant hospital accrued the internal
cost savings or earned the reconciliation
payment that comprises the gainsharing
payment. The quality of care criteria
must be established by the participant
hospital and directly related to CJR
episodes.
++ To be eligible to receive a
gainsharing payment, or to be required
to make an alignment payment, a CJR
collaborator other than an ACO, PGP,
NPPGP, or TGP must have directly
furnished a billable item or service to a
CJR beneficiary during a CJR episode
that occurred in the same performance
year for which the participant hospital
accrued the internal cost savings or
earned the reconciliation payment that
comprises the gainsharing payment or
was assessed a repayment amount.
++ To be eligible to receive a
gainsharing payment, or to be required
to make an alignment payment, a CJR
collaborator that is a PGP, NPPGP, or
TGP must meet the following criteria:
—The PGP, NPPGP, or TGP must have
billed for an item or service that was
rendered by one or more PGP
member, NPPGP member, or TGP
member respectively to a CJR
beneficiary during a CJR episode that
occurred during the same
performance year for which the
participant hospital accrued the
internal cost savings or earned the
reconciliation payment that comprises
the gainsharing payment or was
assessed a repayment amount; and
—The PGP, NPPGP, or TGP must have
contributed to CJR activities and been
clinically involved in the care of CJR
PO 00000
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543
beneficiaries during the same
performance year for which the
participant hospital accrued the
internal cost savings or earned the
reconciliation payment that comprises
the gainsharing payment or was
assessed a repayment amount. For
example, a PGP, NPPGP, or TGP
might have been clinically involved
in the care of CJR beneficiaries by—
∧∧ Providing care coordination
services to CJR beneficiaries during and/
or after inpatient admission;
∧∧ Engaging with a participant
hospital in care redesign strategies, and
actually performing a role in
implementing such strategies, that are
designed to improve the quality of care
for CJR episodes and reduce CJR episode
spending; or
∧∧ In coordination with other
providers and suppliers (such as PGP
members, NPPGP members, or TGP
members; the participant hospital; and
post-acute care providers),
implementing strategies designed to
address and manage the comorbidities
of CJR beneficiaries.
—To be eligible to receive a gainsharing
payment, or to be required to make an
alignment payment, a CJR collaborator
that is an ACO must meet the
following criteria:
∧∧ The ACO must have had an ACO
provider/supplier that directly
furnished, or an ACO participant that
billed for, an item or service that was
rendered to a CJR beneficiary during a
CJR episode that occurred during the
same performance year for which the
participant hospital accrued the internal
cost savings or earned the reconciliation
payment that comprises the gainsharing
payment or was assessed a repayment
amount; and
++ The ACO must have contributed
to CJR activities and been clinically
involved in the care of CJR beneficiaries
during the same performance year for
which the participant hospital accrued
the internal cost savings or earned the
reconciliation payment that comprises
the gainsharing payment or was
assessed a repayment amount. For
example, an ACO might be have been
clinically involved in the care of CJR
beneficiaries by—
∧∧ Providing care coordination
services to CJR beneficiaries during and/
or after inpatient admission;
∧∧ Engaging with a participant
hospital in care redesign strategies, and
actually performing a role in
implementing such strategies, that are
designed to improve the quality of care
and reduce spending for CJR episodes;
or
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∧∧ In coordination with providers
and suppliers (such as ACO
participants, ACO providers/suppliers,
the CJR participant hospital, and postacute care providers), implementing
strategies designed to address and
manage the comorbidities of CJR
beneficiaries.
++ The methodology for accruing,
calculating and verifying internal cost
savings must be transparent,
measurable, and verifiable in
accordance with generally accepted
accounting principles (GAAP) and
Government Auditing Standards (The
Yellow Book).
++ The methodology used to
calculate internal cost savings must
reflect the actual, internal cost savings
achieved by the participant hospital
through the documented
implementation of CJR activities
identified by the participant hospital
and must exclude:
—Any savings realized by any
individual or entity that is not the CJR
participant hospital; and
—‘‘Paper’’ savings from accounting
conventions or past investment in
fixed costs.
• The total amount of a gainsharing
payment for a performance year paid to
a CJR collaborator must not exceed the
following:
++ In the case of a CJR collaborator
who is a physician or nonphysician
practitioner, 50 percent of the Medicareapproved amounts under the PFS for
items and services furnished by that
physician or nonphysician practitioner
to the participant hospital’s CJR
beneficiaries during CJR episodes that
occurred during the same performance
year for which the participant hospital
accrued the internal cost savings or
earned the reconciliation payment that
comprises the gainsharing payment
being made.
++ In the case of a CJR collaborator
that is a PGP or NPPGP, 50 percent of
the Medicare-approved amounts under
the PFS for items and services billed by
that PGP or NPPGP and furnished to the
participant hospital’s CJR beneficiaries
by the PGP members or NPPGP
members respectively during CJR
episodes that occurred during the same
performance year for which the
participant hospital accrued the internal
cost savings or earned the reconciliation
payment that comprises the gainsharing
payment being made.
• The amount of any gainsharing
payments must be determined in
accordance with a methodology that is
substantially based on quality of care
and the provision of CJR activities. The
methodology may take into account the
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Jkt 241001
amount of such CJR activities provided
by a CJR collaborator relative to other
CJR collaborators.
• For a performance year, the
aggregate amount of all gainsharing
payments that are derived from a
reconciliation payment the participant
hospital receives from CMS must not
exceed the amount of that reconciliation
payment.
• No entity or individual, whether a
party to a sharing arrangement or not,
may condition the opportunity to make
or receive gainsharing payments or to
make or receive alignment payments
directly or indirectly on the volume or
value of past or anticipated referrals or
business otherwise generated by,
between or among the participant
hospital, any CJR collaborator, any
collaboration agent, any downstream
collaboration agent, or any individual or
entity affiliated with a participant
hospital, CJR collaborator, collaboration
agent, or downstream collaboration
agent.
• A participant hospital must not
make a gainsharing payment to a CJR
collaborator if CMS has notified the
participant hospital that such
collaborator is subject to any action for
noncompliance with this part or the
fraud and abuse laws, or for the
provision of substandard care to CJR
beneficiaries or other integrity
problems.
• The sharing arrangement must
require the participant hospital to
recoup any gainsharing payment that
contained funds derived from a CMS
overpayment on a reconciliation report
or was based on the submission of false
or fraudulent data.
• Alignment payments from a CJR
collaborator to a participant hospital
may be made at any interval that is
agreed upon by both parties, and must
not be—
++ Issued, distributed, or paid prior
to the calculation by CMS of a
repayment amount reflected in a
reconciliation report;
Loans, advance payments, or
payments for referrals or other business;
or
++ Assessed by a participant hospital
if it does not owe a repayment amount.
• The CJR participant hospital must
not receive any amounts under a sharing
arrangement from a CJR collaborator
that are not alignment payments.
• For a performance year, the
aggregate amount of all alignment
payments received by the CJR
participant hospital must not exceed 50
percent of the participant hospital’s
repayment amount.
• The aggregate amount of all
alignment payments from a CJR
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collaborator to the participant hospital
may not be greater than—
++ With respect to a CJR collaborator
other than an ACO, 25 percent of the
participant hospital’s repayment
amount; or
++ With respect to a CJR collaborator
that is an ACO, 50 percent of the
participant hospital’s repayment
amount.
• The amount of any alignment
payments must be determined in
accordance with a methodology that
does not directly account for the volume
or value of past or anticipated referrals
or business otherwise generated by,
between or among the participant
hospital, any CJR collaborator, any
collaboration agent, any downstream
collaboration agent, or any individual or
entity affiliated with a participant
hospital, CJR collaborator, collaboration
agent, or downstream collaboration
agent.
• All gainsharing payments and any
alignment payments must be
administered by the participant hospital
in accordance with generally accepted
accounting principles (GAAP) and
Government Auditing Standards (The
Yellow Book).
• All gainsharing payments and
alignment payments must be made by
check, electronic funds transfer, or
another traceable cash transaction.
d. Documentation
We proposed revisions to § 510.500(d)
for organization and formatting
purposes, and to align with the
proposed regulations of the EPMs.
Besides the proposed definitional
changes, these revisions would not
change any policies under the current
documentation section of the CJR
model.
In summary we proposed the
following requirements for
documentation:
• Participant hospitals must—
++ Document the sharing
arrangement contemporaneously with
the establishment of the arrangement;
++ Maintain accurate current and
historical lists of all CJR collaborators,
including collaborator names and
addresses; update such lists on at least
a quarterly basis; and publicly report the
current and historical lists of CJR
collaborators on a Web page on the
participant hospital’s Web site; and
++ Maintain and require each CJR
collaborator to maintain
contemporaneous documentation with
respect to the payment or receipt of any
gainsharing payment or alignment
payment that includes at a minimum
the—
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—Nature of the payment (gainsharing
payment or alignment payment);
—Identity of the parties making and
receiving the payment;
—Date of the payment;
—Amount of the payment; and
—Date and amount of any recoupment
of all or a portion of a CJR
collaborator’s gainsharing payment.
• The participant hospital must keep
records of the following:
++ Its process for determining and
verifying its potential and current CJR
collaborators’ eligibility to participate in
Medicare.
++ Its plan to track internal cost
savings.
++ Information on the accounting
systems used to track internal cost
savings.
++ A description of current health
information technology, including
systems to track reconciliation
payments and internal cost savings.
++ Its plan to track gainsharing
payments and alignment payments.
• The participant hospital must retain
and provide access to, and must require
each CJR collaborator to retain and
provide access to, the required
documentation in accordance with
§ 510.110.
In the proposed § 510.500(d)(3), we
proposed that participant hospitals must
retain and provide access to the
required documentation in accordance
with § 510.110 and must obligate CJR
collaborators to do the same. We
proposed to add a new section,
§ 510.110, to the CJR regulations, which
would apply all records access and
retention requirements under the CJR
model, including those for financial
arrangements as well as beneficiary
notifications and beneficiary incentives.
Because we proposed to consolidate all
records access and retention
requirements in one place in the
regulations, we proposed to delete
§ 510.500(e) from the current CJR
regulations. We discussed further our
proposal to consolidate the
requirements under the CJR model for
access to records and record retention
and apply them more broadly in the
model. This approach mirrors our
proposed records retention policies for
the EPMs, which are discussed in detail
in section III.H. of this final rule. We
refer readers to that section for further
discussion of our proposed policies and
rationale.
We proposed to amend the
regulations at § 510.500(d). We sought
comment on our proposals. We received
no specific comments on the proposed
documentation requirements for CJR
sharing arrangements other than the
comment discussed in section III.I.4.d.
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22:30 Dec 30, 2016
Jkt 241001
previously requesting further
documentation related to the criteria for
selection of CJR collaborators.
Final Decision: We are finalizing the
proposals in § 510.500(d) for CJR
documentation requirements, with the
modification previously discussed to
require the participant hospital to
publicly post the written policies for
selecting CJR collaborators on a Web
page on the participant hospital’s Web
site and the reorganization to
consolidate and streamline the
documentation requirements related to
public posting. CJR sharing
arrangements must meet the following
documentation requirements:
• The participant hospital must do all
of the following:
++ Document the sharing
arrangement contemporaneously with
the establishment of the arrangement.
++ Publicly post (and update on at
least a quarterly basis) on a Web page
on the CJR participant hospital’s Web
site:
++ Accurate current and historical
lists of all CJR collaborators, including
CJR collaborator names and addresses.
++ Written policies for selecting
individuals and entities to be CJR
collaborators required by
§ 510.500(a)(3).
++ Maintain and require each CJR
collaborator to maintain
contemporaneous documentation with
respect to the payment or receipt of any
gainsharing payment or alignment
payment that includes at a minimum all
of the following:
—Nature of the payment (gainsharing
payment or alignment payment).
Identity of the parties making and
receiving the payment.
—Date of the payment.
—Amount of the payment.
—Date and amount of any recoupment
of all or a portion of a CJR
collaborator’s gainsharing payment.
—Explanation for each recoupment,
such as whether the CJR collaborator
received a gainsharing payment that
contained funds derived from a CMS
overpayment on a reconciliation
report, or was based on the
submission of false or fraudulent data.
• The participant hospital must keep
records of the following:
++ Its process for determining and
verifying its potential and current CJR
collaborators’ eligibility to participate in
Medicare.
++ Its plan to track internal cost
savings.
++ Information on the accounting
systems used to track internal cost
savings.
++ A description of current health
information technology, including
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545
systems to track reconciliation
payments and internal cost savings.
++ Its plan to track gainsharing
payments and alignment payments.
• The participant hospital must retain
and provide access to, and must require
each EPM collaborator to retain and
provide access to, the required
documentation in accordance with
§ 510.110.
3. Distribution Arrangements
Though we proposed a complete
revision of the regulations in § 510.505,
these changes are mainly to
accommodate our proposals to add
ACOs as CJR collaborators, add the term
‘collaboration agent,’ remove the term
‘collaborator agreement,’ move the
requirements for such agreements to
appear as requirements for sharing
arrangements, and to mirror the
proposed EPM regulations at § 512.505
to avoid confusion for hospitals that are
participating in CJR as well as one or
more of the proposed EPMs. Our
proposed changes to the regulations
reflect that the requirements and rules
regarding distribution arrangements
under the CJR model would stay largely
the same.
a. General
We proposed that certain financial
arrangements between CJR collaborators
and other individuals or entities called
‘‘collaboration agents’’ be termed
‘‘distribution arrangements.’’ A
distribution arrangement is a financial
arrangement between a CJR collaborator
that is an ACO or PGP and a
collaboration agent for the sole purpose
of sharing a gainsharing payment
received by the ACO or PGP. A
collaboration agent is an individual or
entity that is not a CJR collaborator and
that is either a PGP member that has
entered into a distribution arrangement
with the same PGP in which he or she
is an owner or employee or an ACO
participant or ACO provider/supplier
that has entered into a distribution
arrangement with the same ACO in
which it is participating. Where a
payment from a CJR collaborator to a
collaboration agent is made pursuant to
a distribution arrangement, we proposed
to define that payment as a ‘‘distribution
payment.’’ A collaboration agent may
make a distribution payment only in
accordance with a distribution
arrangement which complies with the
provisions of § 510.505 and all other
applicable laws and regulations,
including the fraud and abuse laws. We
solicited comment on whether
requirements for distribution payments
by ACOs under the proposal were
reasonable, necessary and appropriate to
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promote program integrity, prevent
fraud and abuse, and achieve the goals
of the model. In addition, we solicited
comment on how the regulation of the
financial arrangements the proposal
may interact with and on how these or
similar financial arrangements are
regulated under the Medicare Shared
Savings Program.
We received no specific comments on
the proposed general provisions for
distribution arrangements under the CJR
model. However, as discussed
previously, we are finalizing revisions
to allow NPPGP to be eligible to be CJR
collaborators and we are modifying our
general provisions for distribution
arrangements to allow NPPGPs to enter
into distribution arrangements with
NPPGP members. Similarly, we are
modifying our general provisions for
distribution arrangements to allow TGPs
to enter into distribution arrangements
with TGP members. In addition, we are
modifying the EPM proposals in
response to the comments that we
received, and therefore, consistent with
our proposal to amend the CJR
regulations to streamline and simply
requirements for CJR and to align them
with the EPMs, we are making
corresponding changes to the CJR
regulations. We believe these
modifications also will reduce any
burden that could arise from having to
comply with different requirements for
each model for hospitals participating in
both CJR and EPMs. We refer readers to
the discussion at III.I.5. for further
information.
Final Decision: We are finalizing
effective July 1, 2017 the proposals in
§ 510.505(a) for the general
requirements for CJR distribution
arrangements, with modification to
allow NPPGPs or TGPs to enter into
distribution arrangements with NPPGP
members or TGP members respectively.
Similar to PGPs when they are CJR
collaborators, we believe it is
appropriate to allow NPPGPs or TGPs to
enter into distribution arrangements
with NPPGP members or TGP members
respectively for the sole purpose of
sharing a gainsharing payment received
by the NPPGP or TGP. Distribution
arrangements under the CJR model must
comply with the following general
provisions:
• An ACO, PGP, NPPGP, or TGP that
has entered into a sharing arrangement
with a CJR participant hospital may
distribute all or a portion of any
gainsharing payment it receives from
the participant hospital only in
accordance with a distribution
arrangement.
• All distribution arrangements must
comply with the provisions of this
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section and all other applicable laws
and regulations, including the fraud and
abuse laws.
b. Requirements
We proposed to amend the
requirements for distribution payments
in § 510.505 as discussed in this section.
We proposed the opportunity to make
or receive a distribution payment must
not be conditioned directly or indirectly
on the volume or value of past or
anticipated referrals or business
otherwise generated by, between or
among the participant hospital, any CJR
collaborator, collaboration agent, any
downstream collaboration agent, or any
individual or entity affiliated with a
participant hospital, CJR collaborator,
collaboration agent, or downstream
collaboration agent. The proposed
requirement is substantively the same as
the existing requirement in the CJR
model. By adding the word ‘‘past or
anticipated,’’ the proposed provision
makes clear that all previous and future
referrals between or among the
participant hospital, any CJR
collaborator, any collaboration agent,
any downstream collaboration agent, or
any individual or entity affiliated with
a participant hospital, CJR collaborator,
collaboration agent, or downstream
collaboration agent are encompassed.
Currently, methodologies for
determining distribution payments must
not directly account for volume or value
of referrals, or business otherwise
generated, by, between or among the
participant hospital, PGP, other CJR
collaborators, any collaboration agent,
any downstream collaboration agent,
and any individual or entity affiliated
with a participant hospital, CJR
collaborator, collaboration agent, or
downstream collaboration agent. We
proposed to change the requirement as
follows.
Like our proposal for gainsharing
payments discussed previously, we
proposed a more flexible standard for
the determination of the amount of
distribution payments from ACOs and
PGPs for the same reasons we propose
this standard for the determination of
gainsharing payments. Specifically, for
ACOs we proposed that the amount of
any distribution payments must be
determined in accordance with a
methodology that is substantially based
on quality of care and the provision of
CJR activities and that may take into
account the amount of such CJR
activities provided by a collaboration
agent relative to other collaboration
agents. We believe that the amount of a
collaboration agent’s provision of CJR
activities (including direct care) to CJR
beneficiaries during a CJR episode may
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contribute to the participant hospital’s
internal cost savings and reconciliation
payment that may be available for
making a gainsharing payment to the
CJR collaborator with which the
collaboration agent has a distribution
arrangement. Greater contributions of
CJR activities by one collaboration agent
versus another collaboration agent that
result in different contributions to the
gainsharing payment made to the CJR
collaborator with which those
collaboration agents both have a
distribution arrangement may be
appropriately valued in the
methodology used to make distribution
payments to those collaboration agents.
Accordingly, we believe this is the
appropriate standard for determining
the amount of distribution payments
from an ACO to its collaboration agents.
We noted that for distribution
payments made by a PGP to PGP
members, the requirement that the
amount of any distribution payments
must be determined in accordance with
a methodology that is substantially
based on quality of care and the
provision of CJR activities may be more
limiting in how a PGP pays its members
than is allowed under existing law.
Therefore, to retain existing flexibility
for distribution payments by a PGP to
PGP members, we proposed that the
amount of the distribution payment
from a PGP to PGP members must be
determined either using the
methodology previously described for
distribution payments from an ACO or
in a manner that complies with
§ 411.352(g). The proposal would allow
a PGP the choice either to comply with
the general standard that the amount of
a distribution payment must be
substantially based on quality of care
and the provision of CJR activities or to
provide its members a financial benefit
through the CJR without consideration
of the PGP member’s individual quality
of care. In the latter case, PGP members
who are not collaboration agents
(including those who furnished no
services to CJR beneficiaries) would be
able receive a share of the profits from
their PGP that includes the monies
contained in a gainsharing payment. We
believe that our proposal to modify the
current CJR regulations to allow the
amount of the distribution payment
from a PGP to a PGP member to be
determined in a manner that complies
with § 411.352(g) is an appropriate
exception to the general standard for
determining the amount of distribution
payment under the CJR model from a
PGP to a PGP member. CMS has
determined under the physician selfreferral law that payments from a group
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practice as defined under § 411.352 to
its members that comply with
§ 411.352(g) are appropriate. The
proposal would allow a PGP the choice
either to comply with the general
standard that the amount of a
distribution payment must be
substantially based on quality of care
and the provision of CJR activities or to
provide its members a financial benefit
through the CJR model without
consideration of the PGP member’s
individual quality of care. The approach
mirrors our proposed policies for
distribution arrangements for the EPMs,
which are discussed in detail in section
III.I.5. of this final rule.
We proposed to amend the
regulations at § 510.505(b)(4) and (b)(5).
We sought comment on the proposal
and specifically whether additional
safeguards or a different standard was
needed to allow for greater flexibility in
calculating the amount of distribution
payments consistent with the goals of
promoting program integrity, protecting
against abuse, and ensuring that the
goals of the model are met. In addition,
we solicited comment on the proposal
to allow distribution payments by a PGP
to its members that comply with
§ 411.352(g) or whether additional/
different safeguards are reasonable,
necessary, and appropriate.
Except for a distribution payment
from a PGP to a PGP member that
complies with § 411.352(g), we
proposed to continue the limits in the
current CJR regulations on the total
amount of distribution payments to
physicians, nonphysician practitioners,
and PGPs as we proposed for
gainsharing payments. Specifically, in
the case of a collaboration agent that is
a physician or nonphysician
practitioner, absent the alternative
safeguards afforded by compliance with
§ 411.352(g), we would limit the total
amount of distribution payments paid
for a performance year to the
collaboration agent to 50 percent of the
total Medicare-approved amounts under
the PFS for items and services furnished
by the collaboration agent to the CJR
participant hospital’s CJR beneficiaries
during CJR episodes that occurred
during the same performance year for
which the CJR participant accrued the
internal cost savings or earned the
reconciliation payment that comprises
the gainsharing payment being
distributed. In the case of a
collaboration agent that is a PGP, the
limit would continue to be 50 percent
of the total Medicare-approved amounts
under the PFS for items and services
billed by the PGP for items and services
furnished by members of the PGP to the
CJR participant hospital’s CJR
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beneficiaries during CJR episodes that
occurred during the same performance
year for which the CJR participant
hospital accrued the internal cost
savings or earned the reconciliation
payment that comprises the gainsharing
payment being distributed.
We proposed that all distribution
payments must be made by check,
electronic funds transfer, or another
traceable cash transaction. The proposal
would provide additional flexibility for
entities making distribution payments
as well as would mitigate the
administrative burden that the EFT
requirement previously placed on the
financial arrangements between certain
participant hospitals and CJR
collaborators, especially individual
physicians and nonphysician
practitioners and small PGPs, which
could discourage participation of those
suppliers as CJR collaborators.
Finally, we proposed at
§ 510.505(b)(15) that CJR collaborators
must retain and provide access to the
required documentation in accordance
with § 510.110 and must require each
collaboration agent to do so as well. We
discussed further our proposal to
consolidate the requirements under the
CJR model for access to records and
record retention and apply them more
broadly in the model. The approach
mirrors our proposed records retention
policies for the EPMs, which are
discussed in detail in section III.H. of
this final rule. We refer readers to that
section for further discussion of our
proposed policies and rationale.
We sought comment on our proposals
regarding distribution arrangements
The following is a summary of the
comments received and our responses.
Comment: We received comments on
the requirements of a distribution
arrangement under the CJR model and
EPM, including the proposed cap on
distribution and downstream
distribution payments, which are
discussed in section III.I.5.b.
Response: We appreciate the
comments on the requirements of a
distribution arrangement under the CJR
model and the EPM. We refer to section
III.I.5.b for a detailed discussion of
comments and responses in regards to
distribution arrangements under these
models.
We are finalizing in §§ 510.505(6) and
510.510(6) that the amount of any
distribution payments or downstream
distribution payments from a PGP to a
PGP member must be determined either
in a manner that complies with
§ 411.352(g) of this chapter or in
accordance with a methodology that is
substantially based on quality of care
and the provision CJR activities.
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547
Comment: One commenter requested
clarification about whether outpatient
therapy providers can receive
distribution or downstream distribution
payments as either a member of a PGP
who is a CJR collaborator or as a
member of a PGP that is an ACO
participant in an ACO that has a
distribution arrangement with a CJR
collaborator.
Response: Certain outpatient therapy
providers are included in the definition
of a member of a PGP or PGP member
which means ‘‘a physician,
nonphysician practitioner, or therapist
who is an owner or employer of a PGP
and who has reassigned to the PGP his
or her right to receive Medicare
payment.’’ Thus, therapists who are PGP
members may be eligible to receive
distribution payments or downstream
distribution payments when those PGPs
enter into financial arrangements under
the CJR model in accordance with all
the requirements in this final rule.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposals in § 510.505(b)
for the requirements for CJR distribution
arrangements, with modification to
include policies for NPPGPs or TGPs
that enter into distribution arrangements
with NPPGP members or TGP members
respectively. Like a PGP, an NPPGP that
is an ACO participant in an ACO that is
a CJR collaborator may enter into
distribution arrangement with the ACO.
The distribution payments to the
NPPGP are subject to the same
requirements as distribution payments
to PGPs that are collaboration agents.
The NPPGP is eligible to receive a
distribution payment only if the
collaboration agent billed for an item or
service rendered to a CJR beneficiary
during a CJR episode that occurred
during the same performance year for
which the CJR participant hospital
accrued the internal cost savings or
earned the reconciliation payment that
comprises the gainsharing payment
being distributed. The distribution
payment to the NPPGP is capped at 50
percent of the total Medicare-approved
amounts under the PFS for items and
services billed by the NPPGP for items
and services furnished by NPPGP
members to the CJR participant
hospital’s CJR beneficiaries during CJR
episodes that occurred during the same
performance year for which the CJR
participant hospital accrued the internal
cost savings or earned the reconciliation
payment that comprises the gainsharing
payment being distributed.
If an NPPGP is a CJR collaborator, it
may enter into a distribution
arrangement with an NPPGP member,
which is defined as a nonphysician
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practitioner or therapist who is an
owner or employee of an NPPGP and
who has reassigned to the NPPGP his or
her right to receive Medicare payment.
The requirements for NPPGP
distribution payments under those
distribution arrangements are the same
as those for PGPs, except that we allow
the amount of any distribution
payments from a PGP to a PGP member
to be determined in a manner that
complies with § 411.352(g). While CMS
has determined under the physician
self-referral law that payments from a
group practice as defined under
§ 411.352 to its members that comply
with § 411.352(g) are appropriate,
NPPGPs do not fall under this definition
of group practice. Therefore, the amount
of any distribution payments from an
NPPGP to an NPPGP member must
always be determined in accordance
with a methodology that is substantially
based on quality of care and the
provision CJR activities, the same
standard that applies to PGP
distribution payments that are not
determined in a manner that complies
with § 411.352(g). Like the requirement
for PGP members when a distribution
payment does not comply with
§ 411.352(g), an NPPGP member is
eligible to receive a distribution
payment only if the collaboration agent
furnished an item or service to a CJR
beneficiary during a CJR episode that
occurred during the same performance
year for which the CJR participant
hospital accrued the internal cost
savings or earned the reconciliation
payment that comprises the gainsharing
payment being distributed. Finally, the
total amount of distribution payments
paid for a performance year to the NPPG
member may not exceed 50 percent of
the total Medicare-approved amounts
under the PFS for items and services
furnished by the NPPGP member to the
CJR participant hospital’s CJR
beneficiaries during CJR episodes that
occurred during the same performance
year for which the CJR participant
hospital accrued the internal cost
savings or earned the reconciliation
payment that comprises the gainsharing
payment being distributed.
In addition, with respect to the
distribution of any gainsharing payment
received by an NPPGP, the total amount
of all distribution payments must not
exceed the amount of the gainsharing
payment received by the CJR
collaborator from the CJR participant
hospital.
Like a PGP and NPPGP, a TGP that is
an ACO participant in an ACO that is a
CJR collaborator may enter into
distribution arrangement with the ACO.
The distribution payments to the TGP
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are not subject to the cap that applies to
PGPs and NPPGPs. While we cap
distribution payments to physicians and
nonphysician practitioners, we will not
cap such payments to therapists in
private practice for the same reasons
discussed for gainsharing payments to
these individuals and, therefore, we will
not cap distribution payments to TGPs.
Like PGPs and NPPGPs, the TGP is
eligible to receive a distribution
payment only if the collaboration agent
billed for an item or service rendered to
a CJR beneficiary during a CJR episode
that occurred during the same
performance year for which the CJR
participant hospital accrued the internal
cost savings or earned the reconciliation
payment that comprises the gainsharing
payment being distributed.
If a TGP is a CJR collaborator, it may
enter into a distribution arrangement
with a TGP member, who is a therapist
who is an owner or employee of a TGP
and who has reassigned to the TGP his
or her right to receive Medicare
payment. Like distribution payments
from an NPPGP to an NPPGP member,
the amount of any distribution
payments from a TGP to a TGP member
must be determined in accordance with
a methodology that is substantially
based on quality of care and the
provision CJR activities, the same
standard that applies to PGP
distribution payments that are not
determined in a manner that complies
with § 411.352(g). Like the requirement
for PGP members when a distribution
payment does not comply with
§ 411.352(g) and for NPPG members, a
TGP member is eligible to receive a
distribution payment only if the
collaboration agent furnished an item or
service to CJR beneficiary during a CJR
episode that occurred during the same
performance year for which the CJR
participant hospital accrued the internal
cost savings or earned the reconciliation
payment that comprises the gainsharing
payment being distributed. We will not
cap the total amount of distribution
payments paid for a performance year to
a TGP member for the reasons discussed
previously for not applying caps on
gainsharing payments to therapists in
private practice. Finally, with respect to
the distribution of any gainsharing
payment received by a TGP, the total
amount of all distribution payments
must not exceed the amount of the
gainsharing payment received by the
CJR collaborator from the CJR
participant hospital.
We are finalizing that distribution
arrangements under the CJR model must
comply with the following
requirements:
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• All distribution arrangements must
be in writing and signed by the parties,
contain the date of the agreement, and
be entered into before care is furnished
to CJR beneficiaries under the
distribution arrangement.
• Participation in a distribution
arrangement must be voluntary and
without penalty for nonparticipation.
• The distribution arrangement must
require the collaboration agent to
comply with all applicable laws and
regulations.
• The opportunity to make or receive
a distribution payment must not be
conditioned directly or indirectly on the
volume or value of past or anticipated
referrals or business otherwise
generated by, between or among the
participant hospital, any CJR
collaborator, any collaboration agent,
any downstream collaboration agent, or
any individual or entity affiliated with
a participant hospital, CJR collaborator,
collaboration agent, or downstream
collaboration agent.
• The amount of any distribution
payments from an ACO, from an NPPGP
to an NPPGP member, or from a TGP to
a TGP member must be determined in
accordance with a methodology that is
substantially based on quality of care
and the provision CJR activities and that
may take into account the amount of
such CJR activities provided by a
collaboration agent relative to other
collaboration agents.
• The amount of any distribution
payments from a PGP must be
determined either in a manner that
complies with § 411.352(g) of this
chapter or in accordance with a
methodology that is substantially based
on quality of care and the provision CJR
activities and that may take into account
the amount of such CJR activities
provided by a collaboration agent
relative to other collaboration agents.
• Except for a distribution payment
from a PGP to a PGP member that
complies with § 411.352(g), a
collaboration agent is eligible to receive
a distribution payment only if the
collaboration agent furnished or billed
for an item or service rendered to a CJR
beneficiary during a CJR episode that
occurred during the same performance
year for which the participant hospital
accrued the internal cost savings or
earned the reconciliation payment that
comprises the gainsharing payment
being distributed.
• Except for a distribution payment
from a PGP to a PGP member that
complies with § 411.352(g), the total
amount of distribution payments for a
performance year paid to a collaboration
agent must not exceed the following:
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++ In the case of a collaboration agent
that is a physician or nonphysician
practitioner, 50 percent of the total
Medicare-approved amounts under the
PFS for items and services furnished by
the collaboration agent to the
participant hospital’s CJR beneficiaries
during CJR episodes that occurred
during the same performance year for
which the participant hospital accrued
the internal cost savings or earned the
reconciliation payment that comprises
the gainsharing payment being
distributed.
++ In the case of a collaboration agent
that is a PGP or NPPGP, 50 percent of
the total Medicare-approved amounts
under the PFS for items and services
billed by that PGP or NPPGP for items
and services furnished by PGP members
or NPPGP members to the CJR
participant hospital’s CJR beneficiaries
during CJR episodes that occurred
during the same performance year for
which the CJR participant hospital
accrued the internal cost savings or
earned the reconciliation payment that
comprises the gainsharing payment
being distributed.
• With respect to the distribution of
any gainsharing payment received by an
ACO, PGP, NPPGP, or TGP, the total
amount of all distribution payments
must not exceed the amount of the
gainsharing payment received by the
CJR collaborator from the CJR
participant hospital.
• All distribution payments must be
made by check, electronic funds
transfer, or another traceable cash
transaction.
• The collaboration agent must retain
the ability to make decisions in the best
interests of the patient, including the
selection of devices, supplies, and
treatments.
• The distribution arrangement must
not—
++ Induce the collaboration agent to
reduce or limit medically necessary
items and services to any Medicare
beneficiary; or
++ Reward the provision of items and
services that are medically unnecessary.
• The CJR collaborator must maintain
contemporaneous documentation
regarding distribution arrangements in
accordance with § 512.110, including
the following:
The relevant written agreements.
++ The date and amount of any
distribution payment(s);
++ The identity of each collaboration
agent that received a distribution
payment; and
++ A description of the methodology
and accounting formula for determining
the amount of any distribution payment.
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• The CJR collaborator may not enter
into a distribution arrangement with any
individual or entity that has a sharing
arrangement with the same CJR
participant hospital.
• The CJR collaborator must retain
and provide access to, and must require
collaboration agents to retain and
provide access to, the required
documentation in accordance with
§ 512.110.
4. Downstream Distribution
Arrangements Under the CJR Model
a. General
We proposed that the CJR model
allow for certain financial arrangements
within an ACO between a PGP and its
members. We discussed our proposals
for downstream distribution
arrangements, which mirror our
proposals for the proposed EPMs
described in section III.I.6. of this final
rule. Specifically, we proposed that
certain financial arrangements between
a collaboration agent that is both a PGP
and an ACO participant and other
individuals termed ‘‘downstream
collaboration agents’’ be termed a
‘‘downstream distribution
arrangement.’’ A downstream
distribution arrangement is a financial
arrangement between a collaboration
agent that is a both a PGP and an ACO
participant and a downstream
collaboration agent for the sole purpose
of sharing a distribution payment
received by the PGP. A downstream
collaboration agent is an individual who
is not a CJR collaborator or a
collaboration agent and who is a PGP
member that has entered into a
downstream distribution arrangement
with the same PGP in which he or she
is an owner or employee, and where the
PGP is a collaboration agent. Where a
payment from a collaboration agent to a
downstream collaboration agent is made
pursuant to a downstream distribution
arrangement, we defined that payment
as a ‘‘downstream distribution
payment.’’ A CJR collaboration agent
may only make a downstream
distribution payment in accordance
with a downstream distribution
arrangement which complies with the
requirements of this section and all
other applicable laws and regulations,
including the fraud and abuse laws.
The proposals for the general
provisions for downstream distribution
arrangements under the CJR model are
included in § 510.506. These provisions
mirror those proposed for the proposed
EPMs in § 512.510(a). We sought
comment on our proposals for these
general provisions, as well as any
alternatives to this structure.
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549
We received no specific comments on
the proposed general provisions for
downstream distribution arrangements
under the CJR model. However, we are
modifying the EPM proposals in
response to the comments that we
received, and therefore, consistent with
our proposal to amend the CJR
regulations to align them with the
EPMs, we are making corresponding
changes to the CJR regulations. We
believe these modifications also will
reduce any burden on hospitals
participating in both CJR and an EPM
that could arise from having to comply
with different requirements for each
model. We refer readers to the
discussion at III.I.6. for further
information.
Final Decision: We are finalizing
effective July 1, 2017 the proposals in
§ 510.510(a) for the general
requirements for CJR downstream
distribution arrangements with
modification to allow NPPGPs or TGPs
to enter into downstream distribution
arrangements with NPPGP members or
TGP members respectively. Downstream
distribution arrangements under the CJR
model must comply with the following
general provisions:
• An ACO participant that is a PGP,
NPPGP, or TGP and that has entered
into a distribution arrangement with a
CJR collaborator that is an ACO may
distribute all or a portion of any
distribution payment it receives from
the CJR collaborator only in accordance
with a downstream distribution
arrangement.
• All downstream distribution
arrangements must comply with the
provisions of this section and all
applicable laws and regulations,
including the fraud and abuse laws.
b. Requirements
We proposed a number of specific
requirements for downstream
distribution arrangements to help
ensure that their sole purpose is to
create financial alignment between
collaboration agents that are PGPs
which are also ACO participants and
downstream collaboration agents toward
the goal of the CJR model to improve the
quality and efficiency of CJR episodes.
We refer readers to section III.I.6.(b) of
this final rule for further discussion of
our proposals regarding downstream
distribution arrangements and our
rationale for each proposal. Our
proposed requirements largely parallel
those proposed in §§ 510.510(b)
and§ 510.505(b) for sharing and
distribution arrangements and
gainsharing and distribution payments
based on similar reasoning for these
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three types of arrangements and
payments.
As listed in § 510.506 and described
in detail in III.I.6(b) of this final rule, we
proposed requirements addressing the
agreements governing downstream
distribution arrangements, eligibility for
receipt of downstream distribution
payments, a cap on the amount of such
payments, the methodologies used to
determine the amount of downstream
distribution payments, and
documentation regarding downstream
distribution arrangements. Specifically,
we proposed that all downstream
distribution arrangements must be in
writing and signed by the parties,
contain the date of the agreement, and
entered into before care is furnished to
CJR beneficiaries under the distribution
arrangement. We proposed that
participation must be voluntary and
without penalty for nonparticipation,
and the downstream distribution
arrangement must require the
downstream collaboration agent to
comply with all applicable laws and
regulations.
As with our proposals for gainsharing
and distribution payments, we proposed
that the opportunity to make or receive
a downstream distribution payment
must not be conditioned directly or
indirectly on the volume or value of
past or anticipated referrals or business
otherwise generated by, between or
among the participant hospital, any CJR
collaborator, any collaboration agent,
any downstream collaboration agent, or
any individual or entity affiliated with
a participant hospital, CJR collaborator,
collaboration agent, or downstream
collaboration agent. In determining the
amount of downstream distribution
payments we proposed a more flexible
approach, as we did with the proposed
EPMs. Consistent with our proposal for
distribution payments, we proposed that
the amount of any downstream
distribution payments must be
determined either in a manner that
complies with § 411.352(g) or that is
substantially based on quality of care
and the provision of CJR activities and
that may take into account the amount
of CJR activities provided by a
downstream collaboration agent relative
to other downstream collaboration
agents. We also proposed that the
amount of a downstream distribution
payment from a PGP to a PGP member
may be determined in a manner that
complies with § 411.352(g) or in a
manner that is substantially based on
quality of care and the provision of CJR
activities.
Similar to our proposed requirements
for distribution arrangements for those
EPM collaborators that are PGPs, we
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proposed that, except for a downstream
distribution arrangement that complies
with § 411.352(g), a downstream
collaboration agent is eligible to receive
a downstream distribution payment
only if the PGP billed for an item or
service furnished by the downstream
collaboration agent to a CJR beneficiary
during a CJR episode that occurred
during the same performance year for
which the participant hospital accrued
the internal cost savings or earned the
reconciliation payment that comprise
the gainsharing payment from which the
ACO made the distribution payment to
the PGP that is an ACO participant. This
approach mirrors our proposed
requirements for distribution
arrangements between collaborators and
collaboration agents, as well as the
proposed approach for the EPMs.
With regard to limitations on the
amount of downstream distribution
payments made to downstream
collaboration agents, we proposed the
same limit as that proposed for
distribution payments by CJR
collaborators that are PGPs. With the
exception of downstream distribution
payments that comply with § 411.352(g),
we proposed to limit the total amount
of downstream distribution payments
paid for a performance year to a
downstream collaboration agent to 50
percent of the total Medicare-approved
amounts under the PFS for services
billed by the PGP and furnished by the
downstream collaboration agent to the
participant hospital’s CJR beneficiaries
during CJR episodes that occurred
during the same performance year in
which the participant hospital accrued
the internal cost savings or earned the
reconciliation payment that comprises
the gainsharing payment from which the
ACO made the distribution payment to
the PGP. We further proposed that the
total amount of all downstream
distribution payments made to
downstream collaboration agents must
not exceed the amount of the
distribution payment received by the
collaboration agent (PGP that is an ACO
participant) from the ACO that is a CJR
collaborator. In addition, all
downstream distribution payments must
be made by check, electronic funds
transfer, or another traceable cash
transaction, as with our proposed
approach for gainsharing, alignment,
and distribution payments. Finally, the
distribution arrangement must not
induce the downstream collaboration
agent to reduce or limit medically
necessary items and services to any
Medicare beneficiary or reward the
provision of items and services that are
medically unnecessary.
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We proposed that the PGP must
maintain contemporaneous
documentation regarding downstream
distribution arrangements in accordance
with § 510.110, including:
• The relevant written agreements;
• The date and amount of any
downstream distribution payment(s);
• The identity of each downstream
collaboration agent that received a
downstream distribution payment; and
• A description of the methodology
and accounting formula for determining
the amount of any downstream
distribution payment.
We proposed that the PGP may not
enter into a downstream distribution
arrangement with any PGP member who
has a sharing arrangement with a
participant hospital or distribution
arrangement with the ACO in which the
PGP is a participant. Finally, we
proposed that the PGP must retain and
provide access to, and must require
downstream collaboration agents to
retain and provide access to, the
required documentation in accordance
with § 510.110.
The proposals for downstream
distribution arrangement requirements
are included in § 510.506. We sought
comment on our proposals.
We received no specific comments on
the proposed requirements for
downstream distribution arrangements
under the CJR model.
Final Decision: We are finalizing
effective July 1, 2017 the proposals in
§ 510.510(b) for the requirements for CJR
downstream distribution arrangements,
with modification to include policies for
NPPGPs or TGPs that enter into
downstream distribution arrangements
with NPPGP members or TGP members
respectively. Consistent with
commenters’ overall request that we
streamline the regulations, we are also
modifying proposed § 510.510(b)(6),
which is final § 510.510(b)(7), to
eliminate one of the two proposed
requirements for eligibility of a
downstream collaboration agent to
receive a downstream distribution
payment, specifically the requirement
that the PGP bill for the item or service
furnished by the downstream
collaboration agent. Instead, we base
downstream collaboration agent
eligibility only on whether the
downstream collaboration agent
furnished an item or service to a CJR
beneficiary during a CJR episode that
occurred during the same performance
year for which the participant hospital
accrued the internal cost savings or
earned the reconciliation payment that
comprises the gainsharing payment
from which the ACO made the
distribution payment to the PGP,
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NPPGP, or TGP that is an ACO
participant. This approach is parallel to
§ 510.505(b)(7), which applies to
distribution payments from ACOs to
ACO participants or ACO providers/
suppliers and certain distribution
payments from PGPs to PGP members,
and ensures that the member of the PGP,
NPPGP, or TGP receiving the
downstream distribution payment
furnished items and services to a CJR
beneficiary during a CJR episode,
without explicitly requiring that the
PGP, NPPGP, or TGP to which the
member of the PGP, NPPGP, or TGP
would have reassigned his or her
benefits also billed for the item or
service. This latter additional
requirement adds complexity that is
unnecessary when our objective of the
requirement is only to ensure that the
recipient of the downstream distribution
payment furnished an item or service to
a CJR beneficiary during a CJR episode
in order to link the payment to actual
care. Finally, as discussed previously, in
order to achieve consistency in the
parameters for gainsharing payments
and distribution payments to therapists
and to streamline programmatic
requirements, we are revising proposed
§ 510.510(b)(7), which is final in
§ 510.510(b)(8), by removing the cap on
downstream distribution payments to
PGP members as applied to therapists
who are PGP members.
An NPPGP that is an ACO participant
that has entered into a distribution
arrangement with a CJR collaborator that
is an ACO may enter into a downstream
distribution arrangement with an
NPPGP member, who is a nonphysician
practitioner or therapist who is an
owner or employee of an NPPGP and
who has reassigned to the NPPGP his or
her right to receive Medicare payment.
The requirements for NPPGP
downstream distribution payments
under those downstream distribution
arrangements are the same as those for
PGPs, except that we allow the amount
of any downstream distribution
payments from a PGP to be determined
in a manner that complies with
§ 411.352(g). The amount of any
downstream distribution payments from
an NPPGP to an NPPGP member must
be determined in accordance with a
methodology that is substantially based
on quality of care and the provision CJR
activities, the same standard that
applies to PGP downstream distribution
payments that are not determined in a
manner that complies with § 411.352(g).
Like the requirement for PGP members
when a downstream distribution
payment does not comply with
§ 411.352(g), an NPPGP member is
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eligible to receive a downstream
distribution payment only if the
downstream collaboration agent
furnished an item or service to a CJR
beneficiary during a CJR episode that
occurred during the same performance
year for which the CJR participant
hospital accrued the internal cost
savings or earned the reconciliation
payment that comprises the gainsharing
payment from which the ACO made the
distribution payment to the NPPGP that
is an ACO participant. Finally, the total
amount of downstream distribution
payments paid for a performance year to
the NPPGP member who is a
nonphysician practitioner may not
exceed 50 percent of the total Medicareapproved amounts under the PFS for
items and services furnished by the
NPPGP member to the CJR participant
hospital’s CJR beneficiaries during CJR
episodes that occurred during the same
performance year for which the CJR
participant hospital accrued the internal
cost savings or earned the reconciliation
payment that comprises the gainsharing
payment from which the ACO made the
distribution payment to the NPPGP that
is an ACO participant. In addition, the
total amount of all downstream
distribution payments made to
downstream collaboration agents must
not exceed the amount of the
distribution payment received by the
NPPGP from the ACO.
A TGP that is an ACO participant that
has entered into a distribution
arrangement with a CJR collaborator that
is an ACO may enter into a downstream
distribution arrangement with a TGP
member, who is a therapist who is an
owner or employee of an NPPGP and
who has reassigned to the TGP his or
her right to receive Medicare payment.
Like downstream distribution payments
from an NPPGP to an NPPGP member,
the amount of any downstream
distribution payments from a TGP to a
TGP member must be determined in
accordance with a methodology that is
substantially based on quality of care
and the provision CJR activities, the
same standard that applies to PGP
distribution payments that are not
determined in a manner that complies
with § 411.352(g). Like the requirement
for PGP members when a distribution
payment does not comply with
§ 411.352(g) and for NPPG members, a
TGP member is eligible to receive a
distribution payment only if the
downstream collaboration agent
furnished an item or service to a CJR
beneficiary during a CJR episode that
occurred during the same performance
year for which the CJR participant
hospital accrued the internal cost
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551
savings or earned the reconciliation
payment that comprises the gainsharing
payment from which the ACO made the
distribution payment to the NPPGP that
is an ACO participant. We will not cap
the total amount of downstream
distribution payments paid for a
performance year to a TGP member.
Finally, the total amount of all
downstream distribution payments
made to downstream collaboration
agents must not exceed the amount of
the distribution payment received by
the TGP from the ACO.
Like PGPs, NPPGPs and TGPs must
maintain contemporaneous
documentation regarding downstream
distribution arrangements. Similarly,
the NPPG or TGP may not enter into a
downstream distribution arrangement
with any NPPG member or TGP member
respectively who has a sharing
arrangement with a CJR participant
hospital or a distribution arrangement
with the ACO the NPPG or TGP is a
participant in.
Downstream distribution
arrangements under the CJR model must
comply with the following
requirements:
• All downstream distribution
arrangements must be in writing and
signed by the parties, contain the date
of the agreement, and be entered into
before care is furnished to CJR
beneficiaries under the downstream
distribution arrangement.
• Participation in a downstream
distribution arrangement must be
voluntary and without penalty for
nonparticipation.
The downstream distribution
arrangement must require the
downstream collaboration agent to
comply with all applicable laws and
regulations.
• The opportunity to make or receive
a downstream distribution payment
must not be conditioned directly or
indirectly on the volume or value of
past or anticipated referrals or business
otherwise generated by, between or
among the CJR participant hospital, any
CJR collaborator, any collaboration
agent, any downstream collaboration
agent, or any individual or entity
affiliated with a CJR participant
hospital, CJR collaborator, collaboration
agent, or downstream collaboration
agent.
• The amount of any downstream
distribution payments from an NPPGP
to an NPPGP member or from a TGP to
a TGP member must be determined in
accordance with a methodology that is
substantially based on quality of care
and the provision CJR activities and that
may take into account the amount of
such CJR activities provided by a
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downstream collaboration agent relative
to other downstream collaboration
agents.
• The amount of any downstream
distribution payments from a PGP to a
PGP member must be determined either
in a manner that complies with
§ 411.352(g) of this chapter or in
accordance with a methodology that is
substantially based on quality of care
and the provision CJR activities, and the
methodology may take into account the
amount of such CJR activities by a
downstream collaboration agent relative
to other downstream collaboration
agents.
• Except for a downstream
distribution payment from a PGP to a
PGP member that complies with
§ 411.352(g), a downstream
collaboration agent is eligible to receive
a downstream distribution payment
only if the downstream collaboration
agent furnished an item or service to a
CJR beneficiary during a CJR episode
that occurred during the same
performance year for which the
participant hospital accrued the internal
cost savings or earned the reconciliation
payment that comprise the gainsharing
payment from which the ACO made the
distribution payment to the PGP,
NPPGP, or TGP that is an ACO
participant.
• Except for a downstream
distribution payment from a PGP to a
PGP member that complies with
§ 411.352(g), the total amount of
downstream distribution payments for a
performance year paid to a downstream
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collaboration agent who is a physician
or nonphysician practitioner and is
either a PGP member or NPPGP member
must not exceed 50 percent of the total
Medicare-approved amounts under the
PFS for items and services furnished by
the downstream collaboration agent to
the participant hospital’s CJR
beneficiaries during CJR episodes that
occurred during the same performance
year for which the participant hospital
accrued the internal cost savings or
earned the reconciliation payment that
comprises the distribution payment
being distributed.
• The total amount of all downstream
distribution payments made to
downstream collaboration agents must
not exceed the amount of the
distribution payment received by the
PGP, NPPGP, or TGP from the ACO.
• All downstream distribution
payments must be made by check,
electronic funds transfer, or another
traceable cash transaction.
• The downstream collaboration
agent must retain his or her ability to
make decisions in the best interests of
the patient, including the selection of
devices, supplies, and treatments.
• The downstream distribution
arrangement must not—
++ Induce the downstream
collaboration agent to reduce or limit
medically necessary services to any
Medicare beneficiary; or
++ Reward the provision of items and
services that are medically unnecessary.
• The PGP, NPPG, or TGP must
maintain contemporaneous
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documentation regarding downstream
distribution arrangements in accordance
with § 510.110, including the following:
++ The relevant written agreements.
The date and amount of any
downstream distribution payment.
++ The identity of each downstream
collaboration agent that received a
downstream distribution payment.
++ A description of the methodology
and accounting formula for determining
the amount of any downstream
distribution payment.
• The PGP, NPPGP, or TGP may not
enter into a downstream distribution
arrangement with any PGP member,
NPPGP member, or TGP member who
has—
++ A sharing arrangement with a CJR
participant hospital; or
++ A distribution arrangement with
the ACO that the PGP, NPPGP, or TGP
is a participant in.
The PGP, NPPGP, or TGP must retain
and provide access to, and must require
downstream collaboration agents to
retain and provide access to, the
required documentation in accordance
with § 510.110.
5. Summary of Proposals for Sharing,
Distribution, and Downstream
Distribution Arrangements Under the
CJR Model.
Figure 4 summarizes the proposals for
the defined terms and financial
arrangements discussed in section V.J.
of this final rule.
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for financial arrangements we proposed
for CJR, whereas Figure 5 summarizes
the policies we are finalizing for these
arrangements as discussed in sections
V.J.4. through V.J.6. of this final rule.
Given the changes to the financial
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arrangement provisions discussed in
V.J. will not be effective until July 1,
2017, Figure 5 is not applicable until
July 1, 2017.
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Our final policies for financial
arrangements reflect a number of
changes to the proposals for the CJR
model financial arrangements in
response to comments on the proposed
rule. Figure 4. summarizes the policies
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K. Beneficiary Incentives Under the CJR
Model
We proposed numerous amendments
to the regulations in § 510.515. These
are mainly for organizational purposes,
to more clearly specify our policies, and
for the CJR model regulations to mirror
the proposed EPM regulations at
§ 512.525 to avoid confusion for
hospitals that are participating in CJR as
well as one or more of the proposed
EPMs. Our proposed changes to the
regulations reflect that the requirements
and rules regarding the use of
beneficiary incentives under the CJR
model would stay largely the same.
However, we proposed several changes
in order to ensure adequate
documentation of beneficiary incentives
by participant hospitals and to align
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with our proposed requirements for the
EPMs.
First, as a program safeguard against
misuse of beneficiary incentives under
the CJR model, we would clarify our
existing requirements for
documentation of beneficiary
incentives. Documentation regarding
items of technology exceeding $100 in
retail value must also include
contemporaneous documentation of any
attempt to retrieve the technology at the
end of a CJR episode. Documented,
diligent, good faith attempts to retrieve
items of technology will be deemed to
meet the retrieval requirement.
We also proposed to add as a
requirement that participant hospitals
retain and provide access to required
documentation pertaining to beneficiary
incentives as discussed throughout
section V.L. of this final rule and
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proposed in § 510.110 of the regulations.
Participant hospitals retaining and
providing access to documentation in
accordance with § 510.110 would
promote parallel record retention for all
CJR model. As discussed in section V.L.
of this final rule, the proposed section
§ 510.110 would apply to beneficiary
incentives as well as financial
arrangements and beneficiary
notification requirements under the CJR
model; therefore, we proposed to delete
§ 510.515(e) to avoid duplicative
requirements and language and to align
the applicable CJR model regulations
with the proposed regulations of the
EPMs.
We proposed to include these
requirements in the regulations at
§§ 510.515(d)(3) and 510.515(d)(4). We
sought comment on our proposal. We
also sought comment on the proposed
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additional requirements for compliance
with proposed section § 510.110 and the
deletion of § 510.515(e). No comments
were submitted in response to our
proposed amendments to the
beneficiary engagement incentives
under the CJR model. Though we did
not propose to change our policies
regarding beneficiary engagement
incentives under the CJR model
commenters provided comments on
beneficiary engagement incentives for
the EPM, which mirrors the CJR model’s
policies.
We refer readers to section III.I.9 for
a detailed discussion of comments and
responses in regards to beneficiary
engagement incentives under these
models.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposals, without
modification. We are making changes
related to beneficiary incentives
effective July 1, 2017 in order to align
the CJR model with the EPMs, avoid
confusion and preserve the existing CJR
regulations until these changes take
effect.
L. Access to Records and Record
Retention
We proposed to consolidate the
requirements under CJR for access to
records and record retention and apply
them more broadly in the model. The
approach mirrors our proposed records
retention policies for the EPMs, which
are discussed in detail in section III.H.
of this final rule. We refer readers to that
section for further discussion of our
proposed policies and rationale.
We proposed to add § 510.110 to the
CJR regulations, which would apply to
documentation regarding beneficiary
notifications, financial arrangements,
and beneficiary incentives. Because we
proposed to consolidate all of the
existing records access and retention
requirements in one place, we proposed
to delete §§ 510.500(e) and § 510.515(c).
We further proposed to require
participant hospitals, CJR collaborators,
collaboration agents, downstream
collaboration agents and any other
individuals or entities performing CJR
activities to allow the Government,
including CMS, OIG, HHS and the
Comptroller General or their designees,
scheduled and unscheduled access to
all books, contracts, records, documents
and other evidence sufficient to enable
the audit, evaluation, inspection or
investigation of the individual or
entity’s compliance with CJR model
requirements, the calculation,
distribution, receipt, or recoupment of
gainsharing payments, alignment
payments, distribution payments, and
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downstream distribution payments, the
obligation to repay any reconciliation
payments owed to CMS, the quality of
the services furnished to a CJR
beneficiary during a CJR episode, and
the sufficiency of CJR beneficiary
notifications.
In general, we proposed that such
documents be maintained for a period of
10 years from the last day of the
participant hospital’s participation in
the CJR model or from the date of
completion of any audit, evaluation,
inspection, or investigation.
We believe these safeguards regarding
access to records and record retention
are necessary to ensure program
integrity and protect against abuse, in
view of the CJR model’s design and
requirements. We believe that by
providing access to CJR records, we
promote transparency of activities in the
CJR model. Further, the proposed access
to records and record retention
requirements would ensure that the
compliance of participant hospitals, CJR
collaborators, collaboration agents,
downstream collaboration agents, and
any other individuals or entities
performing CJR activities can be
monitored and assessed. Also, these
records may be necessary in the event
that a participant hospital appeals any
matter that is subject to dispute
resolution through CMS. As such, CMS
would have the resources necessary to
prepare and respond to any such appeal.
Finally, we proposed to establish
CEHRT use attestation for CJR
participant hospitals so that a CJR
participant hospital could be in Track 1
of the CJR model that meets the
proposed requirements in the Quality
Payment Program proposed rule to be an
Advanced APM as discussed in section
III.A.2. of this final rule. Thus, we
proposed to require access to records
and record retention about the accuracy
of each Track 1 CJR model participant
hospital’s submissions under CEHRT
use requirements. Specifically,
attestation to CEHRT use and
submission of clinician financial
arrangements lists are key requirements
for Track 1 of the CJR model that is an
Advanced APM, and the access to
records and record retention
requirements provide a program
integrity safeguard by allowing us to
assess the completeness and accuracy of
the participant hospital’s compliance
with the requirements for those
submissions.
In summary, we proposed in
§ 510.110 that participant hospitals, CJR
collaborators, collaboration agents,
downstream collaboration agents, and
any other individuals or entities
performing providing CJR activities
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555
must allow the Government, including
CMS, OIG, HHS and the Comptroller
General or their designees, scheduled
and unscheduled access to all books,
contracts, records, documents and other
evidence (including data related to
utilization and payments, quality
criteria, billings, lists of CJR
collaborators, sharing arrangements,
distribution arrangements, downstream
distribution arrangements and the
documentation required under
§ 510.500(d) and § 510.525(c)) sufficient
to enable the audit, evaluation,
inspection or investigation of the
following:
• Individual’s or entity’s compliance
with CJR model requirements.
• The calculation, distribution,
receipt, or recoupment of gainsharing
payments, alignment payments,
distribution payments, and downstream
distribution payments.
• The obligation to repay any
reconciliation payments owed to CMS.
• The quality of the services
furnished to a CJR beneficiary during a
CJR episode.
• The sufficiency of CJR beneficiary
notifications.
• The accuracy of the CJR participant
hospital’s submission under CEHRT use
requirements.
Further, we proposed that participant
hospitals, CJR collaborators,
collaboration agents, downstream
collaboration agents, and any other
individuals or entities performing
providing CJR activities maintain all
such books, contracts, records,
documents, and other evidence for a
period of 10 years from the last day of
the participant hospital’s participation
in the CJR model or from the date of
completion of any audit, evaluation,
inspection, or investigation, whichever
is later, unless CMS determines a
particular record or group of records
should be retained for a longer period
and notifies the participant hospital at
least 30 calendar days before the
disposition date or there has been a
dispute or allegation of fraud or similar
fault against the participant hospital,
CJR collaborator, collaboration agents,
downstream collaboration agents, or any
other individual or entity performing
CJR activities related to the CJR model.
In this case, the records must be
maintained for 6 years from the date of
any resulting final resolution of the
dispute or allegation of fraud or similar
fault.
We sought comment on our proposals,
including whether additional or
different requirements are appropriate
to promote program integrity, prevent
fraud and abuse and promote the goals
of the model. The following is a
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summary of the comments received and
our responses.
Comment: Generally, commenters
were supportive of our proposal in
§ 510.110 to consolidate the
requirements under the CJR model for
access to records and record retention
and apply them more broadly in the CJR
model. However one commenter stated
that requiring participant hospitals, CJR
collaborators, collaboration agents,
downstream collaboration agents, and
any other individuals or entities
performing CJR activities to maintain all
such books, contracts, records,
documents, and other evidence for a
period of 10 years from the last day of
the participant hospital’s participation
in the CJR model or from the date of
completion of any audit, evaluation,
inspection, or investigation, whichever
is later, is an excessive policy, and
would burden entities and individuals
involved in the CJR model. The
commenter suggested that CMS reduce
the 10 year record retention to 6 years,
as the commenter believes that proposal
is more consistent with other CMS
programs. Further, one commenter
recommended that CMS also request
access to records on gainsharing and
other savings-related payments so as to
help examine the extent to which
savings are equitably being shared by
facilities with participating physicians
and other healthcare professionals.
Response: We note that the 10-year
record retention policy is the current
policy of the CJR model. While we
understand the commenter’s concern
that 10 years is excessive, we note that,
once initiated, appeals and recalculation
disputes can be lengthy processes and
believe that maintaining this
requirement as proposed would give
both the participant and CMS as well as
those conducting any audit, evaluation,
inspection, or investigation, the
resources to prepare and respond to
issues that may take several years to
surface. We appreciate the comment
concerning CMS requesting access to
records on gainsharing and other savingrelated payments, and note that in these
final regulations CMS may request from
participant hospitals and their related
CJR collaborators, collaboration agents,
and downstream collaboration agents,
records of the calculation, distribution,
receipt, or recoupment of gainsharing
payments, alignment payments,
distribution payments, and downstream
distribution payments.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal without
modification. Since the changes to the
financial arrangement provisions
discussed in V.J. will not be effective
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until July 1, 2017, we are also making
amendments to related sections effective
July 1, 2017 to avoid confusion and
preserve the existing CJR regulations
until these changes take effect.
M. Waivers of Medicare Program Rules
To Allow Reconciliation Payment or
Repayment Actions Resulting From the
Net Payment Reconciliation Amount
In order to correct a technical error in
the CJR final rule (42 CFR 510.620), we
proposed to waive the requirements of
section 1833(a) of the Act to the extent
that they would otherwise apply to
reconciliation payments or repayments
from a participant hospital under the
CJR model. We proposed this policy in
the CJR proposed rule (80 FR 41274)
and received no comments from the
public on our proposal; the proposal
was finalized in the CJR final rule. We
refer readers to the CJR final rule (80 FR
73460 and 73461) for further discussion.
We proposed to amend our
regulations at § 10.620 to reflect this
change.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal, without
modification.
N. SNF 3-Day Waiver Beneficiary
Protections
The Medicare SNF benefit is for
beneficiaries who require a short-term
intensive stay in a SNF, requiring
skilled nursing, or skilled rehabilitation
care, or both. Under section 1861(i) of
the Act, beneficiaries must have a prior
inpatient hospital stay of no fewer than
3 consecutive days in order to be
eligible for Medicare coverage of
inpatient SNF care. In the November
2015 final rule (80 FR 73454 through
73460), we provided hospitals in the
CJR model with additional flexibility to
attempt to increase quality and decrease
costs by allowing a waiver of the SNF
3-day rule for beneficiaries in a CJR
episode beginning in performance year
2. Program requirements for this waiver
are codified at § 510.610. Specifically,
under § 510.610, for SNFs that meet all
specified requirements, we waive the
requirement in section 1861(i) of the Act
for a 3-day inpatient hospital stay prior
to a Medicare covered post-hospital
extended care service for eligible
beneficiaries in a CJR episode. The CJR
SNF waiver will only be available to
participant hospitals that are active
participants in the CJR model. If a
participant hospital no longer
participates in the CJR model, due to a
merger or other reason, it cannot
continue to use the CJR SNF waiver. All
other provisions of the statute and
regulations regarding Medicare Part A
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post-hospital extended care services
continue to apply.
We believe that clarity regarding
whether a waiver applies to SNF
services furnished to a particular
beneficiary is important to help ensure
compliance with the conditions of the
waiver and also improve our ability to
monitor waivers for misuse. Therefore,
in the CJR final rule (80 FR 73454
through 73460), we discussed how the
waiver can be utilized when a
beneficiary is in a CJR episode at the
time when the waiver is applied. In
addition, at § 510.405 we require
participant hospitals to provide a
discharge planning notice to
beneficiaries in cases where there is
potential beneficiary liability for the
SNF stay (80 FR 73548 through 73549).
Based on our experiences under BPCI
Model 2, the Pioneer ACO Model, and
other initiatives, we established certain
requirements under § 510.610 for
hospitals and SNFs with respect to the
SNF 3-day rule waiver under the CJR
model. As discussed in the CJR final
rule, commenters expressed concern
about beneficiary liability in cases
where the beneficiary’s eligibility status
has changed, but the hospital is
unaware of the change at the time it
uses the waiver. We noted that we
would continue to evaluate the waiver
of the SNF 3-day rule, including further
lessons learned from Innovation Center
models in which a waiver of the SNF 3day rule is being tested. We indicated
that in the event we determine that
additional safeguards or protections for
beneficiaries or other changes were
necessary, such as to incorporate
additional protections for beneficiaries,
we would propose the necessary
changes through future rulemaking.
In considering additional beneficiary
protections that may be necessary to
ensure proper use of the SNF 3-day
waiver under the CJR model, we noted
that there are existing, well-established
payment and coverage policies for SNF
services based on sections 1861(i),
1862(a)(1), and 1879 of the Act that
include protections for beneficiaries
from liability for certain non-covered
SNF charges. These existing payment
and coverage policies for SNF services
continue to apply under the model,
including SNF services furnished
pursuant to the SNF 3-day waiver. (For
example, see section 70 in the Medicare
Claims Processing Manual, Chapter 30—
Financial Liability Protections on the
CMS Web site at https://www.cms.gov/
Regulations-and-Guidance/Guidance/
Manuals/Downloads/clm104c30.pdf;
and Medicare Coverage of Skilled
Nursing Facility Care at https://
www.medicare.gov/Pubs/pdf/10153.pdf;
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Medicare Benefit Policy Manual,
Chapter 8—Coverage of Extended Care
(SNF) Services Under Hospital
Insurance at https://www.cms.gov/
Regulations-and-Guidance/Guidance/
Manuals/downloads/bp102c08.pdf). In
general, CMS requires that the SNF
inform a beneficiary in writing about
services and fees before the beneficiary
is discharged to the SNF (§ 483.10(b)(6));
the beneficiary cannot be charged by the
SNF for items or services that were not
requested (§ 483.10(c)(8)(iii)(A)); a
beneficiary cannot be required to
request extra services as a condition of
continued stay (§ 483.10(c)(8)(iii)(B));
and the SNF must inform a beneficiary
that requests an item or service for
which a charge will be made that there
will be a charge for the item or service
and what the charge will be
(§ 483.10(c)(8)(iii)(C)). (See also section
6 of Medicare Coverage of Skilled
Nursing Facility Care at https://
www.medicare.gov/Pubs/pdf/
10153.pdf.)
As we discussed in the CJR final rule
(80 FR 73454 through 73460),
commenters expressed concern
regarding the lag between a CJR
beneficiary’s Medicare coverage or
eligibility status change and a
participant hospital’s awareness of that
change. There may be cases in which a
SNF waiver is used by a participant
hospital because the participant hospital
believes that the beneficiary meets the
inclusion criteria, based on the
information available to the hospital
and SNF at the time of the beneficiary’s
admission to the SNF, but in fact the
beneficiary’s Medicare coverage has
changed and the hospital was unaware
of it based on available information. We
recognize that despite good faith efforts
by participant hospitals and SNFs to
determine a beneficiary’s Medicare
status for the model, it may occur that
a beneficiary is not eligible to be
included in the CJR model at the time
the SNF waiver is used. In these cases,
we will cover services furnished under
the waiver when the information
available to the provider at the time the
services under the waiver were
furnished indicated that the beneficiary
was included in the model.
Since publication of our final rule, we
have continued to learn from
implementation and refinement of the
SNF 3-day waiver in other models and
the Shared Savings Program. Based on
these experiences, we believe there are
situations where it would be
appropriate to require additional
beneficiary financial protections under
the SNF 3-day waiver for the CJR model.
Specifically, we are concerned about
potential beneficiary financial liability
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for non-covered Part A SNF services
that might be directly related to use of
the SNF 3-day waiver under the CJR
model. We are concerned that there
could be scenarios where a beneficiary
could be charged for non-covered SNF
services that were a result of a
participant hospital’s inappropriate use
of the SNF waiver. Specifically, we are
concerned that a beneficiary could be
charged for non-covered SNF services if
a participant hospital discharges a
beneficiary to a SNF that does not meet
the quality requirement (3 stars or
higher in 7 of the last 12 months), and
payment for SNF services is denied for
lack of a qualifying inpatient hospital
stay. We recognize that requiring a
discharge planning notice (§ 510.405)
will help mitigate concerns about
beneficiaries’ potential financial
liability for non-covered services.
Nevertheless, we are concerned that in
this scenario, once the claim is denied,
the beneficiary may not be protected
from financial liability under existing
Medicare rules because the waiver
would not be available, and the
beneficiary would not have had a
qualifying inpatient hospital stay. Thus,
the CJR beneficiary could be charged by
the SNF for non-covered SNF services
that were a result of an inappropriate
attempt to use the waiver. In this
scenario, Medicare would deny
payment of the SNF claim, and the
beneficiary could potentially be charged
by the SNF for these non-covered SNF
services, potentially subjecting such
beneficiaries to significant financial
liability. In this circumstance, we
assume the participant hospital’s intent
was to rely upon the SNF 3-day waiver,
but the waiver requirements were not
met. We believe that in this scenario,
the rejection of the claim could easily
have been avoided if the hospital had
confirmed that the requirements for use
of the SNF 3-day waiver were satisfied
or if the beneficiary had been provided
the discharge planning notice and
elected to go to a SNF that met the
quality requirement.
Other models have addressed similar
issues in which the beneficiary may be
subject to financial liability for noncovered SNF services related to the
waiver. The Next Generation ACO
Model generally places the risk on the
SNF, where the SNF did not qualify
under the waiver or otherwise knew or
reasonably could be expected to have
known that payment would not be made
for the non-covered SNF services. In
such cases, CMS makes no payment for
the services, and the SNF may not
charge the beneficiary for the services
and must return any monies collected
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557
from the beneficiary. Additionally,
under the Next Generation ACO Model,
the ACO must indemnify and hold the
beneficiary harmless for the services. As
we stated in the proposed rule, we
believe it was appropriate to propose to
adopt a similar policy under the CJR
model. In contrast to the Next
Generation ACO Model, however, we
believe it is most appropriate to hold the
participant hospitals financially
responsible for misusing the waiver in
situations where waiver requirements
are not met, because participant
hospitals are required to be aware of the
3-day waiver requirements. Participant
hospitals are the entities financially
responsible for episode spending under
the model and will make the decision as
to whether it is appropriate to discharge
a beneficiary without a 3-day stay. In
addition, we clearly laid out the
requirements for use of the SNF waiver
in the CJR final rule. Participant
hospitals may begin using the waiver for
episodes that begin in performance year
2, and may only utilize the waiver to
discharge a beneficiary to a SNF that
meets the quality requirements. CMS
will post on the public Web site a list
of qualifying SNFs (those with a 3-star
or higher rating for 7 of the last 12
months). Participant hospitals are
required to consult the published list of
SNFs prior to utilizing the SNF waiver.
As described later in this section, we
proposed that when the hospital
provides the beneficiary with the
discharge notice in accordance with the
requirements of § 510.405(b)(4) (which
elsewhere in this final rule we are
renumbering as § 510.405(b)(3), and
therefore will refer to this provision by
its new number throughout this
section), the hospital would not have
financial liability for non-covered SNF
services that result from inapplicability
of the waiver. In other words, when the
participant hospital has discharged a
beneficiary to a SNF that does not
qualify under the conditions of the
waiver, and has not provided the
required notice so that the beneficiary is
aware that he or she is accepting
financial liability for non-covered SNF
services as a result of not having a
qualifying inpatient stay, as we stated in
the proposed rule, we believe it is
reasonable that the ultimate
responsibility and financial liability for
the non-covered SNF stay should rest
with the participant hospital. For this
reason, we proposed to require hospitals
to keep a record of discharge planning
notice distribution to CJR beneficiaries.
We proposed to monitor participant
hospitals’ use of discharge planning
notices to assess the potential for their
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misuse. We also considered holding the
SNF responsible but decided that since
hospitals, not SNFs, are the CJR model
participants, they therefore should be
held responsible for complying with the
3-day waiver conditions for the reasons
stated previously in this section.
To protect CJR beneficiaries from
being charged for non-covered SNF
charges in instances when the waiver
was used inappropriately, we proposed
to add certain beneficiary protection
requirements in § 510.610. These
requirements would apply for SNF
services that would otherwise have been
covered except for lack of a qualifying
hospital stay. Specifically, we proposed
that beginning with episodes that are
initiated on or after January 1, 2017,
when the SNF waiver is available, if a
participant hospital discharged a
beneficiary without a qualifying 3-day
inpatient stay to a SNF that was not on
the published list of SNFs that meet the
CJR SNF waiver quality requirements as
of the date of admission to the SNF, the
hospital would be financially liable for
the SNF stay if no discharge planning
notice was provided to the beneficiary,
alerting them of potential financial
liability. If the participant hospital
provides a discharge planning notice in
compliance with the requirements of
§ 510.405(b)(3), we proposed that the
participant hospital would not be
financially liable for the cost of the SNF
stay and the normal Medicare FFS rules
for coverage of SNF services will apply.
We proposed that, in cases where the
participant hospital provides a
discharge planning notice in
compliance with the requirements of
§ 510.405(b)(3) and the beneficiary
chooses to obtain care from a nonqualified SNF without a qualifying
inpatient stay, the beneficiary assumes
financial liability for services furnished
(except those covered by Medicare Part
B during a non-covered inpatient SNF
stay).
In the event a CJR beneficiary is
discharged to a SNF without a
qualifying 3-day inpatient stay, but the
SNF is not on the qualified list as of the
date of admission to the SNF, and the
participant hospital has failed to
provide a discharge planning notice, as
specified in § 510.405(b)(3), we
proposed that CMS apply the following
rules:
• CMS shall make no payment to the
SNF for such services.
• The SNF shall not charge the
beneficiary for the expenses incurred for
such services; and the SNF shall return
to the beneficiary any monies collected
for such services.
• The hospital shall be responsible
for the cost of the uncovered SNF stay.
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In addition, we proposed to amend
our regulations to clarify that the SNF
3-day waiver will be available in
performance years 2 through 5 for those
episodes beginning on or after January
1, 2017. In the CJR final rule, we
discussed how the SNF 3-day waiver
will be available beginning in
performance year 2. We proposed to
clarify that the waiver does begin in
performance year 2, but only for those
episodes that begin on or after January
1, 2017 when the waiver goes into
effect.
We sought comment on these
proposals. Specifically, we sought
comment on whether it is reasonable
to—(1) cover services furnished under
the SNF waiver based on participant
hospital knowledge of beneficiary
eligibility for the CJR model as
determined by Medicare coverage status
at the time the services under the waiver
were furnished; and (2) to hold the
participant hospital financially
responsible for denied SNF claims if a
CJR beneficiary is discharged to a SNF
without a qualifying 3-day inpatient
stay, but the SNF is not on the qualified
list as of the date of admission to the
SNF, and the participant hospital has
failed to provide a discharge planning
notice as specified in § 510.405(b)(3).
We sought comment on whether SNFs
instead of, or in addition to, the
participant hospital should be held
liable for such claims and under what
circumstances. Finally, we sought
comment on any other related issues
that we should consider in connection
with the proposal to protect
beneficiaries from significant financial
liability for non-covered SNF services
related to the waiver of the SNF 3-day
rule under the CJR model. We may
address those issues through future
notice and comment rulemaking.
We proposed to amend our
regulations at § 510.610 to reflect the
change. We also proposed to clarify the
language in § 510.610 to reflect that the
CJR SNF waiver will be available for use
for episodes that begin on or after
January 1, 2017.
We received comments on similar
waivers for the EPM, which we
addressed in III.J of the EPM final rule.
The following is a summary of the
comments received on the CJR SNF 3day waiver and our responses.
Comment: Commenters requested
clarification discharge planning as it
relates to application and use of the SNF
3-day waiver.
Response: CMS requires participant
hospitals to provide written notice to
beneficiaries informing them of
potential financial liability associated
with non-covered services presented as
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an option as part of discharge planning,
as outlined at § 510.405(b)(4) of the CJR
final rule, and amended in this final
rule as § 510.405(b)(3). We refer readers
to the CJR final rule (80 FR 73516–
73521) and § 510.405(b)(3) for further
discussion of this requirement.
Comment: Some commenters
proposed that CMS modify the Bundled
Payments for Care Initiative (BPCI) SNF
3-day waiver to more closely align with
the CJR model’s SNF 3-day waiver.
Response: We did not make any
proposals in this rule with respect to
BPCI.
Comment: Some commenters inquired
about the process if a hospital wishes to
utilize the SNF 3-day waiver, but the
beneficiary wishes to remain in the
hospital.
Response: As stated in 80 FR 73516,
the CJR model does not seek to limit the
beneficiary’s ability to choose among
Medicare providers or the range of
services available. Decisions about the
length of an inpatient stay are not
addressed in this rule.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal without
modification to cover services furnished
under the SNF waiver in cases where
the beneficiary met the criteria at
§ 510.205 on the date of discharge from
the anchor hospitalization, based on
information available as of that date. We
are also finalizing the proposal to hold
the participant hospital financially
responsible for denied SNF claims if a
CJR beneficiary is discharged to a SNF
without a qualifying 3-day inpatient
stay, but the SNF is not on the qualified
list as of the date of admission to the
SNF, and the participant hospital has
failed to provide a discharge planning
notice as specified in § 510.405(b)(3).
We are not finalizing the proposal to
specify that the SNF waiver will be
available for use for episodes that begin
on or after January 1, 2017, as the
change is no longer necessary given the
effective date of this final rule. The final
policies for financial liability for noncovered SNF services provided due to
incorrect application of the SNF 3-day
rule waiver are set forth in § 510.610.
O. Advanced Alternative Payment
Model Considerations
1. Overview for CJR
The MACRA created two paths for
eligible clinicians to link quality to
payments: The MIPS and Advanced
APMs. These two paths create a flexible
payment system called the Quality
Payment Program as proposed by CMS
in the Quality Payment Program
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proposed rule (81 FR 28161 through
28586).
As proposed in the Quality Payment
Program proposed rule, an APM must
meet three criteria to be considered an
Advanced APM (81 FR 28298). First, the
APM must provide for payment for
covered professional services based on
quality measures comparable to
measures described under the
performance category described in
section 1848(q)(2)(B)(i) of the Act,
which is the MIPS quality performance
category. We refer to the discussion
following our proposals for the final
criteria required for the APM to be an
Advanced APM. Under the Quality
Payment Program proposed rule, we
proposed that the quality measures on
which the Advanced APM bases
payment for covered professional
services (as that term is defined in
section 1848(k)(3)(A) of the Act) must
include at least one of the following
types of measures, provided that they
have an evidence-based focus and are
reliable and valid (81 FR 28302):
• Any of the quality measures
included on the proposed annual list of
MIPS quality measures.
• Quality measures that are endorsed
by a consensus-based entity.
• Quality measures developed under
section 1848(s) of the Act.
• Quality measures submitted in
response to the MIPS Call for Quality
Measures under section 1848(q)(2)(D)(ii)
of the Act.
• Any other quality measures that
CMS determines to have an evidencebased focus and be reliable and valid.
As we discussed in the Quality
Payment Program proposed rule,
because the statute identifies outcome
measures as a priority measure type and
we wanted to encourage the use of
outcome measures for quality
performance assessment in APMs, we
further proposed in that rule, that in
addition to the general quality measure
requirements, an Advanced APM must
include at least one outcome measure if
an appropriate measure is available on
the MIPS list of measures for that
specific QP Performance Period,
determined at the time when the APM
is first established (81 FR 28302 through
28303).
Second, the APM must either require
that participating APM Entities bear risk
for monetary losses of a more than
nominal amount under the APM or be
a Medical Home Model expanded under
section 1115A(c) of the Act. Except for
Medical Home Models, we proposed in
the Quality Payment Program proposed
rule that, for an Advanced APM to meet
the nominal amount standard, the
specific level of marginal risk must be
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at least 30 percent of losses in excess of
expected expenditures; a minimum loss
rate, to the extent applicable, must be no
greater than 4 percent of expected
expenditures; and total potential risk
must be at least 4 percent of expected
expenditures (81 FR 28306).
Third, the APM must require
participants to use CEHRT (as defined
in section 1848(o)(4) of the Act), as
specified in section 1833(z)(3)(D)(i)(I) of
the Act, to document and communicate
clinical care with patients and other
health care professionals. Specifically,
where the APM participants are
hospitals, the APM must require each
hospital to use CEHRT (81 FR 28298
through 28299).
In the proposed rule (81 FR 50794),
we proposed to adopt two different
tracks for CJR—Track 1 in which CJR
and its participant hospitals would meet
the criteria for Advanced APMs as
proposed in the Quality Payment
Program proposed rule, and Track 2 in
which CJR and its participant hospitals
would not meet those proposed criteria.
We refer to the discussion following our
proposals for the final criteria required
for the APM to be an Advanced APM.
The CJR model incorporates a pay-forperformance methodology including
quality measures that we believe would
meet the proposed Advanced APM
quality measure requirements in the
Quality Payment Program proposed
rule. Both of the required quality
measures in the CJR model are NQFendorsed, have an evidence-based focus,
and are reliable and valid. We believe
they would meet the proposed
Advanced APM general quality measure
requirements.
The CJR pay-for-performance
methodology includes one outcome
measure that is NQF-endorsed, has an
evidence-based focus, and is reliable
and valid. The pay-for-performance
methodology incorporates the Hospitallevel RSCR following elective primary
THA and/or TKA (NQF #1550) (Hip/
Knee Complications) outcome measure.
Thus, we believe the CJR model would
meet the requirement proposed for
Advanced APMs in the Quality Payment
Program proposed rule for use of an
outcome measure that also meets the
general quality measure requirements.
In terms of the proposed nominal risk
criteria for Advanced APMs, beginning
in performance year 2 for episodes
ending between January 1, 2017 and
December 31, 2017, participant
hospitals would begin to bear downside
risk for excess actual CJR episode
spending above the quality-adjusted
target price. The marginal risk for excess
actual CJR episode spending above the
quality-adjusted target price would be
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559
100 percent over the range of spending
up to the stop-loss limit, which would
exceed 30 percent marginal risk, and
there would be no minimum loss rate.
As a result, we believe the CJR model
would meet the marginal risk and
minimum loss rate elements of the
nominal risk criteria for Advanced
APMs proposed in the Quality Payment
Program proposed rule. Total potential
risk for most CJR participant hospitals is
5 percent of expected expenditures in
performance year 2, and increasing in
subsequent performance years.
Therefore, we believe the total potential
risk applicable to most participant
hospitals, with the lowest total potential
risk being 5 percent for CJR episodes
ending on or after January 1, 2017 in
performance year 2, would meet the
total potential risk element of the
nominal risk amount standard for
Advanced APMs proposed in the
Quality Payment Program proposed rule
because it is greater than the value of at
least 4 percent of expected
expenditures.
We note that participant hospitals that
are rural hospitals, sole community
hospitals (SCHs), Medicare Dependent
Hospitals (MDHs) and Rural Referral
Centers (RRCs) will have a stop-loss
limit of 3 percent in performance year
2. Because 3 percent is less than the
proposed threshold of at least 4 percent
of expected expenditures for total
potential risk proposed for Advanced
APMs in the Quality Payment Program
proposed rule, those rural hospitals,
SCHs, MDHs, and RRCs that are CJR
participant hospitals subject to special
protections would be in Track 2 of the
CJR model and would not meet the
proposed nominal risk standard for
Advanced APMs for performance year 2.
We recognize that the proposal might
initially limit the ability of rural
hospitals, SCHs, MDHs, and RRCs to be
in an Advanced APM for performance
year 2. We believe this potential
limitation on rural hospitals, SCHs,
MDHs, and RRCs is appropriate for the
following reasons: (1) Greater risk
protections for these hospitals under the
CJR model beginning in performance
year 2 and subsequent performance
years compared to other participant
hospitals are necessary, regardless of
their implications regarding Advanced
APMs based on the nominal risk
standard proposed in the Quality
Payment Program proposed rule,
because these hospitals have unique
challenges that do not exist for most
other hospitals, such as being the only
source of health care services for
beneficiaries or certain beneficiaries
living in rural areas or being located in
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areas with fewer providers, including
fewer physicians and post-acute care
facilities; and (2) under the CJR risk
arrangements, these hospitals would not
bear an amount of risk in performance
year 2 that we determined to be more
than nominal in the Quality Payment
Program proposed rule. However, we
sought comment on whether we should
allow participant hospitals that are rural
hospitals, SCHs, MDHs, or RRCs to elect
a higher stop-loss limit for performance
year 2 where downside risk applies in
order to permit these hospitals to be in
Track 1 of the CJR model for
performance year 2. We noted that by
performance year 3, the stop-loss limit
for these hospitals with special
protections under the CJR model would
increase to 5 percent under our
proposal, so the hospitals could be in
Track 1 based on the nominal risk
standard proposed in the Quality
Payment Program proposed rule.
As addressed in the Quality Payment
Program proposed rule, it is necessary
for an APM to require the use of CEHRT
in order to meet the criteria to be
considered to be an Advanced APM.
Therefore, according to the
requirements proposed in the Quality
Payment Program proposed rule, so that
the CJR model may meet the proposed
criteria to be an Advanced APM, we
proposed to require participant
hospitals to use CEHRT (as defined in
section 1848(o)(4) of the Act) to
participate in Track 1 of the CJR model.
We proposed that Track 1 participant
hospitals must use certified health IT
functions, in accordance with the
definition of CEHRT under our
regulation at 42 CFR 414.1305, to
document and communicate clinical
care with patients and other health care
professionals as proposed in the Quality
Payment Program proposed rule (81 FR
28299). We believe the proposal would
allow Track 1 of CJR to be able to meet
the proposed criteria to be an Advanced
APM.
Without the collection of identifying
information on eligible clinicians
(physicians, non-physician
practitioners, physical and occupational
therapists, and qualified speechlanguage pathologists) who would be
considered affiliated practitioners as
proposed in the Quality Payment
program proposed rule under the CJR
model, CMS would not be able to
consider participation in the model in
making determinations as to whom
could be considered a QP (81 FR 28320).
As detailed in the Quality Payment
Program proposed rule, these
determinations are based on the
whether the eligible clinician meets the
QP threshold under either the Medicare
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Option starting in payment year 2019 or
the All-Payer Combination Option,
which is available starting in payment
year 2021 (81 FR 28165). Thus, we made
proposals in subsequent sections to
specifically address these issues that
might otherwise preclude the CJR model
from being considered an Advanced
APM, or prevent us from
operationalizing it as an Advanced
APM. Based on the proposals for
Advanced APM criteria in the Quality
Payment Program proposed rule, we
sought to align the design of the CJR
model with the proposed Advanced
APM criteria and enable CMS to have
the necessary information on eligible
clinicians to make the requisite QP
determinations.
Based on the proposals for Advanced
APM criteria in the Quality Payment
Program proposed rule (81 FR 28161),
we sought to align the design of the CJR
model Advanced APM track with the
proposed Advanced APM criteria and
enable CMS to have the necessary
information on Eligible Clinicians to
make the requisite QP determinations.
As detailed in the Quality Payment
Program final rule with comment
period, QP determinations are based on
whether the Eligible Clinician meets the
QP threshold under either the Medicare
Option starting in payment year 2019 or
the All-Payer Combination Option,
which is available starting in payment
year 2021 (81 FR 77013). The three
criteria for an Advanced APM were
finalized in the Quality Payment
Program final rule with comment period
(81 FR 77008), and we continue to align
the design of the CJR model Advanced
APM track with the finalized Advanced
APM criteria so that the CJR track that
meets such criteria may be an Advanced
APM. To be determined to be an
Advanced APM, an APM must meet
three Advanced APM criteria identified
in § 414.1415 and discussed specifically
later in this section.
First, the APM must require
participants to use CEHRT (as defined
in section 1848(o)(4) of the Act), as
specified in section 1833(z)(3)(D)(i)(I) of
the Act, to document and communicate
clinical care with patients and other
health care professionals (81 FR 77406).
Specifically, where the APM
participants are hospitals, the APM
must require each hospital to use
CEHRT. As addressed in the Quality
Payment Program final rule with
comment period, it is necessary for an
APM to require the use of CEHRT in
order to meet the criteria to be
considered to be an Advanced APM.
Therefore, according to the
requirements now finalized in the
Quality Payment Program final rule
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with comment period, so that a track of
the CJR model may meet the finalized
criteria to be an Advanced APM, we
proposed that those CJR participant
hospitals who choose to participate in
Track 1 of the CJR model must use
certified health IT functions, in
accordance with the definition of
CEHRT under our regulation at 42 CFR
414.1305, to document and
communicate clinical care with patients
and other health care professionals. We
believe that this proposal set forth in the
EPM proposed rule would allow CJR
participant hospitals who use and attest
to use of CEHRT to be in an APM that
meets the first finalized Advanced APM
criterion.
Second, the APM must provide for
payment to participants based on
quality measures comparable to
measures described under the
performance category described in
section 1848(q)(2)(B)(i) of the Act,
which is the MIPS quality performance
category. We interpret this criterion to
require the APM to incorporate quality
measure results as a factor when
determining payment to participants
under the terms of the APM as
described in the Quality Payment
Program final rule with comment period
(81 FR 77414). In order to align the CJR
model Advanced APM track with the
Quality Payment Program final rule
with comment period, the quality
measures on which the Advanced APM
bases payment to participants must
include at least one of the following
types of measures, provided that they
have an evidence-based focus and are
reliable and valid (81 FR 77418):
Any of the quality measures included
on the proposed annual list of MIPS
quality measures.
Quality measures that are endorsed by
a consensus-based entity.
Quality measures developed under
section 1848(s) of the Act.
Quality measures submitted in
response to the MIPS Call for Quality
Measures under section 1848(q)(2)(D)(ii)
of the Act.
Any other quality measures that CMS
determines to have an evidence-based
focus and be reliable and valid.
As we discussed in the Quality
Payment Program final rule with
comment period, because the statute
identifies outcome measures as a
priority measure type and we want to
encourage the use of outcome measures
for quality performance assessment in
APMs, we further finalized in that rule
that, in addition to the general quality
measure requirements, an Advanced
APM must include at least one outcome
measure if an appropriate measure is
available on the MIPS list of measures
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for that specific QP Performance Period,
determined at the time when the APM
is first established (81 FR 77418).
Therefore, according to the
requirements finalized in the Quality
Payment Program final rule with
comment period and the quality
measures adopted for the CJR model in
the CJR Final Rule (80 FR 73375), the
CJR model will meet the second
finalized criterion of the Advanced
APM criteria.
Third, the Quality Payment Program
final rule with comment period requires
that for an APM to meet the Advanced
APM criteria, the APM must either
require that participating APM Entities
bear risk for monetary losses of a more
than nominal amount under the APM or
be a Medical Home Model expanded
under section 1115A(c) of the Act. For
the purposes of the EPM, the generally
applicable nominal amount standard for
an Advanced APM in the Quality
Payment Program final rule with
comment period (81 FR 77425) means
the total amount an APM Entity
potentially owes CMS or foregoes under
an APM must be at least equal to 3
percent of the expected expenditures for
which an APM Entity is responsible
under the APM. The generally
applicable financial risk standard (81 FR
77422) means when an APM Entity’s
actual expenditures for which the APM
Entity is responsible under the APM
exceed expected expenditures during a
specified QP Performance Period, the
APM Entity is required to owe
payment(s) to CMS. We refer to the
Quality Payment Program final rule
with comment period for a discussion
regarding why we did not finalize the
specific level of marginal risk or
minimum loss rate (81 FR 77426).
However, consistent with the
commitments we made to adhere to the
proposed marginal risk and minimum
loss rate requirements in the Quality
Payment Program proposed rule, we
note that the financial risk in this final
rule when the EPMs involve downside
risk exceeds the proposed marginal risk
and minimum loss rate requirements
proposed for the Quality Payment
Program. As discussed in section III.C.
of the CJR Final Rule (80 FR 73324
through 73358), the final total initial
risk of expected expenditures for EPM
participants of 5 percent, except for
rural hospitals, SCHs, MDHs, and RRCs
subject to special protections at 3
percent, beginning in performance year
2 when downside risk first applies to all
participants would meet the total
potential risk element of the nominal
risk amount standard for Advanced
APMs finalized in the Quality Payment
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Program final rule with comment period
(81 FR 77427) because it is greater than
the value of at least 3 percent of
expected expenditures. Therefore,
according to the requirements finalized
in the Quality Payment Program final
rule with comment period and the
payment methodology for CJR
participant hospitals finalized in the
CJR Final Rule (80 FR 73324 through
73358), all CJR participant hospitals in
performance year 2 will be in an APM
that meets the third finalized criterion
of the Advanced APM criteria.
Finally, we finalized in the Quality
Payment Program final rule with
comment period (81 FR 77442) that for
Advanced APMs, such as episode
payment models, in which there are
some Advanced APM Entities that
include Eligible Clinicians on a
Participation List and other Advanced
APM Entities that identify Eligible
Clinicians only on an Affiliated
Practitioner List, we will identify
Eligible Clinicians for QP
determinations based on the
composition of the Advanced APM
Entity. In the scenario that applies to the
CJR model, which includes only
hospitals as Advanced APM Entities on
the Participation List, for those
Advanced APM Entities where there is
an Affiliated Practitioner List that
identifies Eligible Clinicians, that
Affiliated Practitioner List will be used
to identify the Eligible Clinicians for
purposes of QP determinations, and
those Eligible Clinicians will be
assessed individually. Thus, to
operationalize the CJR model as an
Advanced APM, our proposal for the
CJR model to identify Eligible Clinicians
on a clinician financial arrangements
list to construct the Affiliated
Practitioner list would identify those
Eligible Clinicians for purposes of QP
determination, consistent with the
policies finalized in the Quality
Payment Program final rule with
comment period.
2. CJR Participant Hospital Tracks
To be considered an Advanced APM,
the APM must require participants to
use CEHRT (as defined in section
1848(o)(4) of the Act), as specified in
section 1833(z)(3)(D)(i)(I) of the Act. We
proposed that all participant hospitals
must choose whether to meet the
CEHRT use requirement. Participant
hospitals that do not meet and attest to
the CEHRT use requirement would be in
Track 2 of the CJR model. Participant
hospitals selecting to meet the CEHRT
use requirement would be in Track 1 of
the CJR model and would be required to
attest in a form and manner specified by
CMS to their use of CEHRT that meets
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561
the definition in our regulation at
section 414.1305 to document and
communicate clinical care with patients
and other health professionals,
consistent with the proposal in the
Quality Payment Program proposed rule
for the CEHRT requirement for
Advanced APMs (81 FR 28299).
Participant hospitals choosing not to
meet and attest to the CEHRT use
requirement would not be required to
submit an attestation.
We believe that the selection by the
participant hospital to meet and attest to
the CEHRT use requirement would
create no significant additional
administrative burden on participant
hospitals. Moreover, the choice of
whether to meet and attest to the
CEHRT use requirement would not
otherwise change any participant
hospital’s requirements or opportunity
under the CJR model. However, to the
extent the eligible clinicians who enter
into financial arrangements related to
Track 1 CJR participant hospitals are
considered to furnish services through
an Advanced APM, those services could
be considered for purposes of
determining whether the eligible
clinicians are QPs.
The proposals for CEHRT use and
attestation for participant hospitals are
included in § 510.120(a). We sought
comment on our proposals for CJR
tracks and participant hospital
requirements.
We received a number of comments
on our proposals in this section that
applied to both the EPMs and the CJR
model, and no comments unique to the
CJR model. We refer to sections III.A.2.a.
and b. of this final rule for a summary
of the comments and our responses.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal, with
modification to use the term ‘‘specified’’
for consistency with CEHRT attestation
in other CMS programs, to include in
§ 510.120(a) the CEHRT use and
attestation for CJR participant hospitals.
For performance year 2 through 5, CJR
participant hospitals choose either of
the following:
• CEHRT use. Participant hospitals
attest in a form and manner specified by
CMS to their use of CEHRT as defined
in § 414.1305 of this chapter to
document and communicate clinical
care with patients and other health
professionals.
• No CEHRT use. Participant
hospitals do not attest in a form and
manner specified by CMS to their use of
CEHRT as defined in § 414.1305 of this
chapter to document and communicate
clinical care with patients and other
health professionals.
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3. Clinician Financial Arrangements
Lists Under the CJR Model
In order for CMS to make
determinations as to eligible clinicians
who could be considered QPs based on
services furnished under the CJR model
(to the extent the model is determined
to be an Advanced APM), we require
accurate information about eligible
clinicians who enter into financial
arrangements under Track 1 of CJR
under which the Affiliated Practitioners
support the participant hospitals’ cost or
quality goals as discussed in section V.J.
of this final rule. We note that eligible
clinicians could be CJR collaborators
engaged in sharing arrangements with a
CJR participant hospital; PGP members
who are collaboration agents engaged in
distribution arrangements with a PGP
that is a CJR collaborator; or PGP
members who are downstream
collaboration agents engaged in
downstream distribution arrangements
with a PGP that is also an ACO
participant in an ACO that is a CJR
collaborator. These terms as they apply
to individuals and entities with
financial arrangements under CJR are
discussed in section V.J. of this final
rule. A list of physicians and
nonphysician practitioners in one of
these three types of arrangements could
be considered an Affiliated Practitioner
List of eligible clinicians who are
affiliated with and support the
Advanced APM Entity in its
participation in the Advanced APM as
proposed in the Quality Payment
Program proposed rule. Therefore, this
list could be used to make
determinations of who would be
considered for a QP determination
based on services furnished under the
CJR model (81 FR 28320).
Thus, we proposed that each
participant hospital that chooses to meet
and attest to the CEHRT use
requirement must submit to CMS a
clinician financial arrangements list in a
form and manner specified by CMS on
a no more than quarterly basis. The list
must include the following information
for the period of the CJR performance
year specified by CMS:
• For each CJR collaborator who is a
physician, nonphysician practitioner, or
provider of outpatient therapy services
during the period of the CJR
performance year specified by CMS—
++ The name, tax identification
number (TIN), and national provider
identifier (NPI) of the CJR collaborator;
and
++ The start date and, if applicable,
end date, for the sharing arrangement
between the CJR participant hospital
and the CJR collaborator.
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• For each collaboration agent who is
a physician or nonphysician
practitioner of a PGP that is a CJR
collaborator during the period of the CJR
performance year specified by CMS—
++ The TIN of the PGP that is the CJR
collaborator, and the name and NPI of
the physician or nonphysician
practitioner; and
++ The start date and, if applicable,
end date, for the distribution
arrangement between the CJR
collaborator that is a PGP and the
physician or nonphysician practitioner
who is a PGP member.
• For each downstream collaboration
agent who is a physician or
nonphysician practitioner member of a
PGP that is also an ACO participant in
an ACO that is a CJR collaborator during
the period of the CJR performance year
specified by CMS—
++ The TIN of the PGP that is the
ACO participant, and the name and NPI
of the physician or nonphysician
practitioner; and
++ The start date and, if applicable,
end date, for the downstream
distribution arrangement between the
collaboration agent that is both PGP and
an ACO participant and the physician or
nonphysician practitioner who is a PGP
member.
• If there are no individuals that meet
the requirements to be reported as CJR
collaborators, collaboration agents, or
downstream collaboration agents, the
participant hospital must attest in a
form and manner required by CMS that
there are no individuals to report on the
clinician financial arrangements list.
As discussed in the Quality Payment
program proposed rule, those
physicians or nonphysician
practitioners who are included on the
Affiliated Practitioner List as of
December 31 of a performance period
would be assessed to determine whether
they qualify for APM Incentive
Payments (81 FR 28320). The Quality
Payment Program final rule with
comment period (81 FR 77444) modified
this process to identify eligible
clinicians on the Affiliated Practitioner
List for QP determinations at any one of
three snapshots. The first snapshot will
be on March 31 of the QP Performance
Period, the second snapshot will be on
June 30 of the QP Performance Period,
and the third snapshot will be on
August 31, which will be the last day of
the QP Performance Period.
While the submission of this required
information may create some additional
administrative requirements for certain
participant hospitals, we expect that
Track 1 participant hospitals could
modify their contractual relationships
with their CJR collaborators and,
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correspondingly, require those
collaborators to include similar
requirements in their contracts with
collaboration agents and in the contracts
of collaboration agents with
downstream collaboration agents.
The proposal for the submission of a
clinician financial arrangements list by
participant hospitals that meet and
attest to the CEHRT use requirements
for the CJR model is included in
§ 510.120(b). We sought comments on
the proposal for submission of this
information. We noted that we were
especially interested in comments about
approaches to information submission,
including the periodicity and method of
submission to CMS that would
minimize the reporting burden on
participant hospitals while providing
CMS with sufficient information about
eligible clinicians in order to facilitate
QP determinations to the extent the CJR
model is considered to be an Advanced
APM.
We received a number of comments
on our proposals in this section that
applied to both the EPMs and the CJR
model and no comments unique to the
CJR model. We refer to section III.A.2.c.
of this final rule for a summary of the
comments and our responses.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal in § 510.120(b),
with modification to include on the
clinician financial arrangements list all
individuals with financial arrangements
under the CJR model in 2017 through
June 30, 2017 under the existing
definitions and provisions of Part 510
and from July 1, 2017 and thereafter
under the provisions effective July 1,
2017 as finalized in section V.J. of this
final rule, and for CJR participant
hospitals that meet and attest to the
CEHRT use requirement to also submit
on a no more than quarterly basis a
clinician financial arrangements list.
While we are finalizing the regulations
generally as proposed, effective with the
effective date of this final rule, we are
delaying until July 1, 2017 the effective
date of certain provisions that refer to
individuals with financial arrangements
for which the financial arrangements
provisions take effect July 1, 2017. The
implementation of the reporting
requirements for the clinician financial
arrangements list in two stages in 2017
will ensure that all physicians,
nonphysician practitioners, and
therapists with financial arrangements
in association with CJR hospital
participants that attest to CEHRT use
can be reported on the clinician
financial arrangements lists during the
snapshots in 2017 for the Quality
Payment Program, regardless of the
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changes to the definitions and types of
collaborators under the CJR model
effective July 1, 2017.
Effective with the effective date of this
final rule, each participant hospital that
chooses CEHRT use must submit to
CMS a clinician financial arrangements
list in a form and manner specified by
CMS on a no more than quarterly basis.
The list must include the following
information on individuals and entities
for the period of the CJR performance
year specified by CMS:
• CJR collaborators. For each CJR
collaborator who is a physician,
nonphysician practitioner, or therapist
in private practice during the period of
the CJR performance year specified by
CMS:
++ The name, TIN, and NPI of the
CJR collaborator.
++ The start date and, if applicable,
end date, for the sharing arrangement
between the CJR participant hospital
and the CJR collaborator.
• Practice collaboration agents. For
each physician, nonphysician
practitioner, or therapist who is a CJR
practice collaboration agent during the
period of the CJR performance year
specified by CMS:
++ The name and TIN of the CJR
collaborator and the name, TIN, and NPI
of the practice collaboration agent.
++ The start date and, if applicable,
end date, for the distribution
arrangement between the CJR
collaborator and the practice
collaboration agent.
• Attestation to no individuals. If
there are no individuals that meet the
requirements to be reported, the
participant hospital must attest in a
form and manner required by CMS that
there are no individuals to report on the
clinician financial arrangements list.
Effective July 1, 2017, the provisions
for practice collaboration agents on the
clinician financial arrangements list will
be revised to use the term collaboration
agent instead, stating:
• Collaboration agents. For each
physician, nonphysician practitioner, or
therapist who is a collaboration agent
during the period of the CJR
performance year specified by CMS:
++ The name and TIN of the CJR
collaborator and the name, TIN, and NPI
of the collaboration agent.
++ The start date and, if applicable,
end date, for the distribution
arrangement between the CJR
collaborator and the collaboration agent.
Effective July 1, 2017, new provisions
for downstream collaboration agents on
the clinician financial arrangements list
will be added, stating:
• Downstream collaboration agents.
For each physician, nonphysician
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practitioner, or therapist who is a
downstream collaboration agent during
the period of the CJR performance year
specified by CMS—
++ The name and TIN of the CJR
collaborator and the name and TIN of
the collaboration agent and the name,
TIN, and NPI of the downstream
collaboration agent.
++ The start date and, if applicable,
end date, for the downstream
distribution arrangement between the
collaboration agent and the downstream
collaboration agent.
4. Documentation Requirements
For each participant hospital that
chooses to meet and attest to CEHRT
use, we proposed that the participant
hospital must maintain documentation
of its attestation to CEHRT use and
clinician financial arrangements lists
submitted to CMS. These documents
would be necessary to assess the
completeness and accuracy of materials
submitted by a participant hospital in
Track 1 of CJR and to facilitate
monitoring and audits. For the same
reason, we further proposed that the
participant hospital must retain and
provide access to the required
documentation in accordance with
§ 510.110.
The proposal for documentation of
attestation to CEHRT use and clinician
financial arrangements lists submitted
to CMS is included in § 510.120(c). We
sought comment on this proposal for
required documentation.
Final Decision: We did not receive
comments pertaining to § 510.120(c).
Therefore, we are finalizing the proposal
for CJR participant hospital
documentation of attestation to CEHRT
use and clinician financial arrangements
lists submitted to CMS, with
modification to implement the
documentation provisions in two stages.
The following documentation
requirements apply to CJR participant
hospitals choosing CEHRT use. We note
that while the requirement for CJR
participant hospitals to maintain
documentation of attestation to CEHRT
use and clinician financial arrangements
lists will be effective on the effective
date of this final rule, the effective date
of the provision for retention and the
provision of access to the required
documentation will delayed until July 1,
2017 to correspond to the similar delay
in the effective date of § 510.110 to July
1, 2017, for reasons described elsewhere
in this final rule.
• Each participant hospital that
chooses CEHRT use must maintain
documentation of their attestation to
CEHRT use and clinician financial
arrangements lists.
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563
• The participant hospital must retain
and provide access to the required
documentation in accordance with
§ 510.110.
VI. Cardiac Rehabilitation Incentive
Payment Model
A. Background
For patients with coronary and other
atherosclerotic vascular disease, the
American Heart Association and the
American College of Cardiology
Foundation’s 2011 practice guideline for
secondary prevention and risk reduction
therapy specifically highlights health
care treatment strategies following AMI
or CABG.137 These strategies include
smoking cessation, close monitoring of
blood pressure and cholesterol, and the
use of certain medications.
The medical literature further
indicates that cardiac rehabilitation (CR)
and intensive cardiac rehabilitation
(ICR) services, which incorporate the
strategies discussed previously, are
capable of achieving significant
improvements in long-term patient
outcomes. A January 2016 Cochrane
Database of Systematic Reviews article
reviewed 63 trials randomizing almost
15,000 patients and found that in longterm follow up (median 12 months),
exercise-based CR services reduced
cardiovascular mortality (but not total
mortality), improved health-related
quality of life, and reduced the risk of
hospital admission.138
Despite the evidence from multiple
studies that CR services improve health
outcomes, the literature also indicates
that these services are underutilized,
estimating that only about 35 percent of
AMI patients receive this indicated
treatment.139 Recent analysis confirms a
similar pattern of underutilization for
Medicare beneficiaries who are eligible
for and could benefit from CR. This
pattern is virtually unchanged over the
past 2 decades, despite clinical practice
guidelines for CR that were published in
1995 and subsequently endorsed by a
number of professional associations and
137 Smith SC et al. AHA/ACCF secondary
prevention and risk reduction therapy for patients
with coronary and other atherosclerotic vascular
disease: 2011 update: A guideline from the
American Heart Association and American College
of Cardiology Foundation endorsed by the World
Heart Federation and the Preventive Cardiovascular
Nurses Association. J Am Coll Cardiol.
2011;58(23):2432–2446.
138 Anderson L et al. Exercise-based cardiac
rehabilitation for coronary heart disease. Cochrane
Database Syst Rev. 2016 Jan 5;1:CD001800.
139 Receipt of outpatient cardiac rehabilitation
among heart attack survivors—United States, 2005.
MMWR Morbidity and mortality weekly report.
2008 Feb 1;57(4):89–94.
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CMS.140 141 142 Among beneficiaries
hospitalized with a diagnosis of AMI in
2013, only about 15 percent had at least
one claim for CR services, and of those
who received CR services, slightly more
than half received 25 or more CR
sessions. Among beneficiaries
hospitalized with an ICD–9–CM
procedure code for percutaneous
transluminal coronary angioplasty or
coronary stenting in 2013, the findings
on CR use were similar to those for AMI
beneficiaries, with only about 23
percent having at least one claim for CR
services, and of those who received CR
services, slightly more than half
received 25 or more CR sessions.
Finally, among beneficiaries
hospitalized in 2013 with ICD–9–CM
procedure codes for coronary artery
bypass surgery, about 45 percent had at
least one claim for CR services, and
slightly over 60 percent of those
beneficiaries received 25 CR sessions or
more, indicating slightly higher rates for
utilization for these beneficiaries.143
Barriers to CR utilization include low
beneficiary referral rates (particularly of
women, older adults, and ethnic
minorities); lack of strong physician
endorsement of CR to their patients;
lack of awareness of CR; the financial
burden on beneficiaries due to
coinsurance and lost work; lack of
accessibility of CR program sites; the
Medicare requirement for physician
supervision of CR; and inadequate
insurance payment.144 145 146 147
140 Suaya, J.A., Shepard, D.S., Normand, S.L.,
Ades, P.A., Prottas, J., Stason, W.B.. Use of cardiac
rehabilitation by Medicare beneficiaries after
myocardial infarction or coronary bypass surgery.
Circulation. 2007;116:1653–1662.
141 Wenger, N., Froelicher, E., Smith, L., Wenger,
N., Froelicher, E., Smith, L., Ades, P., Berra, K.,
Blumenthal, J., Certo, C., Dattilo, A., Davis, D.,
DeBusk, R., Drozda, J., Fletcher, B., Franklin, B.,
Gaston, H., Greenland, P., McBride, P., McGregor,
C., Oldridge, N., Piscatella, J., Rogers, F. Cardiac
Rehabilitation as Secondary Prevention: Clinical
Practice Guideline, No. 17. Rockville, Md: U.S. Dept
of Health and Human Services, Public Health
Service, Agency for Health Care Policy and
Research and National Heart, Lung, and Blood
Institute; 1995. Publication AHCPR 96–0673.
142 Centers for Medicare and Medicaid Services
(CMS). Cardiac rehabilitation programs. In:
Medicare National Coverage Determinations
Manual, chapter 1, part 1, section 20.10.
143 Medicare Part A and B claims from 2013
through 12 month follow-up, Chronic Conditions
Warehouse.
144 Balady, G.J., Ades, P.A., Bittner, V.A., et al;
Referral, enrollment, and delivery of cardiac
rehabilitation/secondary prevention programs at
clinical centers and beyond: A presidential advisory
from the American Heart Association. Circulation.
2011;124: 2951–2960.
145 Suaya, J.A., Shepard, D.S., Normand, S.L.,
Ades, P.A., Prottas, J., Stason, W.B. Use of cardiac
rehabilitation by Medicare beneficiaries after
myocardial infarction or coronary bypass surgery.
Circulation. 2007;116:1653–1662.
146 Wenger, N.K. Current State of Cardiac
Rehabilitation. J Am Coll Cardiol 2008;51:1619–31.
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Moreover, beneficiaries with CAD
often receive care in many different
settings from multiple providers and
suppliers over the long-term and
subsequently commonly experience care
that is fragmented and uncoordinated.
For example, inpatient hospitals,
physicians, and CR programs currently
are paid separately for the services they
provide, with limited financial
incentives for providing care
management and preventive services,
limiting overuse of tests and procedures,
and coordinating across care settings.
Lack of coordination, of both care and
financial incentives, across the
continuum of CAD care, results in
higher than necessary rates of adverse
drug events, hospital readmissions,
diagnostic errors, and other adverse
outcomes, as well as lower than
appropriate utilization of evidencebased treatments.
Medicare Part B generally covers CR/
ICR services for all Medicare
beneficiaries who are referred by their
physician after having an AMI or
CABG.148 As specified in section
1861(eee) of the Act, CR/ICR programs
must include all of the following: (1)
Physician-prescribed exercise; (2)
cardiac risk factor modification,
including education, counseling, and
behavioral intervention, tailored to the
patient’s individual needs; (3)
psychosocial assessment; (4) outcomes
assessment; and (5) an individualized
treatment plan established, reviewed,
and signed by a physician every 30 days
that details how components are
utilized for each patient. The CR/ICR
services must be provided in a
physician’s office or a hospital
outpatient setting, and a physician must
be immediately available and accessible
to furnish assistance and direction at all
times when cardiac rehabilitation
services are being furnished under the
program.149
The number of CR program sessions
are limited to a maximum of 2 one-hour
sessions per day for up to 36 sessions
over up to 36 weeks with the option for
an additional 36 sessions over an
extended period of time if approved by
the Medicare Administrative Contractor
under section 1862(a)(1)(A) of the
Act.150 ICR program sessions are limited
to 72 one-hour sessions, up to 6 sessions
147 Arena, R., et al. Increasing Referral and
Participation Rates to Outpatient Cardiac
Rehabilitation: The Valuable Role of Healthcare
Professionals in the Inpatient and Home Health
Settings. AHA Scientific Advisory. 2012;125:1321–
1329.
148 https://www.medicare.gov/coverage/cardiacrehab-programs.html.
149 Section 1861(eee)(1) of the Act.
150 42 CFR 410.49(b)(1)(vii).
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per day, over a period of up to 18
weeks.151 To be approved as an ICR
program, a program must demonstrate
through peer-reviewed published
research that it has accomplished at
least one of the following: (1) Positively
affecting the progression of coronary
heart disease; (2) reducing the need for
coronary bypass surgery; or (3) reducing
the need for PCI.152
B. Overview of the CR Incentive
Payment Model
1. Rationale for the CR Incentive
Payment Model
Considering the evidence
demonstrating that CR/ICR services
improve long-term patient outcomes,
the room for improvement in CR/ICR
service utilization for beneficiaries
eligible for this benefit, and the need for
ongoing, chronic treatment for
underlying CAD among beneficiaries
that have had an AMI or a CABG, we
believe that there is a need for improved
long-term care management and care
coordination for beneficiaries that have
had an AMI or a CABG and that
incentivizing the use of CR/ICR services
is an important component of meeting
this need. We want to reduce barriers to
high-value care by testing a financial
incentive for hospitals that encourages
the management of beneficiaries that
have had an AMI or a CABG in ways
that may contribute to long-term
improvements in quality and reductions
in Medicare spending.
We believed that there were important
advantages to proposing such an
incentive in conjunction with the
proposed EPMs that are also discussed
in this final rule. First, we wish to
understand whether and how the effects
of a financial incentive for the use of
CR/ICR services differ depending upon
whether a beneficiary’s care is covered
under an EPM or the Medicare FFS
program. The proposed AMI and CABG
models could be effective to provide the
foundation for beneficiaries to receive
improved coordination, care
management, and secondary risk
reduction during the model episodes
through greater use of medically
necessary CR/ICR services, even if
accountability for beneficiary care
ultimately transitions to other entities,
such as ACOs or PCMHs, after the AMI
or CABG model episode ends.
Therefore, the AMI and CABG models
151 Section
1861(eee)(1) of the Act.
list of ICR programs, approved through the
national coverage determination process, is posted
to the CMS Web site at https://www.cms.gov/
Medicare/Medicare-General-Information/
MedicareApprovedFacilitie/ICR.html and listed in
the Federal Register at 42 CFR 410.49(c)(3).
152 A
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could make the proposed CR incentive
payment more effective (if it is
amplified by the broader care
coordination infrastructure encouraged
by the EPM in comparison with its
effect in the Medicare FFS payment
methodology) or less effective (if the
care coordination infrastructure
encouraged by the EPM is itself
sufficient to ensure appropriate use of
CR/ICR services such that the CR
incentive payment itself has less effect
than in the Medicare FFS payment
methodology). Second, we wish to be
able to examine each intervention’s
separate effects on the quality and
efficiency of the care beneficiaries
receive. We believe that coordinating
the design, implementation, and
evaluation of the EPMs and the CR
incentive payment model is the best
way to ensure that we accomplish both
of these goals.
The following is a summary of the
comments received and our responses.
Comment: Many commenters
encouraged the implementation of this
incentive payment model and reminded
CMS that they believe timely referral of
beneficiaries that have had an AMI or a
CABG to CR programs promotes better
adherence to CR service protocols,
which will yield improved
coordination, care management, and
secondary risk reduction during the
episode of care for the beneficiary.
Other commenters stated their support
for the proposed testing of an incentive
payment was based on the compelling
evidence in the proposed rule that the
completion of a CR/ICR program can
significantly reduce the risk of
subsequent heart attacks and cardiacrelated mortality. A commenter
suggested that if these incentives for
hospitals to increase the use of cardiac
rehabilitation are implemented, CMS
must educate physicians and other
health care providers about the value of
cardiac rehabilitation in improving
patient outcomes, reducing hospital
readmission rates, and lowering health
care costs to increase referrals and
ensure enrollment.
Response: We appreciate the
recognition from commenters that
evidence from multiple studies show
that CR services improve health
outcomes, but also that these services
are underutilized. Considering the
evidence demonstrating that CR/ICR
services improve long-term patient
outcomes, the room for improvement in
CR/ICR service utilization for
beneficiaries eligible for this benefit,
and the need for ongoing treatment
among beneficiaries that have had an
AMI or a CABG, we believe that
incentivizing the use of CR/ICR services
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is an important component of meeting
this need. We continue to believe the
proposed approach will permit CMS to
appropriately evaluate this model and
support testing the proposed
hypotheses—to understand whether and
how the effects of a financial incentive
for the use of CR/ICR services differ
depending upon whether a beneficiary’s
care is covered under an EPM or the
Medicare FFS program and to examine
each intervention’s separate effects on
the quality and efficiency of the care
beneficiaries receive—with the strongest
available evidence. We recognize that
education programs about the value of
CR/ICR services, including The Million
Hearts national initiative to focus
clinical attention on the prevention of
heart attack and stroke, could
complement these incentive payments.
2. General Design of the CR Incentive
Payment Model
We proposed the CR incentive
payment model to test the effects on
quality of care and Medicare
expenditures of providing explicit
financial incentives to hospitals
(hereinafter CR participants) for
beneficiaries hospitalized for treatment
of AMI or CABG to encourage care
coordination and greater utilization of
medically necessary CR/ICR services for
90 days post-hospital discharge where
the beneficiary’s overall care is paid
under either an EPM or the Medicare
FFS program. Under the EPMs, we
proposed in general that the hospital
where the anchor hospitalization for
AMI or CABG treatment occurs that
begins the AMI or CABG model episode
as discussed in section III.C.4.a. of this
final rule would be financially
accountable for the AMI or CABG model
episode. Thus, we expected that EPM
participants would be highly engaged in
care management of beneficiaries for the
90-day post-discharge duration included
in the episode and could be able to
capitalize on that engagement to
encourage greater use of medically
appropriate CR/ICR services if they were
also selected for participation in the CR
incentive payment model. Therefore,
under the CR incentive payment model,
we proposed to provide a CR incentive
payment specifically to selected
hospitals with financial responsibility
for AMI or CABG model episodes
(hereinafter EPM–CR participants)
because they are already engaged in
managing the AMI or CABG model
beneficiary’s overall care for a period of
time following hospital discharge.
Similarly, we believe there are
opportunities to test the same financial
incentives for hospitals where the
beneficiary’s overall care is paid under
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the Medicare FFS program. Thus, we
also proposed to provide a CR incentive
payment specifically to selected
hospitals that are not AMI or CABG
model participants (hereinafter FFS–CR
participants). The design of the CR
incentive payment model would enable
us to test and improve our
understanding of the effects of the CR
incentive payment within the context of
an EPM and the Medicare FFS program,
as well as identify potential interactions
between the proposed CR incentive
payment and the underlying EPM and
FFS payment methodologies. We
understand that there may be providers
and suppliers other than hospitals
caring for beneficiaries with AMI or
CABG whose care is paid under the
Medicare FFS program and that could
assume responsibility for encouraging
greater utilization of CR/ICR services
under the CR incentive payment model.
However, for comparability to the roles
and responsibilities of the hospitals that
are the EPM participants selected for CR
incentive payment model participation,
we proposed to identify hospitals as the
participants in the CR incentive
payment model for beneficiaries whose
care is paid under the Medicare FFS
program. Hospitals provide over 95
percent of CR/ICR services to Medicare
beneficiaries and the beneficiaries in the
CR incentive payment model are
identified based on a hospitalization for
AMI or CABG.153 Thus, we believe that
hospitals are an appropriate entity to
take on care coordination responsibility
for increasing the utilization of
medically necessary CR/ICR services for
those beneficiaries following AMI or
CABG who are in the CR incentive
payment model but that are not in an
EPM.
To test strategies to encourage CR
participants to prioritize referring
beneficiaries following an AMI or CABG
for important CR/ICR services,
monitoring for beneficiary adherence to
the treatment plan, and coordinating
care, we proposed to establish a perservice CR incentive amount for
beneficiary CR use at two levels that
would initially incentivize the use of
any CR/ICR services and that would
increase once a beneficiary meets or
exceeds the proposed CR/ICR service
utilization benchmark. We believe that
encouraging timely referral of
beneficiaries that have had an AMI or a
CABG to CR/ICR programs would
promote better adherence to CR/ICR
153 Analysis of cardiac rehabilitation utilization in
care periods for AMI and CABG beneficiaries
initiated by all U.S. IPPS hospitals not in Maryland
and constructed using standardized Medicare FFS
Parts A and B claims, as proposed in this rule, that
began in CYs 2012–2014.
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service protocols, an expectation that is
supported by data showing that patients
who are referred early to CR were more
likely to enroll.154
Historical claims data show that more
than half of beneficiaries who receive
one CR session go on to complete at
least 25 sessions.155 Thus, providing a
CR incentive payment to reward
increased referrals to CR/ICR programs,
as well as monitoring for beneficiary
adherence with the referral and
participation in the sessions, may
encourage better CAD-specific care
management and care coordination for
beneficiaries that have had an AMI or a
CABG and, ultimately, improve quality
and reduce spending long-term for these
beneficiaries with CAD. CR participants
that would be eligible for these CR
incentive payments could further
reduce potential beneficiary barriers to
CR/ICR services by utilizing other
flexibilities we proposed for the AMI
and CABG models and the CR incentive
payment model, such as beneficiary
engagement incentives as discussed in
sections III.I.9. and VI.F.6. of this final
rule for EPM–CR participants and FFS–
CR participants, respectively.
Furthermore, we refer to section III.J.8.
of this final rule for a discussion of the
proposal to provide greater CR/ICR
program flexibility that may increase the
availability of CR/ICR services for AMI
and CABG model beneficiaries by
providing a waiver of the definition of
a physician to include a physician or
nonphysician practitioner (defined for
the purposes of this waiver as a
physician assistant, nurse practitioner,
or clinical nurse specialist) in
performing specific physician functions.
We also refer to section VI.F.7. of this
final rule for discussion of the proposal
for a similar waiver of the physician
definition to provide greater CR/ICR
program flexibility to increase the
availability of these services for
beneficiaries in a FFS–CR participant, as
defined later in this section.
While we recognize there are other
services focused on secondary
prevention for beneficiaries with CAD
such as diabetes self-management
training, as well as treatments including
drugs for blood pressure and cholesterol
control, we believe that CR/ICR services
are unique as an underutilized
Medicare-covered benefit with a strong
evidence-base of improved health
outcomes for beneficiaries who have
had an AMI or a CABG. Therefore, we
154 Grace, S.L. et al. Effectiveness of inpatient and
outpatient strategies in increasing referral and
utilization of cardiac rehabilitation: A prospective,
multi-site study. Implement Sci. 2012: 7:120.
155 Analysis of CR/ICR services utilization in 2013
Medicare FFS Parts A and B claims.
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believe that CR/ICR services are
uniquely appropriate for CR incentive
payments to selected AMI and CABG
model participants as well as selected
hospitals that would not be
participating in these models in order to
reward their efforts where we observe
increased CR/ICR service utilization for
CR incentive payment model
beneficiaries. By proposing to provide
CR incentive payments to encourage
CR/ICR service utilization, we
maximized our opportunity to
positively affect the quality of care and
reduce the cost-of-care for beneficiaries
that have had an AMI or a CABG both
within the short- and long-term. Like
under other Innovation Center models,
beneficiaries in the CR incentive
payment model would retain freedom of
choice to choose providers and services,
although the proposed model provides
financial incentives to CR participants
to specifically encourage and support
beneficiaries in adhering to a prescribed
CR treatment plan following AMI or
CABG.
By making CR incentive payments
available to selected EPM–CR and FFS–
CR participants and comparing them to
EPM participants and hospitals paid
under the Medicare FFS program for
AMI and CABG care who are not CR
participants, we would be able to
observe the effects of the proposed CR
incentive payments on utilization of CR/
ICR services and short-term (within the
episode or care period) and longer-term
outcomes, including mortality,
hospitalizations, complications, and
other clinically relevant events, as well
as on Medicare expenditures. In testing
the effects of a CR incentive payment,
we wanted to account for a range of
factors and interactions that could
potentially affect the outcomes we
observed. We believe our proposed
methodology would enable us to test
and improve our understanding of the
effects of the CR incentive payment
within the context of an EPM and the
Medicare FFS program, as well as
examine potential interactions between
the proposed CR incentive payment and
the underlying EPM and FFS payment
methodologies.
The following is a summary of the
comments received and our responses.
Comment: MedPAC commented that,
while there are many barriers to
enrollment for CR/ICR services, it is not
clear which barriers create the biggest
hurdles to effective care, and this lack
of clarity makes the determination of the
best corrective action difficult. MedPAC
noted in comment that, for example, if
one of the most significant barriers is
low referral rates, CMS could encourage
greater referral to CR/ICR by creating
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claims-based physician or hospital
quality measures for all providers who
care for beneficiaries with AMI and
CABG. These measures could gauge the
share of beneficiaries who receive CR/
ICR services and the share who receive
some minimum number of CR/ICR
services. However, MedPAC also noted
that tackling these barriers may require
a multifaceted approach. Finally,
MedPAC recommended that CMS not
move forward with the proposed CR/
ICR incentive payment model if CMS
elects to implement the AMI and CABG
EPMs, as they believe the proposed
approach may be unnecessarily costly
for the Medicare program, and seems
overly complex.
Response: While we acknowledge that
many barriers to CR/ICR services exist,
multiple provider types furnish CR/ICR
services, and services are provided for
many indications, it would be
unreasonable to test multiple proposals
to address these concerns
simultaneously, as such tests would
make the assignment of appropriate
controls difficult and assessment of
impacts and outcomes from such
proposals challenging to attribute to just
one proposal. CMS proposed that EPM–
CR participants be defined as hospitals
that are AMI or CABG model
participants located in the MSAs
selected for the EPM–CR participation,
and similarly proposed that FFS–CR
participants are hospitals located in the
MSAs selected for FFS–CR
participation. We continue to believe
the proposed approach will permit CMS
to appropriately evaluate this model and
support testing the proposed
hypotheses—to understand whether and
how the effects of a financial incentive
for the use of CR/ICR services differ
depending upon whether a beneficiary’s
care is covered under an EPM or the
Medicare FFS program and to examine
each intervention’s separate effects on
the quality and efficiency of the care
beneficiaries receive—with the strongest
available evidence. We proposed the CR
incentive payment model to test the
effects on quality of care and Medicare
expenditures of providing explicit
financial incentives in addition to,
rather than in lieu of, current Medicare
expenditures to CR participants for
beneficiaries hospitalized for treatment
of AMI or CABG to encourage care
coordination and greater utilization of
medically necessary CR/ICR services for
90 days post-hospital discharge where
the beneficiary’s overall care is paid
under either an EPM or the Medicare
FFS program. We continue to expect
that EPM participants would be highly
engaged in care management of
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beneficiaries for the 90-day postdischarge duration included in the
episode and could be able to capitalize
on that engagement to encourage greater
use of medically appropriate CR/ICR
services if they were also selected for
participation in the CR incentive
payment model. Therefore, we are
finalizing the proposal to implement the
CR/ICR incentive payment model
simultaneously with the EPMs, rather
than test multiple incentives for the
provision of CR/ICR services.
Comment: A commenter referencing
the CR incentive payment model
expressed concern that this voluntary
program may become be required in the
future and encouraged CMS to utilize
this model to identify the patient
population for whom this service
improves outcomes.
Response: We appreciate the
commenter’s concern however the
design of this model will not identify
additional populations of beneficiaries
who might show improved health
outcomes beyond those undergoing AMI
or CABG. Furthermore, we believe there
is strong evidence already identifying
those patient populations for whom CR/
ICR services improve health
outcomes.156
Comment: Several commenters stated
support for the concept of cardiac
rehabilitation incentive payments as
proposed, whether or not these
payments are tied to episode payments.
A few commenters noted that CMS does
not expressly define the proposed CR/
ICR incentive payment model as
separate and distinct from the EPMs.
Given the similarities in patient
populations and the proposed overlap of
certain MSAs, these commenters
expressed concern that there could be
some confusion as to whether or not
these models are in fact separate and
distinct, and requested that CMS clarify
in expressed terms what the case may
be.
Response: In the proposed rule, we
describe the proposed CR/ICR incentive
payments as separate and distinct from
reconciliation payments and Medicare
repayments for EPM–CR participants
determined under § 512.305(d). The
proposed CR/ICR incentive payment
under the CR/ICR incentive payment
model is a more specific payment
designed to financially incentivize
increased utilization of CR/ICR services
which may improve quality and reduce
costs for AMI and CABG model
beneficiaries.
156 Anderson, L. et al. Exercise-based cardiac
rehabilitation for coronary heart disease. Cochrane
Database Syst Rev. 2016 Jan 5;1:CD001800.
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C. CR Incentive Payment Model
Participants
The selection of MSAs for
participation in the CABG and AMI
EPMs is described in section III.B.5. of
this final rule. The selection process
would identify the 98 EPM MSAs from
the 294 MSAs eligible for selection for
the AMI and CABG models under the
proposed rule. We proposed that 45
MSAs be selected from within the pool
of the 98 EPM MSAs for the CR
incentive payment model (hereinafter
EPM–CR MSAs). An additional 45
MSAs would be selected for the CR
incentive payment model from the pool
of MSAs who were eligible but not
selected for EPM (hereinafter FFS–CR
MSAs). The approach for both
selections is discussed in the following
paragraphs.
We are interested in identifying
control group MSAs that are similar to
the treatment MSAs in ways that might
impact the nature of their response to
the CR incentive payment model.
Having well-matched MSAs in the four
types of MSAs (FFS–CR, FFS-non CR,
EPM–CR and EPM-non CR) is important
to our ability to assess the specific
impact of the CR incentive payment
while holding other considerations
constant. We were concerned that a
simple random selection of FFS–CR and
EPM–CR areas would have a large
probability of selecting MSAs that are
insufficiently similar to the EPM-non
CR areas due to the small number of
MSAs from which to choose. As such,
we proposed the selection of the EPM–
CR MSAs to balance the incidence of
key characteristics between the EPM–CR
and EPM-non CR MSAs and the
selection of FFS–CR MSAs to be based
on similarity to the randomly selected
EPM MSAs.
The 294 MSAs originally eligible for
selection would be classified into
groups based on combinations of several
key dimensions related to CR or ICR
service provision within the MSA in the
reference year including—
• Percent Starting CR/ICR services:
Percent of eligible cases in the MSA
who received one or more CR or ICR
services in the reference year. CMS
considered dividing MSAs through
alternative cut points of this metric
including 20 percent and 30 percent;
• Percent Completing CR/ICR
services: Percent of eligible cases in the
MSA who completed 25 or more CR or
ICR services in the reference year. CMS
considered dividing MSAs through
alternative cut points including 50
percent, 60 percent and 70 percent of
this metric; and.
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• Number of CR/ICR providers: The
number of providers who billed for CR/
ICR services in the MSA during the
reference year. CMS considered
dividing MSAs according to whether
they had one hospital who billed for CR
services or more than one hospital.
MSAs would be assigned into a group
based on combinations of these
measures. An example of a possible
group would be a group of MSAs that
are ‘‘low starters, high users.’’ Such a
group might be defined as MSAs in
which—(1) less than 20 percent of
eligible patients start CR/ICR services;
(2) more than 60 percent of individuals
who start CR/ICR complete 25 or more
sessions; and (3) more than one hospital
bills for CR services.
We proposed the selection of CR
MSAs via a modified stratified random
selection algorithm in which these
groups serve as the selection strata.
Specifically, we proposed that the
number of EPM–CR and FFS–CR MSAs
selected from each group equals the
number of EPM MSAs in the group
multiplied by 0.46. This rate was chosen
with the goal of selecting 45 EPM–CR
MSAs out of 98 EPM MSAs (45/98 is
approximately equal to 0.46). As an
example of this approach to selection,
consider a hypothetical group with 16
EPM MSAs and 28 FFS MSAs. We
would randomly select 7 EPM–CR
MSAs from the 16 EPM MSAs (7 is
equal to 0.46 × 16 with rounding). The
remaining 9 would be EPM-non CR. We
would also randomly select 7 FFS–CR
MSAs from the 28 FFS MSAs. The
remaining 21 MSAs would be FFS-non
CR MSAs. This approach would ensure
balance with respect to group
membership between EPM–CR MSAs
and EPM-non-CR MSAs, as well as
between EPM–CR MSAs and FFS–CR
MSAs; it would not necessarily achieve
balance with respect to group
membership for other comparisons
among model arms.
We also considered other approaches
to selection. Under one alternative
approach, we would select a number of
EPM–CR MSAs from each group equal
to the number of EPM MSAs in the
group multiplied by 0.46 and a number
of FFS–CR MSAs from each group equal
to the number of FFS MSAs in the group
multiplied by 0.23. As previously
discussed, the rate 0.46 was chosen with
the goal of selecting 45 EPM–CR MSAs
out of 98 EPM MSAs. The rate 0.23 is
based on the goal of selecting 45 FFS–
CR MSAs out of 196 FFS MSAs (45/196
is approximately equal to 0.23). As in
our proposed approach, the calculated
number of MSAs to be selected from
each group would be rounded to the
nearest integer as necessary. This
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approach would ensure balance with
respect to group membership between
EPM–CR MSAs and EPM-non-CR MSAs,
as well as between FFS–CR MSAs and
FFS-non-CR MSAs; it would not
necessarily achieve balance with respect
to group membership for other
comparisons among model arms.
Under another alternative approach,
we would use a stratified random
assignment approach to determine both
EPM participation and CR participation.
Specifically, under this approach, the
number of EPM–CRs and FFS–CR MSAs
selected from each group would each be
equal to the total number of MSAs in
that group multiplied by 0.15, the
number of EPM-non-CR MSAs selected
from each group would be equal to the
total number of MSAs in the group
multiplied by 0.18, and the remaining
MSAs in each group would be assigned
to be FFS-non-CR MSAs. The rate 0.15
was chosen with the goal of selecting 45
EPM–CR MSAs and 45 FFS–CR MSAs
out of 294 total MSAs (45/294 is
approximately equal to 0.15), and the
rate 0.18 was chosen with the goal of
selecting 53 EPM-non-CR MSAs out of
294 total MSAs (53/294 is
approximately equal to 0.18). As in our
proposed approach, the calculated
number of MSAs to be selected into
each arm would be rounded to the
nearest integer as necessary. This
approach would ensure balance with
respect to group membership for all
comparisons across the four arms—
EPM–CR, FFS–CR, EPM-non-CR, and
FFS-non-CR—but would forgo the
simplicity of simple random assignment
for the selection of EPM MSAs.
For the purposes of being able to
evaluate the CR incentive payment
model as a whole, we proposed to
implement it in a consistent manner
between the EPM–CR areas and the
FFS–CR areas. As such, we proposed to
use similar approaches to identifying CR
participants in each while also
coordinating with the specifications and
requirements of the AMI and CABG
models. We proposed that EPM–CR
participants are hospitals that are AMI
or CABG model participants located in
the MSAs selected for the EPM–CR
participation based on the methodology
previously described in section VI.C. of
this final rule. We similarly proposed
that FFS–CR participants are hospitals
located in the MSAs selected for FFS–
CR participation based on the
methodology previously described in
section VI.C. of this final rule and that
meet all provisions in sections III.B.2.
through III.B.4. of this final rule to be an
EPM participant if the hospital were
located in an MSA selected for the AMI
or CABG model. We believe that
VerDate Sep<11>2014
22:30 Dec 30, 2016
Jkt 241001
requiring FFS–CR participants to meet
all provisions in sections III.B.2.
through III.B.4. of this final rule would
ensure that FFS–CR participants
resemble EPM–CR participants as
closely as possible, which would
contribute to our ability to test and
evaluate the effect of the CR incentive
payment and specifically whether there
are differential effects of the CR
incentive payment in the underlying
EPM and FFS payment methodologies.
The proposal to select MSAs for the
CR incentive payment model and to
identify CR participants is included in
§ 512.703. We sought comments on our
proposed approach to selecting MSAs
and identifying CR participants.
The following is a summary of the
comments received and our responses.
Comment: Commenters questioned
the emphasis on hospitals for testing the
model. These commenters noted that if
this incentive program were limited to
hospitals only, it would be highly
unlikely to optimize physician
engagement, leaving patient referral
rates low. Other commenters noted that
without including practice-based CR/
ICR programs in the proposal, they
believe the CR/ICR incentive payment
model, despite its excellent intentions,
would be unlikely to achieve its
intended goal of driving better long-term
quality cardiovascular care at lower
cost. Other commenters urged CMS to
expand the CR/ICR incentive payment
model participants to permit physician
practice-based ICR programs to be
included to promote the underlying goal
of increasing access to these services.
Response: While we acknowledge that
many barriers to CR/ICR services exist,
and multiple provider types furnish CR/
ICR services, it would be unreasonable
to test multiple proposals to address
these concerns simultaneously, as such
tests would make the assignment of
appropriate controls difficult and
assessment of impacts and outcomes
from such proposals challenging to
attribute to just one proposal. CMS
proposed that EPM–CR participants be
defined as hospitals that are AMI or
CABG model participants located in the
MSAs selected for the EPM–CR
participation, and similarly proposed
that FFS–CR participants are hospitals
located in the MSAs selected for FFS–
CR participation. We continue to believe
the proposed approach will permit CMS
to appropriately evaluate this model and
support testing the proposed
hypotheses—to understand whether and
how the effects of a financial incentive
for the use of CR/ICR services differ
depending upon whether a beneficiary’s
care is covered under an EPM or the
Medicare FFS program and to examine
PO 00000
Frm 00390
Fmt 4701
Sfmt 4700
each intervention’s separate effects on
the quality and efficiency of the care
beneficiaries receive—with the strongest
available evidence. We continue to
believe it is in the interest of the
Medicare program and its beneficiaries
for us to identify new models that
maintain beneficiary choice, and
disagree that the design of the CR/ICR
incentive payment model will limit
access to CR/ICR services for Medicare
beneficiaries, as the payment model
does not limit a beneficiary’s ability to
choose among Medicare providers and
suppliers or the range of services that
are available to them. Beneficiaries may
continue to choose any Medicare
enrolled provider or supplier, or any
physician or practitioner who has opted
out of Medicare, with the same costs,
copayments and responsibilities as they
have with other Medicare services.
We continue to expect that EPM
participants would be highly engaged in
care management of beneficiaries for the
90-day post-discharge duration included
in the episode and could be able to
capitalize on that engagement to
encourage greater use of medically
appropriate CR/ICR services if they were
also selected for participation in the CR
incentive payment model. Therefore, we
are finalizing the proposal to determine
CR incentive payment model
participants to include EPM–CR
participants because they are already
engaged in managing the AMI or CABG
model beneficiary’s overall care for a
period of time following hospital
discharge and will compare these
participants to FFS–CR participants. We
understand that there may be providers
and suppliers other than hospitals
caring for beneficiaries with AMI or
CABG whose care is paid under the
Medicare FFS program and that could
assume responsibility for encouraging
greater utilization of CR/ICR services
under the CR incentive payment model.
However, for comparability to the roles
and responsibilities of the hospitals that
are the EPM participants selected for CR
incentive payment model participation,
we proposed to identify hospitals as the
participants in the CR incentive
payment model for beneficiaries whose
care is paid under the Medicare FFS
program. Hospitals provide over 95
percent of CR/ICR services to Medicare
beneficiaries and the beneficiaries in the
CR incentive payment model are
identified based on a hospitalization for
AMI or CABG. Thus, we believe that
hospitals are an appropriate entity to
take on care coordination responsibility
for increasing the utilization of
medically necessary CR/ICR services for
those beneficiaries following AMI or
E:\FR\FM\03JAR2.SGM
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CABG who are in the CR incentive
payment model but that are not in an
EPM.
Comment: Several commenters
suggested that the CR incentive payment
model be expanded beyond what was
proposed. A commenter requested that
all providers involved in any cardiac
episode payment model be able to
access the CR payment incentive. A
commenter believed that the CR
incentives should be available to all 98
cardiac EPM MSAs and thought it unfair
that these would not be made
universally available to all cardiac EPM
participant providers. A commenter
suggested that all 98 cardiac EPM–
MSAs be enrolled in the CR incentive
payment model as well as an additional
98 FFS–MSAs. Another commenter
recommended that all cardiac EPM
participant MSAs and an equal number
of random eligible non-participant
MSAs be enrolled in this model.
Similarly, another commenter urged
that similar CR incentive payments be
made available to BPCI Model 2 PGP
episode initiators in order to compare
and contrast physician-led cardiac
episodes and hospital-led episodes.
Response: CMS is encouraged by the
positive reception to the CR Incentive
Payment Model and the belief that it is
immediately suitable for expansion. At
the same time, the incentive payments
represent an additional outlay of funds
beyond the current payment systems. In
its role as a prudent steward of financial
resources, CMS is committed to
assessing the impact of this additional
expenditure prior to a wider scale
implementation. CMS is interested in
conducting a test of the CR incentive
payment model in order to assess the
impact it has on both utilization and
outcomes.
CMS initially considered providing
access to the CR incentive to the 98
cardiac EPM MSAs only. However, after
consideration, CMS decided that it was
important to be able to assess the
performance of EPM–CR areas relative
to EPM-non CR areas, as well as the
performance of EPM–CR MSAs versus
FFS–CR areas and FFS–CR compared to
FFS-non CR areas. The examination of
all these combinations will provide
insight into what factors are associated
with the impacts observed.
Comment: A commenter requested
additional details regarding any
characteristics used in the selection of
MSAs for the CR model.
Response: The characteristics for
selection of the MSAs as stated in the
proposed rule will include 3
dimensions of starting and completing
CR services and number of CR/ICR
providers and we refer the reader to
section VI.C. for further details.
Groupings within an MSA based on
these dimensions will be created and
then a stratified random selection
process will be used to select
participant MSAs. There will be an
equal number of MSAs for eligible
MSAs (EPM–CR MSAs) and those
eligible but not selected for EPM (FFS–
CR).
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal, without
modification, to define CR incentive
payment model participants in
§ 512.703, and specifically include both
EPM–CR MSAs and FFS–CR MSA
participants as being located in the
selected MSAs meeting all requirements
in § 512.100(b) to be an AMI or CABG
569
model participant if the hospital were
located in an MSA selected for the AMI
and CABG EPM.
If a participant changes their
eligibility status during the period of
performance, they will become eligible
for the CR incentive payment model.
This may occur through concluding
their participation as a BPCI initiating
hospital or other means such as a new
hospital being opened. The reassessment and updating of hospital
eligibility status will be performed on
an ongoing periodic basis as frequently
as quarterly if needed.
The selection of the CR areas will
proceed as proposed with a two-step
process in which 98 cardiac EPM MSAs
would be chosen first and then the
EPM–CR and the FFS–CR would be
chosen from within CR selection groups.
Seven CR selection groups were created
using information about the utilization
of CR in the MSA in the reference year.
The groups were defined based on
combinations of the following: (1)
Whether there was more than one
hospital provider who billed for CR
services in the MSA in the reference
year, (2) whether the percent of eligible
Medicare FFS beneficiaries who
received CR services was less than 20
percent, 20 to 30 percent or more than
30 percent, and (3) whether at least 60
percent of eligible patients who start CR
services complete at least 25 sessions.
The definition of seven groups used in
the selection is shown in Table 52. The
number of EPM–CR MSAs and the
number of FFS–CR MSAs to be selected
from each group is also shown in Table
52 and is proportional to the number of
selected cardiac EPM MSAs in each
group.
TABLE 52—CR MSA SELECTION GROUP DEFINITION AND NUMBER OF MSAS TO BE SELECTED
asabaliauskas on DSK3SPTVN1PROD with RULES
CR selection
group No.
1
2
3
4
5
6
7
....................
....................
....................
....................
....................
....................
....................
Total .......
Number of
hospitals billing for CR
Number of
cardiac EPM
MSAs
Percent of eligible Medicare
FFS patients starting CR
Percent of patients starting
CR completing 25 sessions
...................
...................
+ ................
+ ................
+ ................
+ ................
+ ................
<20% ...................................
20% + ..................................
<20% ...................................
20–30% ...............................
20–30% ...............................
30% + ..................................
30% + ..................................
Any ......................................
Any ......................................
Any ......................................
<60% ...................................
60% + ..................................
<60% ...................................
60% + ..................................
40
35
67
34
52
37
28
4
16
17
13
19
15
14
2
7
8
6
9
7
6
.......................
..............................................
..............................................
293
98
45
1
1
2
2
2
2
2
As shown in Table 52, we are
randomly selecting 2 EPM–CR and 2
FFS–CR MSAs from CR Selection Group
VerDate Sep<11>2014
Number of
selection
eligible MSAs
Number of
EPM–CR and
FFS–CR
MSAs to be
selected from
group
(0.46 × #
EPM)
22:30 Dec 30, 2016
Jkt 241001
1 where the number two is derived by
multiplying the number of cardiac EPM
MSAs in the group by the selection
PO 00000
Frm 00391
Fmt 4701
Sfmt 4700
percent and then rounding (round (4 ×
0.46) = 2). The number of MSAs to be
selected within the 7 CR Selection
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Federal Register / Vol. 82, No. 1 / Tuesday, January 3, 2017 / Rules and Regulations
groups are, in order, 2, 7, 8, 6, 9, 7, and
6.
We selected the participating FFS–CR
and EPM–CR MSAs through random
selection within groups. We selected 45
MSAs via stratified random sample from
both AMI and CABG EPM participant
MSAs and traditional fee for service
MSAs (those not selected to participate
in the AMI and CABG EPMs). EPM–CR
MSAs were randomly selected from the
EPM MSAs in the same selection group.
Similarly, the same number of FFS–CR
MSAs were randomly selected from
within the MSAs in the CR selection
group who were eligible for but not
chosen as a cardiac EPM area.
Based on our sampling methodology,
SAS for Windows Version 9.4 software
was used to run a computer algorithm
designed to randomly select MSAs. SAS
for Windows Version 9.4 and the
computer algorithm used to conduct
selection represents an industry
standard for generating advanced
analytics and provides a rigorous,
standardized tool by which to satisfy the
requirements of randomized selection.
The key SAS commands employed
include a ‘‘PROC SURVEYSELECT’’
statement coupled with the
‘‘METHOD=SRS’’ option used to specify
desired random sampling as the sample
selection method. A random number
seed was generated for each of the
fourteen strata by using fourteen
number seeds corresponding to
birthdates and anniversary dates of
parties present in the room. The random
number seeds for stratum one through
fourteen were as follows: 19851201,
20151024, 19841124, 20120827,
19590625, 19650907, 19870213,
19850714, 20090712, 20091024,
19800919, 19781023, 20120807, and
20140928. For more information on this
procedure and the underlying statistical
methodology, please reference SAS
support documentation at: https://
support.sas.com/documentation/cdl/en/
statug/63033/HTML/default/
viewer.htm#statug_surveyselect_
sect003.htm/.
Table 53 shows the list of EPM–CR
MSAs. Table 54 shows the list of FFS–
CR MSAs.
TABLE 53—EPM–CR MSAS. CARDIAC EPM MSAS SELECTED FOR CR INCENTIVE PAYMENT MODEL
asabaliauskas on DSK3SPTVN1PROD with RULES
CBSA OMB No.
10180
10780
10900
12220
13380
14020
14460
15940
15980
16700
16860
17980
19100
19300
20500
21060
21660
22520
24300
25940
26580
26820
27860
27900
30620
30780
31540
33340
33540
35100
35660
36540
39140
39380
39740
40220
41100
41140
41420
44100
46060
46140
46220
47940
48620
...................................................................
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VerDate Sep<11>2014
22:30 Dec 30, 2016
CR selection
group
MSA name
Jkt 241001
Abilene, TX ...................................................................................
Alexandria, LA ..............................................................................
Allentown-Bethlehem-Easton, PA-NJ ...........................................
Auburn-Opelika, AL ......................................................................
Bellingham, WA ............................................................................
Bloomington, IN ............................................................................
Boston-Cambridge-Newton, MA-NH .............................................
Canton-Massillon, OH ...................................................................
Cape Coral-Fort Myers, FL ...........................................................
Charleston-North Charleston, SC .................................................
Chattanooga, TN-GA ....................................................................
Columbus, GA-AL .........................................................................
Dallas-Fort Worth-Arlington, TX ...................................................
Daphne-Fairhope-Foley, AL .........................................................
Durham-Chapel Hill, NC ...............................................................
Elizabethtown-Fort Knox, KY ........................................................
Eugene, OR ..................................................................................
Florence-Muscle Shoals, AL .........................................................
Grand Junction, CO ......................................................................
Hilton Head Island-Bluffton-Beaufort, SC .....................................
Huntington-Ashland, WV-KY-OH ..................................................
Idaho Falls, ID ..............................................................................
Jonesboro, AR ..............................................................................
Joplin, MO .....................................................................................
Lima, OH .......................................................................................
Little Rock-North Little Rock-Conway, AR ...................................
Madison, WI ..................................................................................
Milwaukee-Waukesha-West Allis, WI ...........................................
Missoula, MT ................................................................................
New Bern, NC ...............................................................................
Niles-Benton Harbor, MI ...............................................................
Omaha-Council Bluffs, NE-IA .......................................................
Prescott, AZ ..................................................................................
Pueblo, CO ...................................................................................
Reading, PA ..................................................................................
Roanoke, VA .................................................................................
St. George, UT .............................................................................
St. Joseph, MO-KS .......................................................................
Salem, OR ....................................................................................
Springfield, IL ................................................................................
Tucson, AZ ...................................................................................
Tulsa, OK ......................................................................................
Tuscaloosa, AL .............................................................................
Waterloo-Cedar Falls, IA ..............................................................
Wichita, KS ...................................................................................
PO 00000
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E:\FR\FM\03JAR2.SGM
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5
5
2
2
2
4
4
3
5
5
1
5
7
5
4
6
5
2
7
3
2
4
4
3
3
6
6
7
2
2
6
7
3
3
5
3
7
6
6
4
5
1
6
3
CJR MSA
yes.
yes.
yes.
yes.
yes.
yes.
Federal Register / Vol. 82, No. 1 / Tuesday, January 3, 2017 / Rules and Regulations
571
TABLE 54—FFS–CR MSAS. FFS MSAS SELECTED FOR CR INCENTIVE PAYMENT MODEL
CBSA OMB
No.
11540
12700
13020
14010
15260
16180
16580
16940
17460
18020
18580
19340
20260
21780
22220
22500
24660
25060
25420
25620
28940
30700
33740
34060
34620
34940
37340
37860
38060
38940
39460
40140
40340
40420
40660
41180
41860
42140
42200
42540
42660
42700
44180
45780
47380
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CR selection
group
MSA name
Appleton, WI ..............................................................................................
Barnstable Town, MA ................................................................................
Bay City, MI ...............................................................................................
Bloomington, IL .........................................................................................
Brunswick, GA ...........................................................................................
Carson City, NV ........................................................................................
Champaign-Urbana, IL ..............................................................................
Cheyenne, WY ..........................................................................................
Cleveland-Elyria, OH .................................................................................
Columbus, IN .............................................................................................
Corpus Christi, TX .....................................................................................
Davenport-Moline-Rock Island, IA-IL ........................................................
Duluth, MN-WI ...........................................................................................
Evansville, IN-KY .......................................................................................
Fayetteville-Springdale-Rogers, AR-MO ...................................................
Florence, SC .............................................................................................
Greensboro-High Point, NC ......................................................................
Gulfport-Biloxi-Pascagoula, MS ................................................................
Harrisburg-Carlisle, PA ..............................................................................
Hattiesburg, MS .........................................................................................
Knoxville, TN .............................................................................................
Lincoln, NE ................................................................................................
Monroe, LA ................................................................................................
Morgantown, WV .......................................................................................
Muncie, IN .................................................................................................
Naples-Immokalee-Marco Island, FL ........................................................
Palm Bay-Melbourne-Titusville, FL ...........................................................
Pensacola-Ferry Pass-Brent, FL ...............................................................
Phoenix-Mesa-Scottsdale, AZ ...................................................................
Port St. Lucie, FL ......................................................................................
Punta Gorda, FL ........................................................................................
Riverside-San Bernardino-Ontario, CA .....................................................
Rochester, MN ..........................................................................................
Rockford, IL ...............................................................................................
Rome, GA ..................................................................................................
St. Louis, MO-IL ........................................................................................
San Francisco-Oakland-Hayward, CA ......................................................
Santa Fe, NM ............................................................................................
Santa Maria-Santa Barbara, CA ...............................................................
Scranton-Wilkes-Barre-Hazleton, PA ........................................................
Seattle-Tacoma-Bellevue, WA ..................................................................
Sebring, FL ................................................................................................
Springfield, MO ..........................................................................................
Toledo, OH ................................................................................................
Waco, TX ...................................................................................................
D. CR/ICR Services That Count Towards
CR Incentive Payments
We proposed to identify CR/ICR
services that count towards CR
incentive payments on the basis of the
presence of the HCPCS codes on PFS
and OPPS claims that report CR/ICR
services as displayed in Table 55. These
HCPCS codes have been active since
prior to 2013 through the present. We
note that CMS specifies the CR/ICR
service HCPCS codes in implementing
the statutory coverage provisions for CR
6
1
2
7
1
2
7
2
5
2
3
6
6
4
5
5
5
4
4
4
7
7
3
3
2
2
3
3
5
4
7
3
6
6
5
7
5
3
3
2
6
5
6
5
4
CJR MSA
yes.
yes.
yes.
yes.
yes.
yes.
yes.
yes.
yes.
yes.
yes.
yes.
yes.
and ICR programs, and we would
update this list of HCPCS codes for CR/
ICR services for the CR incentive
payment model in future CR
performance years should CMS adopt
different or additional HCPCS codes for
reporting these services.157 158
TABLE 55—HCPCS CODES FOR CARDIAC REHABILITATION AND INTENSIVE CARDIAC REHABILITATION SERVICES
asabaliauskas on DSK3SPTVN1PROD with RULES
HCPCS Code
93797
93798
G0422
G0423
...................................
...................................
...................................
...................................
Descriptor
Physician services for outpatient cardiac rehabilitation; without continuous ECG monitoring (per session).
Physician services for outpatient cardiac rehabilitation; with continuous ECG monitoring (per session).
Intensive cardiac rehabilitation; with or without continuous ECG monitoring with exercise, per session.
Intensive cardiac rehabilitation; with or without continuous ECG monitoring; without exercise, per session.
157 42
CFR 410.49.
Matters® Number: MM6850 Revised.
Related Change Request #: 6850; Related CR Release
158 MLN
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Date: May 21, 2010. Effective Date: January 1, 2010.
Related CR Transmittal #: R1974CP, R126BP,
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R339PI, and R170FM. Implementation Date:
October 4, 2010.
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We proposed that within the AMI and
CABG models, CR/ICR services paid by
Medicare to any provider or supplier for
AMI and CABG model beneficiaries
during AMI and CABG model episodes
would result in EPM–CR participant
eligibility for CR incentive payments.
For FFS–CR participants, we proposed
to use the terms ‘‘AMI care period’’ and
‘‘CABG care period’’ to refer to a period
of AMI or CABG care, respectively, that
would meet the requirements to be an
AMI or CABG model episode in
accordance with all provisions in
subpart B if the FFS–CR participant
were an AMI or CABG model
participant. CR/ICR services paid by
Medicare to any provider or supplier for
beneficiaries during AMI care periods
and CABG care periods would result in
FFS–CR participant eligibility for CR
incentive payments. Defining AMI care
periods and CABG care periods using
the AMI and CABG model episode
definitions ensures that the care covered
under AMI care periods and CABG care
periods is comparable to AMI and
CABG model episodes in terms of the
criteria that must be met to start an AMI
care period or CABG care period or an
AMI or CABG model episode, as well as
the duration of AMI care periods and
CABG care periods and AMI and CABG
model episodes. This comparability
would contribute to our ability to test
and evaluate the effects of the CR
incentive payment and specifically to
assess whether there are differential
effects of the CR incentive payment in
the underlying EPM and FFS payment
methodologies.
We also proposed that AMI and CABG
model episodes take precedence over
AMI care periods and CABG care
periods. That is, an AMI care period or
CABG care period would not begin if
the beneficiary is in an AMI or CABG
model episode when the AMI care
period or CABG care period would
otherwise begin. Similarly, an AMI care
period or CABG care period would be
canceled if at any time during the AMI
care period or CABG care period the
beneficiary initiates an AMI or CABG
model episode. We believe that this is
appropriate because AMI and CABG
model participants would have ultimate
responsibility for care coordination and
the quality and cost of a beneficiary’s
care during an AMI or CABG model
episode. Giving precedence to AMI and
CABG model episodes would also
ensure that Medicare does not make
duplicative CR incentive payments for a
beneficiary and that a single beneficiary
is not in an AMI or CABG model
episode and an AMI care period or
CABG care period at the same time.
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We proposed that for the purposes of
the CR incentive payment, all AMI and
CABG model episodes and all AMI care
periods and CABG care periods must
begin on or after July 1, 2017 and end
on or before December 31, 2021. Thus,
the CR performance years would be the
same as the performance years proposed
for the EPMs in section III.D.2.a. of this
final rule. Given that the CR incentive
payment model seeks to determine
whether there are differential effects of
the CR incentive payment in the
underlying EPM and FFS payment
methodologies, it is important the EPM
and CR performance years be aligned for
EPM–CR participants.
The proposal to establish which CR/
ICR services count towards CR incentive
payments is included in § 512.705. We
sought comments on our proposal to
establish which CR/ICR services count
towards CR incentive payments.
The following is a summary of the
comments received and our responses.
Comment: A commenter suggested
that EPM beneficiaries be offered the
opportunity to participate in an
independent CR program, as it has been
the experience of this commenter that
many patients see positive outcomes
similar to those of patients who
participate in more traditional CR
programs. However, the commenter
offering this suggestion also raised the
concern that such programs may
inadvertently be financially penalized
because they do not follow the proposed
structure of CR visits. Another
commenter referenced exposure to
numerous studies on and examples of
integrated, remote CR programs, with
reported similar efficacy, higher
enrollment, and higher completion rates
compared to traditional CR, and
recommended CMS support these
alternative models with the belief that
such alternatives will foster innovation,
enable cost-effective and tailored
options for CR.
Response: While we appreciate all
suggestions for considered
improvements to the range and type of
services offered, we are limited by the
scope of this model to testing the
provision of services that can be
recognized through HCPCS coding
procedures and therefore will finalize
provision of incentive payments for
services described by HCPCS codes for
CR/ICR services in Table 55.
Comment: Commenters generally
agreed with the proposed CR/ICR
services that should count towards CR
incentive payments. There were
additional recommendations from
commenters to align incentive payments
with other aspects of a CR/ICR program,
such as duration or frequency of
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sessions, while other commenters
proposed alternative programs
including examples such as physical
and occupational therapy, pulmonary
rehabilitation, home health therapy, and
construction of a new program termed
virtual cardiac rehabilitation to take
place in the patient’s home.
Response: We proposed to identify CR
and ICR services that count towards CR
incentive payments on the basis of the
presence of the HCPCS codes on PFS
and OPPS claims that report CR/ICR
services as displayed in Table 55. These
HCPCS codes have been active since
prior to 2013 through the present. We
note that CMS specifies the CR/ICR
HCPCS codes in implementing the
statutory coverage provisions for CR and
ICR programs, and we would update
this list of HCPCS codes for CR/ICR
services for the CR incentive payment
model in future CR performance years
should CMS adopt different or
additional HCPCS codes for reporting
these services. We continue to believe
that CR/ICR services are unique as an
underutilized Medicare-covered benefit
with a strong evidence base of improved
health outcomes for beneficiaries who
have had an AMI or a CABG. Therefore,
we believe that CR/ICR services are
uniquely appropriate for CR incentive
payments to selected AMI and CABG
model participants as well as selected
hospitals that would not be
participating in these models in order to
reward their efforts where we observe
increased CR/ICR service utilization for
CR incentive payment model
beneficiaries. As a result, we are
finalizing this proposal because we
continue to believe this structured
approach will contribute to our ability
to test and evaluate the effects of the CR
incentive payment and specifically
whether there are differential effects of
the CR incentive payment in the
underlying EPM and FFS payment
methodologies.
Comment: Some commenters
expressed confusion regarding the
process by which ICR programs are
approved by CMS. Others suggested the
need for clarification as to how
individual sites wishing to furnish ICR
services be able to participate. A
commenter was concerned that EPM
participant hospitals that do not have
their own CR/ICR programs will not be
eligible for payments under the CR
Incentive Payment Model. A commenter
requested that CMS clarify that all ICR
programs covered under the CR
incentive payment model receive
approval under the NCD process, as this
commenter believes the NCD process
serves an important function in
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ensuring that these programs meet the
underlying statutory requirements.
Response: Approved ICR programs
will continue to be required to meet the
statutory requirements set forth in
section 1861(eee)(4) of the Act. The
NCD process, as authorized by section
1862(l) of the Act will continue to be
used to determine whether an ICR
program falls within the scope of this
Part B benefit. An ICR program will
continue to be evaluated in an open,
transparent, and publicly engaging
process. The standards for an ICR
program are included in Section
410.49(c) of this subpart. CR
participants without their own CR/ICR
programs will receive the CR incentive
payment based on the CR/ICR service
utilization of beneficiaries attributed to
them, regardless of the specific provider
or supplier that furnished the CR/ICR
services to the beneficiary during the
episode or care period.
Comment: A commenter believes a
significant majority of PFS claims for CR
services are misleading. This
commenter submitted an analysis of
Medicare PFS claims for HCPCS code
93798 by specialty and identified the
top five most frequently occurring
specialties to be cardiology, internal
medicine, family practice, cardiac
electrophysiology, and emergency
medicine. Based on these data, the
commenter strongly questioned the
appropriateness of the physician’s office
for the provision of CR services, and
urged CMS to scrutinize PFS claims
paid for delivery of CR services, as the
commenter believes these claims are
simple coding errors, or possible fraud/
abuse. The commenter recommended
that OPPS claims for CR/ICR services
would be the accurate source to track for
the CR incentive payment model.
Response: We thank the commenter
for providing their analysis. While most
CR/ICR services are billed and paid
under the OPPS because they are
furnished in the hospital outpatient
department, CR/ICR services are also
covered under Medicare when
furnished in a physician’s office where
they are paid under the PFS.159 PFS
claims for CR/ICR services furnished in
the physician’s office report place of
service code 11 (office). Our analysis
showed that more than 95 percent of
CR/ICR services for beneficiaries with
AMI or CABG were billed under the
OPPS. In addition, for CR/ICR services
billed under the PFS, the physician’s
159 Analysis of cardiac rehabilitation utilization in
care periods for AMI and CABG beneficiaries
initiated by all U.S. IPPS hospitals not in Maryland
and constructed using standardized Medicare FFS
Parts A and B claims, as proposed in this rule that
began in CYs 2012–2014.
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office was more frequently reported
than the hospital outpatient department.
In some cases, there were OPPS and PFS
claims for the same beneficiary for the
same day and the same CR/ICR service
HCPCS code, but it was extremely rare
for the PFS claim to have a place of
service code for the physician’s office in
these cases, occurring in only 0.01
percent of AMI care periods and 0.02
percent of CABG care periods. These
uncommon circumstances could either
reflect incorrect billing or an actual care
pattern where the same beneficiary
received CR/ICR services on the same
day in both the hospital outpatient
department and physician’s office.
Nevertheless, our analysis of historical
claims data showed no concerning
patterns about coding errors on claims
for CR/ICR services.
As discussed in the CY 2010 PFS
Final Rule (74 FR 61879), we note that
when a CR/ICR service is furnished in
a hospital outpatient department, a
physician cannot bill the Medicare
contractor for CR/ICR unless the
physician personally performs the CR/
ICR service. To personally perform the
CR/ICR service, the physician would
provide direct care to a single patient for
the entire session of CR/ICR that is
being reported. The hospital would
report the CR/ICR service and be paid
the OPPS payment amount for the
facility services associated with the CR/
ICR services. The physician would
report place of service code 19 or 22 (Off
Campus-Outpatient Hospital or On
Campus-Outpatient Hospital,
respectively) on the PFS claim. A
physician cannot bill under the PFS for
CR/ICR services furnished in a hospital
for which the physician furnishes only
supervision or for services furnished in
part by others. If the physician furnishes
no direct CR/ICR services for a given
session on a given day or provides
direct CR/ICR services for less than the
full session, then only the hospital
would report the CR/ICR services and
these services would be paid only under
the OPPS. Thus, to be sure that we are
capturing all unique sessions of CR/ICR
services furnished in the hospital
outpatient department or physician’s
office, without duplication in counting
those services, we will include all CR/
ICR services paid under the OPPS but
only those CR/ICR services that report
place of service code 11 on PFS claims
in the CR/ICR services that count
toward CR incentive payments.
We note that CR/ICR services will be
continue to be paid by the Medicare
program under the OPPS and the PFS
throughout the CR incentive payment
model performance years for CR
beneficiaries and are subject to all
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573
applicable rules governing the
submission of claims for services for
payment by Medicare. We refer to
sections III.J.8. and VI.F.7. of this final
rule for our discussion of the waiver of
the physician definition to allow, in
addition to a physician, a nonphysician
practitioner to perform the functions of
supervisory physician; prescribing
exercise; and establishing, reviewing,
and signing an individualized treatment
plan for a provider or supplier of CR/
ICR services furnished to an EPM–CR or
FFS–CR beneficiary during an AMI or
CABG episode or AMI care period or
CABG care period, respectively. We will
rely upon the CR/ICR services paid by
Medicare under the OPPS or to any
supplier reporting place of service code
11 on the PFS claim for determining the
CR/ICR services furnished to EPM–CR
and FFS–CR participants. All CR/ICR
services billed to Medicare must also
meet the billing requirements outlined
in the Medicare Claims Processing
Manual.160 CR/ICR services billed to
Medicare outside the episode must
continue to meet coverage requirements
described in 42 CFR 410.94 and any
applicable National Coverage
Determinations.161
We will monitor throughout the CR
incentive payment model the utilization
of CR/ICR services, including the place
of service. If this monitoring raises
concerns about erroneous claims or
potential fraud and abuse based on
significant changes in the distribution of
CR/ICR services being billed and paid
for CR beneficiaries in the physician’s
office and the hospital outpatient
department compared to historical
patterns and current patterns of CR/ICR
services furnished to Medicare
beneficiaries not in the CR incentive
payment model, we may more closely
examine the claims for these services
and/or refer these circumstances to
Medicare contractors for further
investigation.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal, with
modification, to establish which CR/ICR
services count towards CR incentive
payments in § 512.705 as CR/ICR
services identified by the HCPCS codes
for CR/ICR services in the CR
performance year when those CR/ICR
services are paid under the OPPS or to
160 Claims Processing Requirements for Cardiac
Rehabilitation (CR) and Intensive Cardiac
Rehabilitation (ICR) Services Furnished on or After
January 1, 2010. Chapter 32, Section 140.2.2.
Medicare Claims Processing Manual.
161 Intensive Cardiac Rehabilitation (ICR)
Programs. Chapter 1, Part 1, Section 20.31.1–3.
Medicare National Coverage Determinations (NCD)
Manual.
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any supplier reporting place of service
code 11 on a PFS claim. This
modification to limit CR/ICR services
from suppliers to those reporting place
of service code 11 on the PFS claim,
rather than all CR/ICR services from
suppliers, ensures that we can establish
a unique, unduplicated count of CR/ICR
services furnished in the hospital
outpatient department and in the
physician’s office to a CR beneficiary for
purposes of the CR incentive payment to
CR participants.
Table 56 displays the HCPCS codes
currently used for reporting CR/ICR
services and that will be used counting
CR/ICR services under the CR incentive
payment model.
TABLE 56—HCPCS CODES FOR CARDIAC REHABILITATION AND INTENSIVE CARDIAC REHABILITATION SERVICES
HCPCS Code
93797
93798
G0422
G0423
...................................
...................................
...................................
...................................
Descriptor
Physician services for outpatient cardiac rehabilitation; without continuous ECG monitoring (per session).
Physician services for outpatient cardiac rehabilitation; with continuous ECG monitoring (per session).
Intensive cardiac rehabilitation; with or without continuous ECG monitoring with exercise, per session.
Intensive cardiac rehabilitation; with or without continuous ECG monitoring; without exercise, per session.
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1. Determination of CR Amounts That
Sum To Determine a CR Incentive
Payment
Given the potential benefits of CR/ICR
services, in conjunction with the low
adoption of these services, we sought to
propose an incentive for CR participants
that was sufficient to encourage them to
increase clinically appropriate CR/ICR
service referrals for beneficiaries; reduce
barriers to beneficiary adherence to a
CR/ICR service treatment plan by
making additional resources available
for transportation to and from CR/ICR
services; and incentivize CR participant
monitoring and support of beneficiary
adherence to all prescribed sessions of
the CR/ICR program. As such, in
addition to the usual payments that
Medicare makes to providers and
suppliers that furnish CR/ICR services,
we proposed to establish a two-level
per-service CR incentive amount that
would initially incentivize the use of
any CR/ICR services and that would
increase once a beneficiary meets or
exceeds the proposed CR/ICR service
utilization benchmark. The CR amount
would be the dollar amount determined
by the two-level per-service CR
incentive amounts that apply to the
number of CR/ICR services paid by
Medicare to any provider or supplier for
a beneficiary in an AMI or CABG model
162 Hammill BG, Curtis LH, Schulman KA,
Whellan DJ. Relationship between cardiac
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episode or AMI care period or CABG
care period. CR amounts across all of a
CR participant’s beneficiaries that
received CR/ICR services would be
summed for the CR performance year to
determine the CR incentive payment for
a CR participant. CMS would pay the
CR incentive payment from the Part B
Trust Fund to the CR participant after
the end of each CR performance year,
and the beneficiary-specific CR amounts
would be submitted to the CMS Master
Database Management (MDM) System.
For the purpose of determining the CR
incentive payment, we proposed to
count the number of CR/ICR services for
the relevant time periods under the
OPPS and PFS on the basis of the
presence on paid claims of the HCPCS
codes that report CR/ICR services as
displayed in Table 55 and the units of
service billed.
The initial level of the per-service CR
incentive amount that would count
toward the CR amount would be $25 per
CR/ICR service for each of the first 11
CR/ICR services paid for by Medicare
during an AMI or CABG model episode
or AMI care period or CABG care
period. We believe that $25 is an
appropriate amount to account for the
additional resources that CR
participants would expend to reduce
beneficiary barriers to utilizing any CR/
ICR services and to support beneficiary
adherence to all prescribed services in
the CR/ICR program.
After 11 CR/ICR services are paid for
by Medicare for a beneficiary, the level
of the per-service CR incentive amount
would increase to $175 per CR/ICR
service for each additional CR/ICR
service paid for by Medicare during the
AMI or CABG model episode or AMI
care period or CABG care period. This
higher payment would account for the
additional resources that CR
participants expend to reduce
beneficiary barriers to CR/ICR service
utilization and also would reward CR
participants for AMI or CABG model
episodes or AMI care periods or CABG
care periods in which beneficiaries meet
or exceed the service utilization
benchmark of 12 CR/ICR services.
We set the proposed service
utilization benchmark based on
evidence from the literature that shows
reduced mortality for Medicare
beneficiaries that complete at least 12
CR sessions relative to Medicare
beneficiaries who complete 1–11 CR
sessions. A study by Hammill et al
found that over a 4-year follow-up
period beneficiaries who completed 12–
23 CR sessions had lower mortality
compared to beneficiaries who
completed 1–11 CR sessions and that
beneficiaries who completed 24 or more
CR sessions had lower mortality
compared to beneficiaries that
completed 12–23 sessions.162 Figure 6
replicates Figure 2 from that study.
rehabilitation and long-term risks of mortality and
E. Determination of CR Incentive
Payments
myocardial infarction among elderly Medicare
beneficiaries. Circulation. 2010; 121:63–70.
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575
sessions had lower mortality compared
to beneficiaries who were probable
candidates for CR but completed 0 CR
sessions and that beneficiaries who
completed 25 or more CR sessions had
lower mortality compared to
beneficiaries who completed 1–24 CR
sessions.164 Figure 7 replicates Figure 1
from that study.
163 Figure 2 of Hammill BG, Curtis LH, Schulman
KA, Whellan DJ. Relationship between cardiac
rehabilitation and long-term risks of mortality and
myocardial infarction among elderly Medicare
beneficiaries. Circulation. 2010; 121:63–70. Note
that the 30,161 overall beneficiaries in the table
contained in the figure refers to the number of
Medicare beneficiaries that initiated cardiac
rehabilitation services between January 1, 2000 and
December 31, 2005 in the national 5 percent sample
used by Hammill et al.
164 Suaya JA, Stason WB, Ades PA, Normand ST,
Shephard DS. Cardiac rehabilitation and survival in
older coronary patients. Journal of the American
College of Cardiology 2009; 54:25–33.
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Another study by Suaya et al. showed
that over a 5-year period beneficiaries
who were hospitalized for coronary
conditions or cardiac revascularization
procedures and completed 1–24 CR
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We did not propose to set a cap on the
number of CR/ICR services that would
count toward the CR amount during an
AMI or CABG model episode or AMI
care period or CABG care period
because the literature showed
incremental improvements in outcomes
associated with more CR/ICR services
through 36 or more sessions. The
duration of AMI and CABG model
episodes and AMI care periods and
CABG care periods is only 90 days postdischarge from the hospitalization that
begins the episode or care period, or
roughly 13 weeks, and Medicare already
limits the number of covered CR/ICR
services for a beneficiary. The number
of CR program sessions are limited to a
maximum of 2 one-hour sessions per
day for up to 36 sessions over up to 36
weeks, with the option for an additional
36 sessions over an extended period of
time if approved by the Medicare
Administrative Contractor under section
1862(a)(1)(A) of the Act.166 ICR program
sessions are limited to 72 one-hour
sessions, up to 6 sessions per day, over
a period of up to 18 weeks.167
We believe that the higher per-service
CR incentive amount that would count
toward the CR amount when CR/ICR
165 Figure 1 of Suaya JA, Stason WB, Ades PA,
Normand ST, Shephard DS. Cardiac rehabilitation
and survival in older coronary patients. Journal of
the American College of Cardiology 2009; 54:25–33.
166 42 CFR 410.49(b)(1)(vii).
167 Section 1861(eee)(1) of the Act.
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services paid by Medicare to any
provider or supplier for a beneficiary in
an AMI or CABG model episode or AMI
care period or CABG care period meet
or exceed the evidence-based service
utilization benchmark would strengthen
the financial incentive for CR
participants to ensure beneficiary
adherence to all prescribed CR/ICR
services beyond the initial $25 perservice CR incentive amount for the first
11 CR/ICR services. Moreover, the
higher level of the per-service CR
incentive amount when a beneficiary
completes at least 12 CR/ICR services
provides a strong incentive for CR
participants to expand CR referrals and
to increase the likelihood that
beneficiaries complete a clinically
meaningful number of CR services. The
proposal creates a continuous,
significant incentive for increased CR/
ICR service utilization that provides
value beyond the service utilization
benchmark of 12 CR/ICR services,
consistent with the literature that shows
a decrease in mortality for beneficiaries
that complete more CR sessions relative
to beneficiaries that complete fewer CR
sessions.
The CR amount for a beneficiary in a
CR participant’s AMI and CABG model
episodes or AMI care periods and CABG
care periods in a CR performance year
would be the sum of the $25 per-service
CR incentive amount for each of the first
11 CR/ICR services and the $175 per-
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service CR incentive amount for each
additional CR/ICR service paid by
Medicare beyond the first 11. The CR
participant’s CR incentive payment for a
CR performance year would be
determined based on the sum of the CR
amounts across all of its beneficiaries
for that CR performance year.
We believe that this comprehensive
CR incentive payment methodology
would be appropriate because it would
create an explicit, strong incentive for
CR participants to expand the
utilization of CR/ICR services to achieve
at least the evidence-based service
utilization benchmark of 12 ICR/CR
services and then significantly and
continuously incentivize the provision
of additional CR/ICR services that
provide additional value, even if the full
benefit of CR/ICR services for
beneficiaries that have had an AMI or a
CABG is not realized until after an
episode or care period ends. Moreover,
the CR incentive payment could offset
resource costs incurred by CR
participants that successfully increase
utilization of CR/ICR services, such as
FFS–CR participants providing
transportation or EPM–CR participants
providing beneficiary engagement
incentives as discussed in sections
III.I.9. and VI.F.6. of this final rule for
EPM–CR and FFS–CR participants,
respectively.
Because the CR incentive payment
would be made to the CR participant
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retrospectively after the end of a CR
performance year as discussed in
section VI.E.4. of this final rule, the CR
incentive payment would represent the
totality of financial reward to the CR
participant based on the proposed
methodology for determining the
payment based on CR/ICR service
utilization during the CR performance
year. The CR participant’s resources
required to support the increased
utilization of CR/ICR services are likely
to vary among beneficiaries. For
example, it is possible that greater CR
participant resources may be required to
encourage and support the utilization of
a beneficiary’s first CR/ICR services
during an AMI or CABG model episode
or AMI care period or CABG care
period, in comparison with promoting
adherence to additional prescribed CR/
ICR services once the care pattern is
well-established for that beneficiary.
The proposed retrospective payment
approach means CR participants would
have the flexibility to redesign care to
meet the needs of their beneficiaries
regarding increased utilization of CR/
ICR services, even though the CR
incentive payment methodology only
provides the higher level per-service CR
incentive amount when CR/ICR service
utilization achieves levels associated
with improved outcomes. The approach
is consistent with the model payment
methodology that is designed to reward
the value and not the volume of services
by providing a higher total financial
reward for utilization of services that
has been shown to result in improved
outcomes.
The proposals for determining the
amount of the CR incentive payments
were proposed in § 512.710(a) and (b).
We would also note that we expect to
revisit the levels of the CR incentive
payment and the service utilization
benchmark over the CR performance
years as we observe the effects of the
model policies on CR/ICR service
utilization and the long-term outcomes
and Medicare expenditures for CR
incentive payment model beneficiaries
under the EPMs and Medicare FFS
program payment methodologies for
overall care. For example, it is possible
that the proposed CR incentive payment
methodology could lead to substantial
increases in CR/ICR service utilization
such that the proposed CR incentive
payment model policies may no longer
be necessary or appropriate once new
care patterns are well-established.
The following is a summary of the
comments received and our responses.
Comment: A few commenters
requested CMS consider the feasibility
of expanding the number of CR/ICR
incentive payment model beneficiaries
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to include all diagnoses eligible for CR
coverage through Medicare and/or
enable all EPM participants which are
selected for the AMI/CABG model to be
eligible for participation in the CR
program.
Response: While we acknowledge that
CR/ICR services are provided for many
indications, it would be unreasonable to
test multiple proposals to address these
concerns simultaneously, as such tests
would make the assignment of
appropriate controls difficult and
assessment of impacts and outcomes
from such proposals challenging to
attribute to just one proposal. CMS
proposed that EPM–CR participants be
defined as hospitals that are AMI or
CABG model participants located in the
MSAs selected for the EPM–CR
participation, and similarly proposed
that FFS–CR participants are hospitals
located in the MSAs selected for FFS–
CR participation. We proposed the CR
incentive payment model to test the
effects on quality of care and Medicare
expenditures of providing explicit
financial incentives in addition to,
rather than in lieu of, current Medicare
expenditures to CR participants for
beneficiaries hospitalized for treatment
of AMI or CABG to encourage care
coordination and greater utilization of
medically necessary CR/ICR services for
90 days post-hospital discharge where
the beneficiary’s overall care is paid
under either an EPM or the Medicare
FFS program. We continue to expect
that EPM participants would be highly
engaged in care management of
beneficiaries for the 90-day postdischarge duration included in the
episode and could be able to capitalize
on that engagement to encourage greater
use of medically appropriate CR/ICR
services if they were also selected for
participation in the CR incentive
payment model.
Comment: Commenters offered a
variety of perspectives on the duration
of the period of time for which the CR/
ICR incentive payment would be made.
A commenter suggested that the
incentives as stated should be sufficient
to encourage the timely enrollment of
patients in to CR but noted that the 90day period will likely not be sufficient
to maximize their full effect on
improving adherence if they are only in
effect for 90 days after index event. A
few commenters further encouraged
CMS to consider the option of having
the incentives maintained beyond the
90-day period. In contrast, one
commenter noted that the timing of the
payments as proposed may serve as an
incentive to enroll patients as soon as
possible and make program adjustments
to allow for more active participation
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577
during the 90-day time period.
Therefore, the commenter reasoned, it
would be incumbent on the CR/ICR
programs to implement strategies that
would result in immediate referral to get
patients enrolled within seven days of
hospital discharge and remove barriers
to more active participation to fully
complete the 36 sessions during the 90day period. A few other commenters
expressed uncertainty around the
structure of the CR incentive payment
and requested that CMS confirm that
CR/ICR incentive payments will persist
for EPM beneficiaries after their 90-day
EPM episode ends, citing their
experiences of a lag in time before
which a referral for CR/ICR services is
made and their experience with the
period of time over which a CR/ICR
course of treatment takes place.
Similarly, several commenters requested
that CMS confirm that CR/ICR incentive
payments will be made in addition to,
rather than in lieu of, the underlying
Medicare FFS payments to providers for
CR/ICR services.
Response: While we acknowledge that
CR/ICR services often continue beyond
the 90- day post-discharge duration we
proposed for the CR incentive payment
model, it would be unreasonable to test
multiple proposals to address these
concerns simultaneously, as such tests
would make the assignment of
appropriate controls difficult and
assessment of impacts and outcomes
from such proposals challenging to
attribute to just one proposal. We
proposed the CR incentive payment
model to test the effects on quality of
care and Medicare expenditures of
providing explicit financial incentives
in addition to, rather than in lieu of,
current Medicare expenditures to CR
participants for beneficiaries
hospitalized for treatment of AMI or
CABG to encourage care coordination
and greater utilization of medically
necessary CR/ICR services for 90 days
post-hospital discharge where the
beneficiary’s overall care is paid under
either an EPM or the Medicare FFS
program. We continue to expect that
EPM participants would be highly
engaged in care management of
beneficiaries for the 90-day postdischarge duration included in the
episode and could be able to capitalize
on that engagement to encourage greater
use of medically appropriate CR/ICR
services if they were also selected for
participation in the CR incentive
payment model. Therefore, we are not
extending incentive payments at this
time as we believe the proposal to
provide a CR incentive payment
specifically to EPM–CR participants is
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reasonable when it aligns with the AMI
or CABG episode of care because these
participants are already engaged in
managing the AMI or CABG model
beneficiary’s overall care for a period of
time following hospital discharge and
will compare these participants to FFS–
CR participants.
Comment: Commenters raised
concern that the proposed timing of the
CR incentive payment model did not
align with the panoply of patient
experiences. A commenter stated that
not all patients need the full
complement of CR/ICR sessions, and
another stated that not all cardiac
patients are candidates for cardiac
rehabilitation services. To this end,
commenters submitted alternative
proposals, including combining
payments for CR/ICR services into the
bundled payment for AMI and CABG.
Response: While we agree that
improved outcomes have been
demonstrated in patients who
participate in as little as one CR session
per week over 36 weeks (74 FR 61875),
the proposed general design of the CR
incentive payment model is consistent
with the belief that encouraging timely
referral of beneficiaries that have had an
AMI or a CABG to CR/ICR programs
would promote better adherence to CR/
ICR service protocols, an expectation
that is supported by data showing that
patients who are referred early to CR
were more likely to enroll.168 We
believe this model may yield improved
coordination, care management, and
secondary risk reduction during the
episode of care after AMI or CABG for
the beneficiary. Additionally, CMS
proposed the CR incentive payment
model to test the effects on quality of
care and Medicare expenditures of
providing explicit financial incentives
to CR participants for beneficiaries
hospitalized for treatment of AMI or
CABG to encourage care coordination
and greater utilization of medically
necessary CR/ICR services for 90 days
post-hospital discharge where the
beneficiary’s overall care is paid under
either an EPM or the Medicare FFS
program, and believe that extending CR/
ICR incentive payments beyond the 90day episode is not aligned with the
proposed rationale. We remind all
commenters that section 410.49(f)
includes coverage for a maximum of two
1-hour CR sessions per day for up to 36
sessions over up to 36 weeks with the
option for an additional 36 sessions over
an extended period of time if approved
168 Grace SL et al. Effectiveness of inpatient and
outpatient strategies in increasing referral and
utilization of cardiac rehabilitation: A prospective,
multi-site study. Implement Sci. 2012: 7:120.
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by the Medicare Administrative
Contractor under section 1862(a)(1)(A)
of the Act.
Comment: Many commenters
expressed support for the CR/ICR
incentive payments as proposed, and
encouraged implementation, as they
believe the result will show support of
its broader use. A commenter noted that
the incentive payments are in the right
amounts and appropriately tiered for the
initial demonstration program. Several
commenters expressed opposing
viewpoints as to the sufficiency of the
CR/ICR incentive payment, and
MedPAC questioned whether such a
large amount would be necessary to
induce changes in provider behavior. A
commenter noted that it does not have
the expertise to determine whether the
proposed monetary payment is
sufficient to achieve the stated goal, and
encouraged CMS to seriously consider
comments from hospitals and the
community of cardiology professionals
to ensure the sufficiency of the
incentive payment. Another commenter
encouraged CMS to revisit the amount
of the incentive payments after 6
months to observe the effects of the
model policies on service utilization,
long-term outcomes, and Medicare
expenditures to assess if they are
sufficiently high to encourage plan
participants to identify and remove
beneficiary barriers to provision of CR/
ICR services. A commenter noted that
despite the CR/ICR incentive payment,
even participant hospitals that share
CMS’ goal of increasing clinically
appropriate services may be unlikely to
be able to devote staff and financial
resources to encourage beneficiary
participation in programs such as CR/
ICR whose benefits, while important,
primarily affect the cost of services
needed by beneficiaries long after the
AMI or CABG episode ends. Many
commenters questioned the extent to
which CMS provided sufficient
evidence supporting the sufficiency of
the CR incentive payment amount.
Several other commenters submitted
both general and specific concerns with
the proposed CR/ICR incentive payment
amount. MedPAC commented that the
proposed incentive payment of $175 per
CR/ICR service once a beneficiary
exceeds 11 CR/ICR services
considerably exceeds the amount
Medicare pays for each service itself,
could add up to a substantial amount
per beneficiary, and expressed
uncertainty as to how CMS determined
the level of the proposed payment
incentive amount. Several commenters
proposed alternative amounts for CR/
ICR incentive payments, including (1)
bundled payment for all CR/ICR
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services, which could be divided into
the following four categories: 5 or less
sessions, $500 allowed; 6–12 sessions,
$1000; 13–24 sessions, $2000; 25–36
sessions, $3000; (2) offer of a higher
level of per-service CR/ICR incentive
amount or adding a tier for increasing
the number of enrollees from an
underserved group; (3) make interim
incentive payments during the year; and
(4) increase in payment for the initial
session of CR/ICR services provided to
the patient from $25 to $175 as this first
session is fundamental to enrolling the
patient, beginning the rehabilitation
process, and reflecting the intense
resources necessary in the initial
evaluation, enrollment, and education
of the patient.
Response: We understand the
commenters’ concerns and appreciate
alternative proposals that are in the
spirit of testing the outcomes of the
proposed model. We set the proposed
service utilization benchmark based on
evidence from the literature that shows
reduced mortality for Medicare
beneficiaries that complete at least 12
CR sessions relative to Medicare
beneficiaries who complete 1–11 CR
sessions 169 170 and evidence that
beneficiaries who completed 25 or more
CR sessions had lower mortality
compared to beneficiaries who
completed 1–24 CR sessions.171 172
Furthermore, we did not propose to set
a cap on the number of CR/ICR services
that would count toward the CR
payment amount during an AMI or
CABG model episode or AMI care
period or CABG care period. We believe
the proposed approach, rather than the
alternative recommendations of the
commenters, is consistent with the
model payment methodology that is
designed to reward the value and not
the volume of services by providing a
higher total financial reward for
169 Intensive Cardiac Rehabilitation (ICR)
Programs. Chapter 1, Part 1, Section 20.31.1–3.
Medicare National Coverage Determinations (NCD)
Manual.
170 Hammill BG, Curtis LH, Schulman KA,
Whellan DJ. Relationship between cardiac
rehabilitation and long-term risks of mortality and
myocardial infarction among elderly Medicare
beneficiaries. Circulation. 2010; 121:63–70.
171 Figure 2 of Hammill BG, Curtis LH, Schulman
KA, Whellan DJ. Relationship between cardiac
rehabilitation and long-term risks of mortality and
myocardial infarction among elderly Medicare
beneficiaries. Circulation. 2010; 121:63–70. Note
that the 30,161 overall beneficiaries in the table
contained in the figure refers to the number of
Medicare beneficiaries that initiated cardiac
rehabilitation services between January 1, 2000 and
December 31, 2005 in the national 5 percent sample
used by Hammill et al.
172 Suaya JA, Stason WB, Ades PA, Normand ST,
Shephard DS. Cardiac rehabilitation and survival in
older coronary patients. Journal of the American
College of Cardiology 2009; 54:25–33.
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utilization of services that has been
shown to result in improved outcomes.
Since such incentive payments
specific to the provision of CR/ICR
services have not previously been tested
in this way, we will test to determine
whether there are sufficient payment
amounts applicable and available to
increase utilization of CR/ICR services.
We do know that an important design
element of any incentive payment
model is the threshold or benchmark 173
used to determine which CR
participants will receive incentive
payments. For this design element, we
believe we have presented strong
evidence in support of proposed
benchmarks that are clear, transparent,
and for which CR participants can attain
meaningful improvements. Therefore,
the proposed incentive payment amount
provides a strong incentive for CR
participants to expand CR referrals and
to increase the likelihood that
beneficiaries complete a clinically
meaningful number of CR services.
We may revisit the levels of the CR
incentive payment and the service
utilization benchmark over the CR
performance years as we observe the
effects of the model policies on CR/ICR
service utilization and the long-term
outcomes and Medicare expenditures
for CR incentive payment model
beneficiaries under the EPMs and
Medicare FFS program payment
methodologies for overall care.
Comment: A minority of commenters
stated confusion as to the extent to
which CR incentive payments would be
made in addition to or in lieu of
payments to providers for CR/ICR
services.
Response: We reiterate that under the
CR incentive payment model, a CR
incentive payment to EPM–CR and
FFS–CR participants would be made
under the model. Regular Medicare
program payments would continue to be
made to providers and suppliers that
furnish and bill for CR/ICR services to
beneficiaries in AMI or CABG episodes
or AMI care periods or CABG care
periods.
Comment: A few commenters raised
concern as to the means to implement
a value-based incentive design for a CR/
ICR model, as these commenters believe
the proposed CR/ICR incentive payment
model to be a utilization-based model.
Such alternative proposals included a
general focus on outcomes associated
with use of CR/ICR services and a
specific focus on outcome metrics (for
173 Damberg CL, et al. (2014) Measuring Success
in Health Care Value-Based Purchasing Programs.
Retrieved October 31, 2016, from the RAND
Corporation Web site: https://www.rand.org/pubs/
research_reports/RR306.html.
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example, 30-day mortality, rehospitalization rates) as well as process
metrics (referral to CR, statin use) for
those processes that are well established
and evidence-based. To this end, a few
commenters requested that CMS work
with the healthcare community to
determine appropriate patient-reported
outcomes measures for CR/ICR services
prior to finalizing the proposed EPMs.
Without specific outcome measures
attributed to this model, commenters
suggested that some policy makers
might incorrectly conclude that CR/ICR
services are not important. Furthermore,
commenters stated that these quality
measures would permit alignment with
tracks for Advanced APMs and MIPS
APMs. Several commenters suggested
inclusion of patient-reported outcome
(PRO) metrics, and requested that CMS
work with the healthcare community to
determine appropriate PRO metric(s). It
was suggested by these commenters that
such outcomes may identify appropriate
length of rehabilitation. Additionally,
MedPAC recommended creating claimsbased physician or hospital measures
for all providers who care for
beneficiaries with AMI and CABG, and
then such measures could gauge the
share of beneficiaries who receive CR/
ICR services.
Response: The CR incentive payment
for EPM–CR participants is specifically
tied to increased utilization of CR/ICR
services within AMI and CABG model
episodes and, the rationale for
utilization of such services is built on a
strong evidence base of improved health
outcomes for beneficiaries who have
had an AMI or a CABG. Therefore, this
model is designed to reward increased
EPM–CR participant referral of AMI and
CABG model beneficiaries to CR/ICR
programs. Additionally, we remind all
commenters that historical claims data
show that more than half of
beneficiaries who receive one CR
session go on to complete at least 25
sessions.174 Furthermore, we note that
an outcomes assessment is part of the
CR benefit established by Congress in
section 144(a) of the MIPPA, which is
designed to ensure CR programs
enhance the patient’s clinical outcomes.
Section 410.49 of this subpart further
describes the assessment of outcomes.
While we appreciate the remark that
quality measures are required for an
APM to qualify as an Advanced APM
under the QPP final rule, we remind all
commenters that an APM must also
require participants to bear financial
risk (or be a Medical Home Model
expanded under section 1115A(c) of the
174 Analysis of CR/ICR services utilization in 2013
Medicare FFS Parts A and B claims.
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579
Act) and utilize CEHRT, which CMS did
not propose for the CR/ICR incentive
payment model. Thus, we are finalizing
our CR incentive payment model
without including separate and distinct
quality measures.
Comment: MedPAC commented that
the same outcomes could be
accomplished by simply carving out
payment for CR/ICR services from the
EPM bundled payment and continuing
to pay for these services separately,
without incentive payments for EPM
participants.
Response: CMS proposed the CR
incentive payment model to test the
effects on quality of care and Medicare
expenditures of providing explicit
financial incentives to CR participants
for beneficiaries hospitalized for
treatment of AMI or CABG to encourage
care coordination and greater utilization
of medically necessary CR/ICR services
for 90 days post-hospital discharge
where the beneficiary’s overall care is
paid under either an EPM or the
Medicare FFS program. Therefore, we
disagree that the same test could be
accomplished by simply carving out CR/
ICR services from a bundled payment
for a broadly defined cardiac episode-ofcare. The CR incentive payment is not
a payment for the CR/ICR services
themselves. Rather, it is for the CR
participant work to coordinate and
increase the utilization of the
beneficiary’s participation in CR/ICR
services following hospital discharge. A
carve-out of the payments for CR/ICR
services from the EPM episode would
also not allow us to examine the effects
of a CR incentive payment in the
context of an underlying episode or FFS
payment methodology for overall care.
We will continue to monitor the effects
of this model on EPM–CR and FFS–CR
participants.
Comment: Most commenters agreed
that the primary goal of an incentive
payment model should be to recruit the
vast majority of prospective patients
into cardiac rehabilitation, with much
less emphasis on how many sessions
they attend. A commenter shared their
experience that for patients who have
been diligent in performing an exercise
program prior to cardiac event and/or
performing a home exercise program
since cardiac event, only one or several
sessions may be all that is necessary to
insure that these patients will obtain the
documented benefits of regular exercise.
Another commenter shared their
experience, particularly in the past 5–10
years, that most cardiac rehabilitation
participants, particularly those who
have not been very active pre- and postcardiac event, can achieve reasonable
improvements in exercise skills and
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confidence with just 6 to 24 sessions of
cardiac rehabilitation exercise. To this
end, many commenters expressed
concern that they believe there is a lack
of standardization around CR programs,
and it may be unclear which number of
sessions be tied to CR/ICR incentive
payments. A commenter encouraged
CMS to study the appropriate length of
these programs.
Response: We disagree, and refer the
commenters to research demonstrating
that beneficiaries who completed more
CR sessions had lower mortality
compared to beneficiaries that
completed fewer sessions.175 176 We
believe that the CR incentive payment
model has an evidence-based focus on
payment of the CR incentive payment
based on the number of sessions
beneficiaries attend. The proposed
model is also focused in scope so as to
best understand the effects on quality of
care and Medicare expenditures for
providing explicit financial incentives
to CR participants to increase CR/ICR
utilization for beneficiaries following
hospitalization for treatment of AMI or
CABG. Therefore, we believe that such
research and development of a
standardized CR program is outside the
scope of the proposed rule.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal, with
modification as discussed in the
previous section, for determining the
amount of the CR incentive payments in
§ 512.710(a) based on CR/ICR services
paid by Medicare to any provider or any
supplier reporting place of service code
11 on the claim for CR beneficiaries. We
are finalizing the proposal, without
modification, in § 512.710(b) for
determination of the CR incentive
payment. However, we are revising our
proposed definitions of the terms CR
amount and CR service count used in
§ 512.710(b) to incorporate the same
limitation to include only those CR/ICR
services on supplier claims that report
place of service code 11 as previously
discussed. Therefore, CR amount means
the dollar amount determined by the
number of CR/ICR services paid by
Medicare to any provider or to any
supplier reporting place of service code
11 on the claim for a beneficiary in an
AMI or CABG model episode or AMI
care period or CABG care period.
175 Hammill BG, Curtis LH, Schulman KA,
Whellan DJ. Relationship between cardiac
rehabilitation and long-term risks of mortality and
myocardial infarction among elderly Medicare
beneficiaries. Circulation. 2010; 121:63–70.
176 Suaya JA, Stason WB, Ades PA, Normand ST,
Shephard DS. Cardiac rehabilitation and survival in
older coronary patients. Journal of the American
College of Cardiology 2009; 54:25–33.
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Similarly, CR service count means the
number of CR/ICR services paid by
Medicare to any provider or to any
supplier reporting place of service code
11 on the claim for a beneficiary in an
AMI or CABG model episode or AMI
care period or CABG care period.
As we proposed, we will determine
the CR amount for a beneficiary in an
AMI or CABG model episode or AMI
care period or CABG care period with a
CR service count less than 12 by
multiplying the CR service count by
$25. We will determine the CR amount
for a beneficiary in an AMI or CABG
model episode or AMI care period or
CABG care period with a CR service
count of 12 or more as the sum of $275
($25 multiplied by 11 for the first 11
CR/ICR services paid for by Medicare)
and $175 multiplied by the difference
between the CR service count and 11.
Finally, we will sum the CR amounts
determined previously across the CR
participant’s beneficiaries in AMI and
CABG model episodes or AMI care
periods and CABG care periods for a
given CR performance year to determine
the CR incentive payment for the CR
performance year. The determination of
the CR incentive payment occurs at the
same time that CMS carries out the
reconciliation process for an EPM
performance year.
2. Relation of CR Incentive Payments to
EPM Pricing and Payment Policies and
Sharing Arrangements for EPM-CR
Participants
We view the proposed CR incentive
payments as separate and distinct from
reconciliation payments and Medicare
repayments for EPM–CR participants
determined under § 512.305(d). The
determination of these latter payments
is based on an assessment of actual
episode payments and quality of the
totality of episode services and
coordination of those services during
AMI and CABG model episodes within
a performance year, consistent with the
goals of improving quality and reducing
costs within the model episode itself. In
contrast, the proposed CR incentive
payment under the CR incentive
payment model is a more circumscribed
and specific payment designed to
financially incentivize increased
utilization of CR/ICR services which
may improve quality and reduce costs
for AMI and CABG model beneficiaries
in the long-term, after the episodes end.
Thus, we proposed to determine and
apply the CR incentive payment
separately from the determination and
application of reconciliation payments
and Medicare repayments for EPM–CR
participants. Moreover, we would also
note that we proposed to make CR
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incentive payments to EPM–CR
participants without application of the
limitation on gains as specified in
§ 512.305(c)(2)(iii)(B). This is because
the limitation on gains is designed to
mitigate potential excessive reductions
in utilization under the EPMs, and by
construction, the CR incentive payment
would only be made when an EPM–CR
participant increases utilization of CR/
ICR services. Therefore, the CR
incentive payment is unrelated to the
comparison of actual EPM episode
payment to the quality-adjusted target
price in calculating the NPRA, to which
the limitation on gains applies and that
may ultimately result in a reconciliation
payment to an EPM-CR participant.
Consistent with the aforementioned
proposal and for the aforementioned
reasons, in contrast to reconciliation
payments, we proposed to not permit
the inclusion of CR incentive payments
in sharing arrangements for EPM-CR
participants specified in § 512.500. As
discussed in section III.I.1. of this final
rule, we believe that EPM participants
may wish to enter into financial
arrangements with providers and
suppliers caring for EPM beneficiaries to
share financial risks and rewards under
the EPM, in order to align the financial
incentives of those providers, suppliers,
and Medicare ACOs with the EPM goals
of improving quality and efficiency for
EPM episodes. In contrast, the CR
incentive payment for EPM-CR
participants is specifically tied to
increased utilization of CR/ICR services
within AMI and CABG model episodes
and, therefore, is designed to reward
increased EPM-CR participant referral of
AMI and CABG model beneficiaries to
CR/ICR programs, as well as supporting
beneficiary adherence to the referral and
participation in CR/ICR services, rather
than the quality and efficiency of EPM
episodes themselves. Thus, we did not
propose to allow CR incentive payments
to be included in sharing arrangements,
and the CR incentive payments may be
shared with other individual and
entities only under circumstances
which comply with all existing laws
and regulations, including fraud and
abuse laws. Similarly, we did not
propose that CR incentive payments be
allowed to be shared by FFS–CR
participants with other individuals and
entities other than under circumstances
which comply with all existing laws
and regulations, including fraud and
abuse laws. We refer to section VI.G. of
this final rule for further discussion of
considerations regarding financial
arrangements under the CR incentive
payment model.
Likewise, we proposed to exclude CR
incentive payments when updating
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quality-adjusted target prices for EPMCR participants for performance years
3–5 of the EPMs because payments for
CR/ICR services already would be
captured in the claims used to update
those quality-adjusted target prices.
Therefore, we believe that including the
CR incentive payments would result in
double counting expenditures for CR/
ICR services when updating qualityadjusted target prices. We note that
while the CR incentive payments would
not be included in the calculation of
actual EPM episode spending or when
updating quality-adjusted target prices
for EPM-CR participants, the claims for
those CR/ICR services upon which the
CR incentive payment was determined
would be included in both calculations.
The proposals for keeping CR
incentive payments, if any, separate
from reconciliation payments and
Medicare repayments as well as
excluding them from sharing
arrangements and updating quality
adjusted target prices for EPM-CR
participants are included in § 512.710(c)
through (e). We sought comments on
our proposals to keep CR incentive
payments separate and exclusive.
The following is a summary of the
comments received and our responses.
We refer to section VI.G of this final rule
for a summary of the comments and our
response on our discussion in the
proposed rule of financial arrangements
under the CR incentive payment model.
Comment: A commenter raised
concern that while CMS proposed to
exclude CR incentive payments from the
calculation of episode spending and
quality-adjusted target prices for AMI
and CABG episodes, the actual FFS
payments to providers of CR/ICR
services will be included in both
calculations. To this end, another
commenter suggested that if efforts to
increase CR utilization are successful,
many EPM participants will not be
eligible for reconciliation payments; in
addition, this commenter believes that
EPM participant hospitals that do not
have their own CR/ICR programs will
not be eligible for CR incentive
payments under the CR incentive
payment model.
Response: We acknowledge that FFS
payments for CR/ICR services will be
included in the calculation of AMI and
CABG actual episode spending because
these services are related and included
in AMI and CABG episodes. We
proposed that the CR incentive payment
itself be separate and excluded from
AMI and CABG episodes because this
incentive payment is a more
circumscribed and specific payment
designed to financially incentivize
increased utilization of CR/ICR services
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which may improve quality and reduce
costs for AMI and CABG model
beneficiaries in the long-term, after the
episodes end. However, we also believe
that there is potential for CR/ICR
services to improve the quality of care
and reduce spending during the AMI
and CABG episodes themselves. For
example, CR/ICR services for which a
CR incentive payment may ultimately
be made under the CR incentive
payment model may provide additional
transferable benefits on cost and quality
to beneficiaries during EPM episodes,
including the potential benefit
experienced by beneficiaries simply by
virtue of their participation in CR/ICR
programs, increased interaction with the
health care delivery system, and
frequent follow-up. Furthermore, EPM–
CR participants may see benefit from the
patient’s own behavior change as a
result of being under supervision, as
such interactions through CR/ICR
services could impact, for example,
adherence to medication therapies after
discharge, and/or seeking of follow-up
care from a primary care physician or
appropriate specialist. Therefore, any
increased spending for CR/ICR services
for beneficiaries in AMI and CABG
episodes attributable to EPM–CR
participants may be offset by reductions
in spending for other episode services,
such as readmissions or emergency care.
We disagree with the assumption that
EPM–CR participants cannot achieve
savings in the EPMs that result in
reconciliation payments due to reduced
spending on other episode service after
referring EPM beneficiaries for an
increased number of CR/ICR services
over historical CR/ICR utilization. We
also reiterate that EPM–CR participants
that do not have their own CR/ICR
programs will be eligible for CR
incentive payments under the CR
incentive payment model based on the
CR/ICR utilization of AMI and CABG
model beneficiaries attributed to them,
regardless of where those beneficiaries
receive CR/ICR services. Finally, as we
stated previously, the design of the CR
incentive payment model will enable us
to test and improve our understanding
of the effects of the CR incentive
payment within the context of an EPM
and the Medicare FFS program, as well
as identify potential interactions
between the CR incentive payment and
the underlying EPM and FFS payment
methodologies.
Comment: A commenter
recommended that the cardiac
rehabilitation payment should be
included in the bundled payment for
AMI and CABG.
Response: We assume that this
comment refers to the CR incentive
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payment, and we disagree with such a
recommendation as this model
proposed a specific payment designed
to financially incentivize increased
utilization of CR/ICR services which
may improve quality and reduce costs
for AMI and CABG model beneficiaries.
FFS payments for CR/ICR services
themselves are included in EPM episode
spending. Thus, we proposed and are
finalizing that the CR incentive payment
be separate for EPM–CR participants.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal, without
modification, to keep CR incentive
payments, if any, separate from
reconciliation payments and Medicare
repayments, as well as excluding them
from sharing arrangements and updating
quality-adjusted target prices for EPM–
CR participants in § 512.710(c) through
(e).
3. CR Incentive Payment Report
For CR participants to receive timely
and meaningful feedback on their
performance with respect to the
proposed CR incentive payments, we
proposed to annually issue to CR
participants a report containing at a
minimum—
• 1—The number of AMI and CABG
model episodes or AMI care periods and
CABG care periods attributed to the CR
participant in which Medicare paid for
11 or fewer CR/ICR services for a
beneficiary during the CR performance
year, if any;
• 2—The total number of CR/ICR
services Medicare paid for during AMI
and CABG model episodes or AMI care
periods and CABG care periods
identified in (1);
• 3—The amount of the CR incentive
payment attributable to the AMI and
CABG model episodes or AMI care
periods and CABG care periods
identified in (1);
• 4—The number of AMI and CABG
model episodes or AMI care periods and
CABG care periods attributed to the CR
participant in which Medicare paid for
12 or more CR/ICR services for a
beneficiary during the CR performance
year, if any;
• 5—The total number of CR/ICR
services Medicare paid for during AMI
and CABG model episodes or AMI care
periods and CABG care periods
identified in (4);
• 6—The amount of the CR incentive
payment attributable to the AMI and
CABG model episodes or AMI care
periods and CABG care periods
identified in (4); and
• 7—The total amount of the CR
incentive payment.
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We also considered including
additional information in the CR
incentive payment report, including
information on the number of CR/ICR
services paid for by Medicare during
each AMI or CABG model episode or
AMI care period or CABG care period
attributed to the CR participant during
the CR performance year. However,
because EPM–CR participants and FFS–
CR participants can request more
specific beneficiary-level data that
would contain information on CR/ICR
services paid for by Medicare for each
AMI or CABG model episode or AMI
care period or CABG care period
attributed to the CR participant during
the CR performance year, as discussed
in sections III.K.2. and VI.F.3. of this
final rule, we did not include such
additional information in the CR
incentive payment report.
For EPM–CR participants, we
proposed to issue this annual report at
the same time we issue the
reconciliation report specified in
§ 512.305(f). For FFS–CR participants,
we proposed to issue this report at the
same time proposed for EPM–CR
participants.
The proposal to issue a CR incentive
payment report is included in
§ 512.710(f). We sought comments on
our proposal to issue a CR incentive
payment report to CR participants and
what other information, if any, would be
helpful to include in the CR incentive
payment report.
We received no comments specific to
our proposals for the CR incentive
payment report.
Final Decision: We are finalizing our
proposal, without modification, in
§ 512.710(f) to issue a CR incentive
payment report for each CR performance
year to EPM–CR and FFS–CR
participants to include at a minimum —
• 1—The number of AMI and CABG
model episodes or AMI care periods and
CABG care periods attributed to the CR
participant in which Medicare paid for
11 or fewer CR/ICR services for a
beneficiary during the CR performance
year, if any;
• 2—The total number of CR/ICR
services Medicare paid for during AMI
and CABG model episodes or AMI care
periods and CABG care periods
identified in (1);
• 3—The amount of the CR incentive
payment attributable to the AMI and
CABG model episodes or AMI care
periods and CABG care periods
identified in (1);
• 4—The number of AMI and CABG
model episodes or AMI care periods and
CABG care periods attributed to the CR
participant in which Medicare paid for
12 or more CR/ICR services for a
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beneficiary during the CR performance
year, if any;
• 5—The total number of CR/ICR
services Medicare paid for during AMI
and CABG model episodes or AMI care
periods and CABG care periods
identified in (4);
• 6—The amount of the CR incentive
payment attributable to the AMI and
CABG model episodes or AMI care
periods and CABG care periods
identified in (4); and
• 7—The total amount of the CR
incentive payment.
4. Timing for Making CR Incentive
Payments
We proposed to make CR incentive
payments on a retrospective basis. In the
case of an EPM–CR participant, these
payments would occur concurrently
with EPM reconciliation payments or
repayment amounts assessed for a
specific CR performance year which is
the same as the performance year for the
EPM, subject to the relation of the CR
incentive payment described in section
VI.E.2. of this final rule and the appeals
process for EPM participants described
in section III.D.8. of this final rule. In
the case of a FFS–CR participant, these
payments would occur at the same time
as was proposed for EPM–CR
participants, subject to the appeals
process described in section VI.F.2. of
this final rule.
The proposed timing for making CR
incentive payments is included in
§ 512.710(g). We sought comments on
our proposed timing for making CR
incentive payments.
The following is a summary of the
comments received and our responses.
Comment: A commenter stated
support for the proposal to establish an
incentive payment that would be paid
retrospectively, as this commenter
believes that cardiac rehabilitation is
very important in improving patient
health outcomes and reducing hospital
readmissions. In contrast, another
commenter offered an alternative
proposal for the timing of CR incentive
payments, and recommended CMS
make interim incentive payments
during the year so as to monitor take-up
rates to see if the incentive level needs
to be adjusted.
Response: We appreciate the
comments on the proposed timing for
making CR incentive payments.
However, we will not make interim CR
incentive payments through the
performance year based on claims for
CR/ICR services furnished to CR
beneficiaries that reflect less than a full
model performance year. Given the lag
in claims submission and payment in
the Medicare FFS program for Part B
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services, we are not confident that we
could gather sufficient reliable
information in a period of less than a
year that would cause us to reconsider
the CR incentive payment methodology,
including the amount, based on accurate
observations of complete CR/ICR service
utilization for model beneficiaries. In
addition, changing the CR incentive
payment methodology, including the
amount, would require rulemaking, for
which we would need sufficient
information on true utilization changes
and evaluation findings to propose a
revised methodology.
Therefore, we believe that the
proposed retrospective methodology
that provides the CR incentive payment
once per year to each CR participant
after the end of the CR performance year
is administratively straightforward for
CMS and CR participants and will allow
us to provide accurate CR incentive
payments based on the CR/ICR
utilization for CR beneficiaries. It will
be possible with this payment
methodology to monitor utilization of
CR/ICR services for beneficiaries
attributable to EPM–CR and FFS–CR
participants, and we will continue to
consider whether future proposals to
change the CR incentive payment
methodology are warranted based on
our monitoring and early model
implementation experience. Thus we
are finalizing our proposed timing for
the CR incentive payment.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal, without
modification, for the timing of making
CR incentive payments in § 512.710(g).
CMS makes CR incentive payments on
a retrospective basis subject to the
appeals process for EPM participants in
§ 512.310 and makes the CR incentive
payments, if any, at the same time as for
EPM–CR participants, subject to the
provisions in § 512.720.
F. Provisions for FFS–CR Participants
1. Access to Records and Retention for
FFS–CR participants
In section III.H. of this final rule, we
discuss our proposals for record access
and retention under the EPM. The
proposals describe the access to records
and retention requirements for all EPM
participants, including EPM–CR
participants and other individuals and
entities with respect to the EPM and CR
incentive payment model, if the latter is
applicable to the EPM participant. Two
of the six categories of information
subject to the requirements, specifically
compliance with the requirements of the
CR incentive payment model and the
obligation to repay any CR incentive
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payments owed to CMS, are relevant
only to the CR incentive payment
model. Thus, we proposed to establish
CR incentive payment model access to
records and retention requirements for
FFS–CR participants and any other
individuals or entities providing items
or services to a FFS–CR beneficiary that
are the same as we proposed for EPM–
CR participants and other individuals
and entities but only for the two
categories of information that are
applicable to the CR incentive payment
model. The other four categories of
information proposed for records access
and retention under the EPM,
specifically the calculation, distribution,
receipt, or recoupment of gainsharing
payments, alignment payments,
distribution payments, and downstream
distribution payments; the quality of the
services furnished; the sufficiency of
beneficiary notifications; and the
accuracy of the EPM participant’s
submissions under CEHRT use
requirements, are not relevant to the CR
incentive payment model for FFS–CR
participants and other individuals and
entities providing items and services to
FFS–CR beneficiaries because the CR
incentive payment model includes no
policies that relate directly to these
categories of information.
The proposals for access to records
and record retention for FFS–CR
participants and other individuals and
entities providing items and services to
FFS–CR beneficiaries are included in
§ 512.715. We sought comment on our
proposals, including whether it is
necessary, reasonable and appropriate to
impose these access and retention
obligations on the FFS–CR participant
and other individuals and entities
providing items and services to FFS–CR
beneficiaries for the proposed categories
of information to be retained and made
accessible. In addition, we sought
comment on whether additional or
different safeguards would be needed to
ensure program integrity, protect against
abuse, and ensure that the goals of the
CR incentive payment model are met.
The following is a summary of the
comments received and our responses.
Comment: A commenter requested
that CMS lower the duration of record
retention requirement for the CR
incentive payment model from ten
years, as this commenter believes ten
years is an excessive amount of time for
participating hospitals, collaborators,
collaboration agents, and downstream
collaboration agents to maintain
documentation on this model.
Response: While we appreciate the
commenter’s concern that ten years may
seem excessive, we note that, once
initiated, appeals and recalculation
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disputes can be lengthy processes and
believe that maintaining this
requirement as proposed would give
both the participant and CMS, as well
as those completing any audit,
evaluation, inspection, or investigation,
the resources to prepare and respond to
issues that may take several years to
surface. We continue to believe that
these record retention requirements can
be applied to categories of information
that are broader than those solely
related to financial arrangements, and
therefore will consider requesting access
to records that will assist in evaluating
and measuring the CR incentive
payment model goals.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal, without
modification, for access to records and
record retention for FFS–CR
participants and other individuals and
entities providing items and services to
FFS–CR beneficiaries in § 512.715.
2. Appeals Process for FFS–CR
Participants
a. Overview
In section III.D.8. (81 FR 50877
through 50880) of the proposed rule, we
discuss our proposals for the appeals
process under the EPMs. The proposal
outlines the appeals process
requirements for all EPM participants,
including EPM–CR participants, with
respect to the EPM and CR incentive
payment model, if the latter is
applicable to the EPM participant. CR
incentive payments as well as nonpayment related issues, such as
enforcement matters, are relevant only
to the CR incentive payment model.
Thus, we proposed to establish CR
incentive payment model appeals
process for FFS–CR participants that
have the same requirements as we
proposed for the EPM but based on only
the CR incentive payment and nonpayment related issues, such as
enforcement matters. All other
appealable items under the EPM,
specifically related to payment,
reconciliation amounts, repayment
amounts, determinations associated
with quality measures affecting payment
are not relevant to the CR incentive
payment model for any FFS–CR
participants because the CR incentive
payment model includes no policies
that relate directly to these categories of
information.
Final Decision: CMS did not receive
any comments on this section.
Therefore, we are finalizing the proposal
without modification.
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b. Notice of Calculation Error (First
Level Appeal)
We proposed the following
calculation error process for the CR
incentive payment model to contest
matters related to the calculation of the
FFS–CR participant’s CR incentive
payment as reflected in the CR incentive
payment report. FFS–CR participants
would review their CR incentive
payment report and be required to
provide written notice of any error in a
calculation error form that must be
submitted in a form and manner
specified by CMS. Unless the FFS–CR
participant provides such notice, the CR
incentive payment report would be
deemed final within 45 calendar days
after it is issued, and CMS would
proceed with payment. If CMS receives
a timely notice of an error in the
calculation, CMS would respond in
writing within 30 calendar days to
either confirm or refute the calculation
error, although CMS would reserve the
right to an extension upon written
notice to the participant. We proposed
that if a FFS–CR participant does not
submit timely notice of a calculation
error, which is notice within 45
calendar days of the issuance of the CR
incentive payment report, the FFS–CR
participant would be precluded from
later contesting the CR incentive
payment report for that CR performance
year.
In summary, we proposed the
following requirements in § 512.720(a)
for notice of calculation error:
• Subject to the limitations on review
in subpart H of this part, if a FFS–CR
participant wishes to dispute
calculations involving a matter related
to a CR incentive payment, the FFS–CR
participant is required to provide
written notice of the calculation error,
in a form and manner specified by CMS.
• Unless the FFS–CR participant
provides such notice, CMS deems final
the applicable CR incentive payment
report 45 calendar days after the
applicable CR incentive payment report
is issued and proceeds with the
payment as applicable.
• If CMS receives a notice of a
calculation error within 45 calendar
days of the issuance of the applicable
CR incentive payment report, CMS
responds in writing within 30 calendar
days to either confirm that there was an
error in the calculation or verify that the
calculation is correct, although CMS
reserves the right to an extension upon
written notice to the FFS–CR
participant.
• Only FFS–CR participants may use
the notice of calculation error process
described in this subpart.
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We sought comment on the proposed
notice of calculation error requirements.
Final Decision: We did not receive
any comments on this section.
Therefore, we are finalizing the proposal
without modification.
c. Dispute Resolution Process (Second
Level of Appeal)
We proposed the following dispute
resolution process. First, we proposed
that only a FFS–CR participant may
utilize this dispute resolution process.
Second, in order to access the dispute
resolution process a FFS–CR participant
must have timely submitted a
calculation error form, as previously
discussed, regarding the CR incentive
payment. We proposed these matters
would include any amount or
calculation indicated on a CR incentive
payment report, including calculations
not specifically reflected on a CR
incentive payment report but which
generated figures or amounts reflected
on a CR incentive payment report. We
proposed calculation of CR incentive
payment amounts would need to be first
adjudicated by the calculation error
process as previously detailed. If a FFS–
CR participant wants to engage in the
dispute resolution process with regard
to the calculation of a CR incentive
payment amount, we proposed it would
first need to submit a calculation error
form. Where the FFS–CR participant
does not timely submit a calculation
error form, we proposed the dispute
resolution process would not be
available to the FFS–CR participant
with regard to the CR incentive payment
report for that CR performance year.
If the FFS–CR participant did timely
submit a calculation error form and the
FFS–CR participant is dissatisfied with
CMS’ response to the FFS–CR
participant’s notice of calculation error,
the FFS–CR participant would be
permitted to request reconsideration
review by a CMS reconsideration
official. The reconsideration review
request would be submitted in a form
and manner and to an individual or
office specified by CMS. The
reconsideration review request would
provide a detailed explanation of the
basis for the dispute and include
supporting documentation for the FFS–
CR participant’s assertion that CMS or
its representatives did not accurately
calculate CR incentive payment in
accordance with CR incentive payment
model rules.
Where the matter is unrelated to
payment, such as termination from the
CR incentive payment model, the FFS–
CR participant need not submit a
calculation error form. We proposed to
require the FFS–CR participant to
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timely submit a request for
reconsideration review, in a form and
manner to be determined by CMS.
Where such request is timely received,
we proposed CMS would process the
request as discussed later in this
section.
We proposed that the reconsideration
review would be an on-the-record
review (a review of briefs and evidence
only). The CMS reconsideration official
would make reasonable efforts to notify
the FFS–CR participant in writing
within 15 calendar days of receiving the
FFS–CR participant’s reconsideration
review request of the date and time of
the review, the issues in dispute, the
review procedures, and the procedures
(including format and deadlines) for
submission of evidence (the
‘‘Scheduling Notice’’). The CMS
reconsideration official would make
reasonable efforts to schedule the view
to occur no later than 30 days after the
date of the Scheduling Notice. The
provisions at § 425.804(b), (c), and (e)
(as in effect on the publication date of
this final rule) would apply to reviews
conducted pursuant to the
reconsideration review process for the
CR incentive payment model. The CMS
reconsideration official would make
reasonable efforts to issue a written
determination within 30 days of the
review. The determination would be
final and binding.
In summary, we proposed the
following requirements in § 512.720 (b)
for the reconsideration process:
• If the FFS–CR participant is
dissatisfied with CMS’ response to the
notice of a calculation error, the FFS–CR
participant may request a
reconsideration review in a form and
manner as specified by CMS.
• The reconsideration request must
provide a detailed explanation of the
basis for the dispute and include
supporting documentation for the FFS–
CR participant’s assertion that CMS or
its representatives did not accurately
calculate the CR incentive payment in
accordance with subpart H of this part.
• If CMS does not receive a request
for reconsideration from the FFS–CR
participant within 10 calendar days of
the issue date of CMS’ response to the
FFS–CR participant’s notice of
calculation error, then CMS’ response to
the calculation error is deemed final and
CMS proceeds with the applicable
processes, as described in subpart H of
this part.
• The CMS reconsideration official
notifies the FFS–CR participant in
writing within 15 calendar days of
receiving the FFS–CR participant’s
review request of the following:
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++ The date, time, and location of the
review.
++ The issues in dispute.
++ The review procedures.
++ The procedures (including format
and deadlines) for submission of
evidence. The CMS reconsideration
official takes all reasonable efforts to
schedule the review to occur no later
than 30 days after the date of receipt of
notification.
• The provisions at § 425.804(b), (c),
and (e) of this chapter are applicable to
reviews conducted in accordance with
the reconsideration review process for
the FFS–CR participant.
• The CMS reconsideration official
issues a written determination within 30
days of the review. The determination is
final and binding.
• Only a FFS–CR participant may
utilize the dispute resolution process
described in this subpart. We sought
comment on the proposed
reconsideration process for the CR
incentive payment model.
Final Decision: We did not receive
any comments on this section.
Therefore, we are finalizing the proposal
without modification.
d. Exception to the Notice of Calculation
Error Process and Notice of Termination
If the FFS–CR participant contests a
matter that does not involve an issue
contained in, or a calculation which
contributes to a CR incentive payment
report, a notice of calculation error is
not required. In instances where a
notice of calculation error is not
required, for example a FFS–CR
participant’s termination from the CR
incentive payment model, we proposed
the FFS–CR participant provide a
written notice to CMS requesting review
within 10 calendar days of the notice.
CMS has 30 days to respond to the FFS–
CR participant’s request for review. If
the FFS–CR participant fails to notify
CMS, the decision is deemed final.
In summary, we proposed the
following requirements in § 512.720 (c)
for an exception to the notice of
calculation error process:
• If the FFS–CR participant contests a
matter that does not involve an issue
contained in, or a calculation which
contributes to a CR incentive payment
report a notice of calculation error is not
required. In these instances, if CMS
does not receive a request for
reconsideration from the FFS–CR
participant within 10 calendar days of
the notice of the initial determination,
the initial determination is deemed final
and CMS proceeds with the action
indicated in the initial determination.
This does not apply to the limitations
on review in sub-paragraph (e).
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In summary, we proposed the
following requirements in § 512.720 (d)
for notice of termination:
• If an FFS–CR participant receives
notification that it has been terminated
from the CR incentive payment model,
it must provide a written request for
reconsideration to CMS requesting
review of the termination within 10
calendar days of the notice. CMS has 30
days to respond to the FFS–CR
participant’s request for review. If the
FFS–CR participant fails to notify CMS,
the termination is deemed final.
We sought comment on the proposed
exception to the process and notice of
termination.
Final Decision: CMS did not receive
any comments on this section.
Therefore, we are finalizing the proposal
without modification.
e. Limitations on Review
In summary, we proposed the
following requirements in § 512.720(e)
for limitations on review:
• In accordance with section
1115A(d)(2) of the Act, there is no
administrative or judicial review under
sections 1869 or 1878 of the Act or
otherwise for the following:
++ The selection of models for testing
or expansion under section 1115A of the
Act.
++ The selection of organizations,
sites, or participants to test those
models selected.
++ The elements, parameters, scope,
and duration of such models for testing
or dissemination.
++ Determinations regarding budget
neutrality under section 1115A(b)(3) of
Act.
++ The termination or modification
of the design and implementation of a
model under section 1115A(b)(3)(B) of
Act.
++ Decisions to expand the duration
and scope of a model under section
1115A(c) of the Act, including the
determination that a model is not
expected to meet criteria described in
paragraph (e)(1) or (2) of this section.
We sought comment on the proposed
limitations on review.
The proposals for the appeals process
for FFS–CR participants are included in
§ 512.720. We sought comment on our
proposals for the appeals process as it
related to FFS–CR participants. The
two-step appeal process for payment
matters—(1) calculation error form, and
(2) reconsideration review—is used
broadly in other CMS models. We
sought comment on whether we should
develop an alternative appeal process.
In addition, we sought comment on
whether additional or different
safeguards would be needed to ensure
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program integrity, protect against abuse,
and ensure that the goals of the CR
incentive payment model are met.
Final Decision: CMS did not receive
any comments on this section.
Therefore, we are finalizing the proposal
without modification.
3. Data Sharing for FFS–CR Participants
a. Overview
Section III.K. of the proposed rule (81
FR 50945 through 50948) discussed our
proposed policies for the types and
formats of financial data that we would
make available to EPM participants, the
frequency with which we would make
these data available, and the authority
for making these data available to EPM
participants. Specifically, in section
III.K.2. of the proposed rule (81 FR
50946), we proposed to provide certain
financial data in two formats. First, we
proposed to make summary beneficiary
claims data reports on beneficiaries’ use
of health care services during the
baseline and performance periods upon
request and in accordance with
applicable privacy and security laws
and established privacy and security
protections. These data would consist of
summary claims data reports that would
contain payment information such as
episode counts, total average spending
for each episode, based upon categories,
including, inpatient services, outpatient
services, skilled nursing facility
services, and carrier/Part B services.
Alternatively, for EPM participants with
the capacity to analyze raw claims data,
we proposed to make more detailed
beneficiary-level information available
upon request and in accordance with
applicable privacy and security laws
and established privacy and security
protections. In addition to these more
detailed data, we proposed to include
episode summaries, indicators for
excluded episodes, diagnosis and
procedure codes, and enrollment and
dual eligibility information for
beneficiaries that initiate EPM episodes.
In section III.K.2. of the proposed rule
(81 FR 50945 through 50947), we also
noted our view that making this
information available to EPM
participants would provide the
participants with tools to monitor,
understand, and manage utilization and
expenditure patterns as well as to
develop, target, and implement quality
improvement programs and initiatives.
In addition to the aforementioned
data, we proposed in section III.K.3. of
the proposed rule (81 FR 50945) to
provide comparable aggregate regional
data to EPM participants. Our proposal
to make these regional data available
was based on our proposal to use
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585
regional pricing data to determine
benchmark and quality-adjusted target
prices for EPM participants, and these
aggregate regional data would assist
participants in better understanding the
basis of these prices. In section III.K.4.
of the proposed rule (81 FR 50946), we
proposed to make 3 years of baseline
data available to EPM participants prior
to the models’ start date, which we
believe would help the participants
assess their practice patterns, identify
cost drivers, and ultimately redesign
their care practices to improve
efficiency and quality. In section III.K.5.
of the proposed rule (81 FR 50946), we
proposed to provide to EPM
participants, upon request and in
accordance with the HIPAA Privacy
Rule, up to 6 quarters of claims data as
frequently as on a quarterly basis
throughout the EPM participant’s
participation or until they notify CMS
that they no longer wish to receive these
data.
As we stated in section III.K.6 of the
proposed rule (81 FR 50946 through
50947), we believe our proposals are
consistent with and authorized under
the HIPAA Privacy Rule under the
provisions that permit disclosures of
PHI for ‘‘health care operations’’
purposes. Under those provisions, a
covered entity is permitted to disclose
PHI to another covered entity for the
recipient’s health care operations
purposes if both covered entities have or
had a relationship with the subject of
the PHI to be disclosed, the PHI pertains
to that relationship, and the recipient
would use the PHI for a ‘‘health care
operations’’ function that falls within
the first two paragraphs of the definition
of ‘‘health care operations’’ in the
HIPAA Privacy Rule (45 CFR
164.506(c)(4)). The first paragraph of the
definition of health care operations
includes ‘‘conducting quality
assessment and improvement activities,
including outcomes evaluation and
development of clinical guidelines,’’
and ‘‘population-based activities
relating to improving health or reducing
health costs, protocol development, case
management and care coordination’’ (45
CFR 164.501). As we stated in section
III.K.6. of the proposed rule (81 FR
50944 through 50945), EPM participants
would be using the data on their
patients to evaluate the performance of
the participant hospital and other
providers and suppliers that furnished
services to the patient, conduct quality
assessment and improvement activities,
and conduct population-based activities
relating to improved health for their
patients. When done by or on behalf of
a covered entity, these are covered
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functions and activities that would
qualify as ‘‘health care operations’’
under the first and second paragraphs of
the definition of health care operations
at 45 CFR 164.501. Hence, we noted our
view that this provision covers the uses
we would expect under the proposed
EPMs. We also noted our view that, in
proposing to make available the
‘‘minimum necessary’’ data to
accomplish the intended purpose of the
use, our proposal was consistent with
45 CFR 164.502(b). Last, we stated our
belief that our proposed data disclosures
are consistent with the purpose for
which the data discussed in the
proposed rule was collected and may be
disclosed in accordance with the
routine uses exception to the Privacy
Act, which would otherwise prohibit
disclosure of information from a system
of records to any third party without the
prior written consent of the individual
to whom the records apply (5 U.S.C.
552a(b)). For a more detailed discussion
of our proposals and authority for
sharing data with EPM participants,
please see section III.K. of this final rule.
b. Data Sharing With CR Participants
As is the case with the proposed
EPMs, we believe that making certain
beneficiary-identifiable claims
information available, upon request and
in accordance with applicable privacy
and security laws and established
privacy and security protections, is
necessary for CR participants to best
improve their performance with respect
to increasing utilization of CR/ICR
services, which we believe should result
in improved health care outcomes and
reduced health care costs. However, we
believe that a more limited set of data
would be needed for purposes of testing
the CR incentive payment model than
would be made available under the
proposed EPMs. This is because the
purposes and processes related to the
proposed CR incentive payment model
are narrower in focus than under the
proposed EPMs where hospitals must
coordinate care across a broader array of
providers and services to improve
health care quality across a broader
range of dimensions. Also, unlike the
EPMs where a participant’s performance
each performance year is compared
against historical spending, the CR
incentive payments are based only on a
CR participant’s CR/ICR service
utilization performance within a given
CR performance year. Further, CR
incentive payments are tied only to the
CR participant’s performance and are
unrelated to performance within a
region.
Thus, upon request and in accordance
with applicable privacy and security
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laws and established privacy and
security protections, we proposed to
make the following data available to
FFS–CR participants:
• Inpatient claims—containing
potential admissions for CABG and AMI
MS–DRGs (and PCI DRGs with an AMI
ICD–CM diagnosis code in the principal
or any secondary diagnosis code
position).
• Carrier and Outpatient claims—
containing CR/ICR services that
occurred in the 90- day period after
discharge (called the AMI care period or
CABG care period).
We would note that our proposal
pertains only to FFS–CR participants
and not to EPM–CR participants. This is
because an EPM–CR participant that has
requested data under the EPM would
already have had the data previously
described made available to them under
their broader data sharing request. As
such, we believe that also making these
data separately available to EPM–CR
participants would be duplicative and
could create confusion for participants.
We also note that we did not propose to
make historical payment or aggregate
regional payment data available to FFS–
CR participants. This is because, as
previously discussed, neither historical
nor regional CR/ICR service utilization
performance would be factors
considered when determining their
eligibility for or the amount of a CR
incentive payment.
As is the case for our proposed data
sharing with EPM participants, we
proposed to make these data available in
either summary or claims-level format,
depending on the FFS–CR participant’s
request. Also, we proposed to make
these data available consistent with the
same schedule we proposed to use for
making data available to EPM
participants and to make available up to
6 quarters of claims data as frequently
as on a quarterly basis throughout the
FFS–CR participant’s participation or
until they notify CMS that they no
longer wish to receive these data. As is
the case with the EPMs, we proposed
that the data files would be packaged
and sent to a data portal (to which the
FFS–CR participants must request and
be granted access) in a ‘‘flat’’ or binary
format for the FFS–CR participant to
retrieve.
The proposal to share data with FFS–
CR participants is included in § 512.725.
We sought comments on our data
sharing proposals.
The following is a summary of the
comments received and our responses.
Comment: Commenters were
supportive of CMS’ efforts to provide
beneficiary-level and summary claims
data available to selected FFS hospitals
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selected for the CR incentive payment
model upon request. Commenters also
were supportive of our proposal to make
this data available as frequently as
monthly, and encouraged us to follow a
monthly data release schedule for FFS–
CR participants as soon as the EPMs are
implemented, instead of sending the
FFS–CR data quarterly since more
frequent data updates would be useful
in managing care under EPMs.
Response: We appreciate these
comments and realize that more
frequent data releases will assist many
hospitals that are selected for the CR
incentive payment model in
understanding care patterns and
identifying opportunities for improved
efficiencies in care delivery.
Accordingly, we are modifying our
proposal to make these data available on
a quarterly basis to make these data
available ‘‘no less frequently’’ than on a
quarterly basis with the goal of making
these data available on a monthly basis
as soon as we have the operational
capabilities needed for monthly
distribution.
Final Decision: After consideration of
the public comments we received, we
are modifying our proposal at
§ 512.725(b)(2) to no longer limit the
availability of updated CR data to a
frequency ‘‘as frequently as on a
quarterly basis throughout the FFS–CR
participant’s participation’’ to instead
‘‘no less frequently than on a quarterly
basis throughout the FFS–CR
participant’s participation’’ with the
goal of making these data available as
frequently as on a monthly basis if
practicable.
4. Compliance Enforcement for FFS–CR
Participants and Termination of the CR
Incentive Payment Model
In section III.F. (81 FR 50911 through
50914) of the proposed rule, we discuss
our proposals for compliance
enforcement under the EPM. The
proposal outlines the non-compliance
by EPM participants, including EPM–CR
participants with respect to the EPMs
and CR incentive payment model, if the
latter is applicable to the EPM
participant that may trigger compliance
enforcement by CMS and the
enforcement mechanisms available to
CMS. Four out of the seven remedial
actions, specifically issuing a warning
letter to the EPM participant, requiring
the EPM participant to develop a
corrective action plan, commonly
referred to as a CAP, reducing or
eliminating the EPM participant’s CR
incentive payment, and terminating the
EPM participant from the CR incentive
payment model, are relevant to the CR
incentive payment model. Thus, we
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proposed to establish compliance
enforcement for the CR incentive
payment model for FFS–CR participants
that is substantively similar to the
requirements as we proposed for the
EPM but that the CMS enforcement
mechanisms may use with FFS–CR
participants be the four remedial actions
previously listed in this section. All
other types of enforcement mechanisms
under the EPMs, specifically, reducing
or eliminating the EPM participant’s
reconciliation payment, requiring the
EPM participant to terminate a sharing
arrangement with an EPM collaborator
and prohibiting the EPM collaborator
from further engagement in sharing
arrangements with the EPM participant,
and allowing CMS to add 25 percent to
a repayment amount on an EPM
participant’s reconciliation report under
certain circumstances, are not relevant
to the CR incentive payment model for
any FFS–CR participants because the CR
incentive payment model includes no
policies that relate directly to these
categories of activity.
Another distinction between the
policies proposed under the EPMs and
the CR incentive payment model is
regarding prevention of EPM–CR
participants from avoiding the high cost
and high severity patients and targeting
low cost and low severity patients.
Under the EPMs, we prohibit EPM
participants from avoiding both
potentially high cost or high severity
patients and targeting both potentially
low cost or low severity patients. Under
the CR incentive payment model we are
only concerned with FFS–CR
participants avoiding high severity
patients and targeting low severity
patients. The goal of EPMs is to
maintain or improve quality and
coordination of care while reducing
program expenditures. In contrast, the
goals of the CR incentive payment
model are to reduce cardiovascular
mortality, improve health-related
quality of life, and reduce the risk of
hospital admission. The EPMs explicit
prohibition of avoiding high cost and
targeting low cost patients is not
included for the FFS–CR participants as
cost savings are not a goal for
participants under the CR incentive
payment model.
We proposed that CMS would have
the remedial actions detailed in this
section available for use against FFS–CR
participants where such FFS–CR
participant furnishing CR services to a
beneficiary during the CR incentive
payment model is not compliant in a
matter listed in § 512.730(b)(1). These
mechanisms would support CMS’ goal
for the CR incentive payment model to
prevent overutilization of CR services
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that are not medically necessary,
prevent FFS–CR participants from
avoiding high severity patients and
seeking out low severity patients,
safeguard program integrity, protect
against fraud and abuse, and deter
noncompliance with CR incentive
payment model requirements.
Upon discovering an instance of
noncompliance by a FFS–CR participant
with the requirements of the CR
incentive payment model, CMS, HHS,
or a designee of such Agencies may take
remedial action against such FFS–CR
participant. Any information collected
by CMS in relation to termination of a
participant from the model would be
shared with our program-integrity
colleagues at HHS, the Department of
Justice, and their respective designees.
Should such participant, or one of its
EPM collaborators, collaboration agents,
or downstream collaboration agents, be
noncompliant with the requirements of
the EPMs or engage in unlawful
behavior related to participation in the
EPMs, we note that such information
could be used in proceedings unrelated
to the enforcement mechanisms in this
section. FFS–CR participants also would
be subject to all applicable requirements
and conditions for Medicare
participation not otherwise waived
under section 1115A(d)(1) of the Act.
In summary, we proposed in
§ 512.730 that FFS–CR participants
must comply with all requirements
outlined in subpart H. Except as
specifically noted subpart H, the
regulations under this part must not be
construed to affect the payment,
coverage, program integrity, or other
requirements (such as those in parts 412
and 482 of this chapter) that apply to
providers and suppliers under this
chapter.
Further, we proposed in § 512.730
that CMS may take the remedial actions
later discussed in this section, if a FFS–
CR participant—
• Fails to comply with any
requirements of this subpart or is
identified as noncompliant through
monitoring by HHS (including CMS and
OIG) of the CR incentive payment
model, including but not limited to—
++ Avoiding potentially high-severity
patients;
++ Targeting potentially low-severity
patients;
++ Failing to provide medically
appropriate services or systematically
engaging in the over or under-delivery
of appropriate care;
++ Failing to provide beneficiaries
with complete and accurate
information; or
• Takes any action that threatens the
health or safety of patients;
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587
• Avoids at risk Medicare
beneficiaries, as this term is defined in
§ 425.20 of this chapter;
• Avoids patients on the basis of
payer status;
• Is subject to sanctions or final
actions of an accrediting organization or
federal, state, or local government
agency that could lead to the inability
to comply with the requirements of this
subpart;
• Takes any action that CMS
determines for program integrity reasons
is not in the best interests of the CR
incentive payment model, or fails to
take any action that CMS determines for
program integrity reasons should have
been taken to further the best interests
of the CR incentive payment model;
• Is subject to action by HHS
(including OIG and CMS) or the
Department of Justice to redress an
allegation of fraud or significant
misconduct, including intervening in a
False Claims Act qui tam matter, issuing
a pre demand or demand letter under a
civil sanction authority, or similar
actions; or
• Is subject to action involving
violations of the physician self-referral
law, civil monetary penalties law,
federal anti-kickback statute, antitrust
laws, or any other applicable Medicare
laws, rules, or regulations that are
relevant to the CR incentive payment
model.
We proposed the remedial actions to
include the following:
• Issuing a warning letter to the FFS–
CR participant.
• Requiring the FFS–CR participant
to develop a corrective action plan,
commonly referred to as a CAP.
• Reducing or eliminating the FFS–
CR participant’s CR incentive payment.
• Terminating the FFS–CR
participant from the CR incentive
payment model.
The proposals for compliance
enforcement for FFS–CR participants
are included in § 512.730. We sought
comment on our proposals for
compliance enforcement as it is related
to FFS–CR participants. In addition, we
sought comment on whether additional
or different safeguards would be needed
to ensure program integrity, protect
against abuse, and ensure that the goals
of the CR incentive payment model are
met.
We further proposed under § 512.905,
CMS may terminate the CR incentive
payment model for reasons including
but not limited to—
• CMS no longer has the funds to
support the CR incentive payment
model; or
• CMS terminates the applicable
model in accordance with section
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1115A(b)(3)(B) of the Act. As provided
by section 1115A(d)(2) of the Act,
termination of the model is not subject
to administrative or judicial review.
Final Decision: We did not receive
any comments on this section.
Therefore, we are finalizing the proposal
without modification.
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5. Enforcement Authority for FFS–CR
Participants
OIG authority is not limited or
restricted by the provisions of the CR
incentive payment model, including the
authority to audit, evaluate, investigate,
or inspect the FFS–CR participants.
Additionally, no CR incentive payment
model provisions limit or restrict the
authority of any other Government
Agency to do the same.
The proposals for enforcement
authority for FFS–CR participants in the
CR incentive payment model were
included in proposed § 512.735. We
sought comment about all of the
requirements set out in the preceding
discussion, including whether
additional or different safeguards would
be needed to ensure program integrity,
protect against abuse, and ensure that
the goals of the CR incentive payment
model are met.
We received no comments on the
proposals for enforcement authority for
FFS–CR participants in the CR incentive
payment model.
Final Decision: We are finalizing the
proposals in § 512.735 for the
enforcement authority for FFS–CR
participants, without modification. In
the final provisions:
• OIG authority is not limited or
restricted by the provisions of the CR
incentive payment model, including the
authority to audit, evaluate, investigate,
or inspect the FFS–CR participant, or
any other person or entity or their
records, data, or information, without
limitation.
• None of the provisions of the CR
incentive payment model limits or
restricts the authority of any other
government agency permitted by law to
audit, evaluate, investigate, or inspect
the FFS–CR participant or any other
person or entity or their records, data,
or information, without limitation.
6. Beneficiary Engagement Incentives
for FFS–CR Participants
We proposed to allow EPM
participants to provide beneficiary
engagement incentives under certain
conditions as discussed in section III.I.9.
of the proposed rule (81 FR 50929
through 50931) based on the goals of the
EPM to improve EPM episode quality
and efficiency. The goals of the CR
incentive payment model in which
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some EPM participants would also
participate are to increase CR/ICR
service care coordination and the
medically necessary utilization of CR/
ICR services in AMI and CABG model
episodes for EPM–CR participants and
in AMI care periods and CABG care
periods for FFS–CR participants. In the
proposed rule, we discussed our belief
that one mechanism that may be useful
to CR participants in achieving this goal
would be the provision of transportation
to CR/ICR services as in-kind patient
engagement incentives to AMI and
CABG model beneficiaries and
beneficiaries in AMI care periods and
CABG care periods (hereinafter FFS–CR
beneficiaries). As discussed earlier in
this section, lack of accessibility of CR
program sites can be a significant barrier
to beneficiary adherence to a CR
treatment plan. We did not believe there
were beneficiary engagement incentives
other than transportation that would be
important for achieving the CR
incentive payment model goals of
increasing CR/ICR service care
coordination and the medically
necessary utilization of CR/ICR services.
However, we believed that EPM–CR and
FFS–CR participants should generally
have the same regulatory flexibilities
that are directly relevant to advancing
the CR incentive payment model goals
so that we could evaluate the CR
incentive payment model under the two
different underlying payment
methodologies for AMI and CABG care
(episode or FFS) and draw conclusions
about the relationship between the CR
incentive payment model and the
underlying payment methodology for
care.
Under the proposed beneficiary
engagement incentive policies for the
EPM, EPM–CR participants would be
able to provide beneficiary
transportation to CR/ICR services in
order to achieve the clinical goal of the
EPM of beneficiary adherence to a care
plan, subject to certain conditions on
these incentives that are necessary to
ensure that their provision is solely for
the purpose of achieving the EPM goals
of improvements in episode quality and
efficiency. When transportation is
provided by an EPM–CR participant as
a beneficiary engagement incentive for
CR/ICR services, its use would also be
aligned with the CR incentive payment
model goals of increasing CR/ICR
service care coordination and the
medically necessary utilization of CR/
ICR services. Thus, our proposal for
beneficiary engagement incentives
under the EPM met the potential need
for transportation to CR/ICR services for
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AMI and CABG model beneficiaries
under an EPM–CR participant.
We proposed to allow FFS–CR
participants to provide transportation to
CR/ICR services as a beneficiary
engagement incentive for FFS–CR
beneficiaries during AMI care periods
and CABG care periods to allow these
participants similar use of beneficiary
engagement incentives to achieve the
CR incentive payment model goals as
would be available to EPM–CR
participants for that purpose. We
proposed the same conditions on
beneficiary engagement incentives
provided by FFS–CR participants as
would be applicable to EPM beneficiary
engagement incentives when those
beneficiary incentives are
transportation.
The proposed conditions for
transportation when provided as a
beneficiary engagement incentive by
FFS–CR participants were—
• The incentive must be provided
directly by the FFS–CR participant or by
an agent of the FFS–CR participant
under the FFS–CR participant’s
direction and control to the FFS–CR
beneficiary during an AMI care period
or CABG care period;
• Transportation must not be tied to
the receipt of items or services other
than CR/ICR services during AMI care
periods or CABG care periods;
• Transportation must not be tied to
the receipt of items or services from a
particular provider or supplier;
• The availability of transportation
must not be advertised or promoted
except that a beneficiary may be made
aware of the availability of
transportation at the time the
beneficiary could reasonably benefit
from it;
• The cost of transportation must not
be shifted to another federal health care
program, as defined at section 1128B(f)
of the Act.
In addition, as we would apply to
transportation as a beneficiary
engagement incentive under the EPMs,
we proposed the same documentation
requirements for beneficiary
engagement incentives provided by
FFS–CR participants;
• FFS–CR participants must maintain
documentation of transportation
furnished as a beneficiary engagement
incentive that exceeds $25 in retail
value;
• The documentation established
contemporaneously with the provision
of transportation must include at least
the following:
++ The date the transportation is
provided.
++ The identity of the beneficiary to
whom the transportation was provided.
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• The FFS–CR participant must retain
and provide access to the required
documentation in accordance with
§ 512.715.
Our proposals for beneficiary
engagement incentives provided by
FFS–CR participants were included in
proposed § 512.740. We sought
comment on our proposed provisions
for beneficiary engagement incentives
for FFS–CR participants and welcomed
comment on additional or alternative
program integrity safeguards. We also
sought comment about beneficiary
engagement incentives other than
transportation that could advance the
CR incentive payment model goals of
increased CR/ICR service care
coordination and the medically
necessary utilization of CR/ICR services
in AMI care periods and CABG care
periods.
The following is a summary of the
comments received and our responses.
Comment: Multiple commenters
claimed that a significant barrier to CR/
ICR program participation is beneficiary
cost-sharing due to the high cumulative
costs associated with completion of
multi-session CR/ICR treatment,
although the evidence is largely
anecdotal. A commenter referenced a
recent study that found that in a
multiracial population, low
socioeconomic status, lack of insurance
and copayment were independent risk
factors of poor adherence to CR after
adjusting for race. They stated that
additional research in this area would
be helpful in addressing cost as a barrier
to participation in CR/ICR services. The
commenters urged CMS to lower or
eliminate beneficiary copayments under
the CR incentive payment model. A
commenter suggested that a tieredcopayment structure could be applied
that would provide successive
reductions in copayments the longer the
beneficiary remains in the program. In
this example, the first six sessions
would be a full copayment, followed by
a percentage reduction for the next six
and an additional percentage reduction
for the remaining sessions. Another
commenter requested that CMS allow
CR incentive payment model
participants to use the CR incentive
payment to decrease the cumulative
copayment for CR services and claims
that this would assist in increasing the
utilization of CR/ICR services.
Response: We appreciate the interest
of the commenters in additional
strategies that could assist in beneficiary
adherence to the recommended CR/ICR
treatment plan for those who are
included in the CR/ICR incentive
payment model. We note that most
beneficiaries in traditional Medicare
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have supplemental coverage,
specifically employer-sponsored,
Medicaid, and Medigap in descending
order of prevalence.177 In 2011, only 19
percent of beneficiaries in traditional
Medicare did not have supplemental
coverage. Thus, while we recognize that
without supplemental coverage the
cumulative copayments associated with
multiple sessions of CR/ICR services
could be significant and discourage
beneficiary participation, most of the
beneficiaries in the CR/ICR incentive
payment model would not experience
significant out-of-pocket costs for the
services themselves because their
supplemental coverage would help to
cover those costs. Thus, we do not
believe it is necessary to lower or
eliminate beneficiary copayments in
order to test the CR incentive payment
model under Medicare FFS, and we
have concerns that such provisions
could result in program integrity issues
such as patient steering toward a
particular provider.
Comment: A number of commenters
expressed support for CMS’ proposal to
allow transportation to be provided as a
beneficiary engagement incentive under
the CR incentive payment model by
FFS–CR participants. The commenters
agreed that transportation is a
fundamental beneficiary engagement
incentive that will increase access to
CR/ICR services by removing barriers to
enrollment and attendance. Several
commenters requested clarification
about whether specific types of support
would qualify as transportation under
the proposed beneficiary engagement
incentives policy, including parking
fees, rebates, or waivers; taxi services;
gasoline for mileage traveled to CR/ICR
services; a gas card; and public
transportation card. With regard to the
specific types of potential transportation
support listed, a commenter urged CMS
to clarify that FFS–CR participants have
flexibility in how they offer the benefit.
Another commenter recommended that
CMS allow a higher amount of
transportation incentives for
beneficiaries residing in rural MSAs for
whom accessibility of the CR/ICR
program is a greater challenge. A
commenter who favored allowing FFS–
CR participants greater flexibility
beyond transportation to provide
beneficiary engagement incentives
nevertheless requested that should CMS
not create parity in the beneficiary
engagement incentives that can be
offered by EPM–CR and FFS–CR
participants, CMS should revise the
177 The Henry J. Kaiser Family Foundation. An
Overview of Medicare. April 1, 2016. https://kff.org/
medicare/issue-brief/an-overview-of-medicare.
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proposal to clarify that transportation
both to and from CR/ICR services would
be permitted. Finally, the same
commenter requested that CMS clarify
the requirement that transportation
must not be tied to the receipt of items
or services from a particular provider or
supplier other than the FFS–CR
participant. As proposed, the
commenter believes a FFS–CR
participant would be prohibited from
furnishing transportation to its site in
order for a Medicare beneficiary to
receive CR or ICR services from that
FFS–CR participant.
While many commenters expressed
appreciation for CMS’ proposal to allow
FFS–CR participants to offer
transportation as a beneficiary
engagement incentive, the commenters
urged CMS to broaden the types of
beneficiary engagement incentives that
can be provided by FFS–CR participants
to model beneficiaries beyond
transportation. A commenter pointed
out that the proposal would allow EPM–
CR participants to provide the broader
set of beneficiary engagement incentives
available under the EPM to EPM–CR
beneficiaries, allowing EPM–CR
participants the flexibility to choose the
most appropriate incentives, as long as
the requirements for providing them
under the EPM are met. The commenter
reiterated CMS’ stated intent in the
proposed rule to create parity between
EPM–CR and FFS–CR participants
regarding the available regulatory
flexibilities directly relevant to
advancing the CR incentive payment
model goals and disagreed that CMS’
proposal for beneficiary engagement
incentives that could be offered by FFS–
CR participants would meet that
objective. The commenter urged CMS to
apply the EPM beneficiary engagement
incentive provisions to both EPM–CR
and FFS–CR participants. The
commenter reasoned that doing so
would enable all CR participants to
develop innovative methods of
increasing beneficiary utilization of CR/
ICR programs and improving beneficiary
adherence to CR/ICR program regimens.
The commenter further acknowledged
that even if in practice the vast majority
of CR/ICR programs ultimately relied
exclusively on providing transportation
as a beneficiary engagement incentive,
CMS would nevertheless have created
the opportunity for both EPM–CR and
FFS–CR participants to explore
alternatives.
Other commenters provided specific
examples of items and services that
could be provided as beneficiary
engagement incentives that would assist
in increasing CR/ICR program
enrollment and adherence to the CR/ICR
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treatment plan, including mobile
applications for phones to text health
messages between sessions; activity
devices to track calories and steps; and
evidence-based support/counseling
weight management services or
programs. A commenter asserted that
these items and services would be
allowed as beneficiary engagement
incentives in the EPM and have been
shown to improve adherence and foster
self-management behaviors in the CR
setting. Several commenters
recommended that CR participants be
able to offer financial incentives to
model beneficiaries, such as a per
session payment of $10 to $20 if the
beneficiary completes the treatment
program; payment by the CR participant
to rebate part of the beneficiary’s
copayment to reward adherence; or a
financial incentive that offers assistance
to accommodate work or child/elder
care obligations while the beneficiary
attends CR/ICR sessions. Other
commenters suggested that beneficiary
engagement incentives could include
vouchers for continued enrollment in
exercise programs; gym memberships;
diet and nutrition services and tobacco
cessation services; and a preventive
cardiology visit for review and
reassessment of patient-centric goals.
Another commenter requested
clarification about regarding beneficiary
engagement incentives can be used to
assist with incorporating technology
platforms needed to operate home-based
cardiac rehabilitation.
Response: We appreciate the support
of the commenters for our proposal to
allow FFS–CR participants to provide
transportation as a beneficiary
engagement incentive to FFS–CR
beneficiaries and the robust information
provided by the commenters about other
beneficiary engagement incentives that
could help FFS–CR participants to
advance the goals of the CR incentive
payment model of increasing CR/ICR
service care coordination and the
medically necessary utilization of CR/
ICR services for beneficiaries following
hospitalization for AMI or CABG. As we
stated in the proposed rule (81 FR
50897), we believe that EPM–CR and
FFS–CR participants should generally
have the same regulatory flexibilities
that are directly relevant to advancing
the CR incentive payment model goals
so that we can evaluate the CR incentive
payment model under the two different
underlying payment methodologies for
AMI and CABG care (episode or FFS)
and draw conclusions about the
relationship between the CR incentive
payment model and the underlying
payment methodology for care. While
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undoubtedly transportation has the
potential to be an important beneficiary
engagement incentive for FFS–CR
beneficiaries to enhance their adherence
to the CR/ICR treatment plan, we
believe that our proposal for FFS–CR
beneficiary engagement incentives was
too narrow and would not have allowed
FFS–CR participants sufficient
flexibility to provide other beneficiary
engagement incentives to help advance
the goals of the model, while EPM–CR
participants may be able to provide
those incentives based on their
participation in the EPM, as discussed
in section III.I.9. of this final rule.
Therefore, we will adopt beneficiary
engagement incentive requirements for
FFS–CR participants that are modeled
closely after those we are finalizing for
the EPMs to address the interests of the
commenters in providing a broader
array of beneficiary incentives under the
CR incentive payment model and
aligning the requirements for EPM–CR
and FFS–CR participants who want to
furnish beneficiary incentives to EPM–
CR and FFS–CR beneficiaries. We
sought comment on the proposal for
beneficiary engagement incentives in
the EPMs and respond to those
comments in section III.I.9. of this final
rule.
We note that under the EPMs, the
item or service provided as a beneficiary
engagement incentive must be a
preventive care item or service or an
item or service that advances a clinical
goal for a beneficiary in an EPM
episode, where the goals are—
• Beneficiary adherence to drug
regimens;
• Beneficiary adherence to care plan;
• Reduction of readmissions and
complications resulting from treatment
for the EPM clinical condition; and
• Management of chronic disease and
conditions that may be affected by
treatment for the EPM clinical
condition.
FFS–CR participants are responsible
for increasing CR/ICR service care
coordination and the medically
necessary utilization of CR/ICR services
for beneficiaries following
hospitalization for AMI or CABG. The
AMI and CABG models both focus on
beneficiaries with the same clinical
conditions as the CR incentive payment
model. The CR incentive payment
model’s ultimate goal is improving
beneficiary health and reducing the cost
of health care. Increased utilization of
CR/ICR services for beneficiaries
following AMI and CABG is known to
contribute to that ultimate goal based on
the components of the CR/ICR program,
and the utilization of CR/ICR services
for which the model will make a CR
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incentive payment is only an interim
process measure that has an association
with the longer-term outcomes we are
seeking to achieve.
Section 410.49(b)(2) defines the
components of a cardiac rehabilitation
and an intensive cardiac rehabilitation
program as:
• Physician-prescribed exercise each
day cardiac rehabilitation items and
services are furnished;
• Cardiac risk factor modification,
including education, counseling, and
behavioral intervention, tailored to the
patients’ individual needs;
• Psychosocial assessment;
• Outcomes assessment; and
• An individualized treatment plan
detailing how components are utilized
for each patient.
Therefore, we believe that the clinical
goals of the CR model for the purpose
of FFS–CR participants providing
beneficiary engagement incentives can
be appropriately identified as the same
as those of the EPMs, related to
improving beneficiary adherence to
recommended treatments and
improving beneficiary health. We will
identify the same clinical goals for
beneficiary engagement incentives that
may be provided by FFS–CR
participants as for the EPMs, noting that
some contribute to the immediate CR
incentive payment model objective of
increasing CR/ICR service utilization
(for example, beneficiary adherence to a
care plan) and others to the longer-term
improvement of beneficiary health that
is expected to result from increased
utilization of CR/ICR services (for
example, management of chronic
disease and conditions that may be
affected by treatment for AMI or CABG).
The final regulations for the
beneficiary engagement incentive
payments that may be provided by FFS–
CR participants are parallel to the final
regulations for beneficiary engagement
incentives under the EPMs, with the
exception of the conforming changes
that are necessary due to FFS–CR
participant participation in the CR
incentive payment model, rather than
an EPM; the specific clinical conditions
of AMI and CABG that are included in
the CR incentive payment model; and
use of the terms AMI care period and
CABG care period rather than EPM
episode to define the duration of time
during which the beneficiary
engagement incentive can be provided
by the FFS–CR participant.
We note that, like the EPMs, the FFS–
CR participant beneficiary engagement
incentive requirements allow the
provision of items and services as inkind patient engagement incentives but
do not allow FFS–CR participants to pay
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money to FFS–CR participants for any
purpose, including completion of the
treatment program or as a rebate of CR
copayments. While we can understand
the potential benefit of such payments
in engaging FFS–CR beneficiaries to
advance the goals of the CR incentive
payment model by financially
rewarding their participation in CR/ICR
services, we do not believe that we
could include provide sufficient
safeguards against patient steering if we
were to permit such payments as
beneficiary engagement incentives.
With regard to the commenters
requesting specific clarification about
transportation incentives, the final
beneficiary engagement incentives
requirement for FFS–CR participant use
no longer are specific to transportation.
Therefore, we encourage those
commenters to review the final
requirements and ensure that all
beneficiary engagement incentives,
including transportation, provided by
FFS–CR participants to FFS–CR
beneficiaries meet the requirements. We
note that the final requirements include
that the item or service must not be tied
to the receipt of items or services from
a particular provider or supplier so that
a FFS–CR participant who offers
transportation as a beneficiary
engagement incentive to CR/ICR
services furnished by the FFS–CR
participant would need to make
comparable transportation support
available for CR/ICR services furnished
by another provider so that the
availability of transportation would not
be used to steer the beneficiary to a
particular CR/ICR service provider.
Regarding the request by a commenter
for clarification about whether
beneficiary engagement incentives can
be used to assist with incorporating
technology platforms needed to operate
home-based cardiac rehabilitation, we
note that Medicare does not cover
home-based CR. Any home-based CR
activities could not be billed to
Medicare and would not contribute to
the FFS–CR participant’s CR incentive
payment.178 In addition, technology
platforms provided as a beneficiary
engagement incentive by a FFS–CR
participant would need to meet all the
requirements specified in this final rule
for beneficiary engagement incentives
for FFS–CR participant use.
We are finalizing in the proposals in
§ 512.740 beneficiary engagement
incentives to be provided by FFS–CR
participants, with modification to our
178 Medicare Claims Processing Manual. Chapter
32—Billing Requirements for Special Services.
Section 140.2—Cardiac Rehabilitation Program
Services Furnished On or After January 1, 2010.
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proposals for comparability to EPM
beneficiary engagement incentives.
Pursuant to section 1115A(d)(1) of the
Act, the Secretary will consider whether
waivers of certain fraud and abuse laws
are necessary to test the CR incentive
payment model in FFS–CR participants.
Such waivers would be promulgated
separately from this final regulation by
OIG (as to sections 1128A and 1128B of
the Act) and CMS (as to section 1877 of
the Act), to which the respective
authorities have been delegated. Any
fraud and abuse waivers issued in
connection with the FFS–CR beneficiary
engagement incentives model will be
available at https://www.cms.gov/
Medicare/Fraud-and-Abuse/
PhysicianSelfReferral/Fraud-andAbuse-Waivers.html and on OIG’s Web
site. No waivers of any fraud and abuse
authorities are being issued in this final
rule.
Comment: A commenter requested
clarification about what considerations
could be given for beneficiary adherence
to a CR/ICR treatment plan when the
most convenient CR program is a rural
CAH and the CR participant’s location
where their CR program resides is
beyond a reasonable distance from the
beneficiary’s home. The commenter
recommended that CR participants be
permitted to extend transportation
beneficiary engagement incentives to
model beneficiaries who are receiving
CR from rural non-CR participants due
to a distance barrier in order for
transportation cost barriers to CR service
adherence to be reduced for rural
beneficiaries as it is for beneficiaries
receiving CR at the CR participant.
Other commenters who requested that
CMS broaden the beneficiary
engagement incentives permitted for
FFS–CR participants requested
clarification about whether these
incentives could still be provided if a
FFS–CR beneficiary was referred to a CR
program at a location other than at the
FFS–CR participant.
Response: We appreciate the
opportunity to clarify the beneficiary
engagement incentive policies for CR
participants whose model beneficiaries
obtain CR/ICR services at different
locations. Under our policies that apply
to CR participants, beneficiary
engagement incentives must be
provided directly by the EPM–CR or
FFS–CR participant or by an agent of the
EPM–CR or FFS–CR participant under
the EPM or FFS–CR participant’s
direction and control to the EPM–CR or
FFS–CR beneficiary during an AMI
episode or AMI care period,
respectively, or during a CABG episode
or CABG care period. Therefore, while
we limit who may provide the
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591
beneficiary engagement incentives to a
model beneficiary to safeguard against
patient steering to any particular
provider, transportation to CR/ICR
services or other items and services
provided as in-kind patient engagement
incentive may be provided by the FFS–
CR participant to the model beneficiary,
regardless of where the beneficiary
receives CR/ICR services. Therefore, in
the example raised by the commenter,
the CR participant where the beneficiary
was hospitalized for AMI or CABG that
initiated the AMI episode or AMI care
period would be permitted to provide
transportation to CR services at the CAH
near the beneficiary’s home as an inkind patient engagement incentive,
subject to all the other requirements for
beneficiary engagement incentives for
EPM or FFS–CR participants, as
applicable to the specific CR
participant, being met. In this scenario,
we note that the CR incentive payment
for CR/ICR services utilized by the
beneficiary would be made to the CR
participant, not the CAH, although the
CAH would be paid for all CR services
furnished to the beneficiary under the
applicable Medicare FFS payment
system.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposals in § 512.740 for
beneficiary engagement incentives
provided by FFS–CR participants, with
modification to allow beneficiary
engagement incentives that are subject
to the same overall requirements as the
EPM but as applicable to AMI care
periods and CABG care periods under
the CR incentive payment model.
Beneficiary engagement incentives
provided by FFS–CR participants must
meet the following requirements:
FFS–CR participants may choose to
provide in-kind patient engagement
incentives to beneficiaries in an AMI
care period or CABG care period under
the CR incentive payment model,
subject to the following conditions:
• The incentive must be provided
directly by the FFS–CR participant or by
an agent of the FFS–CR participant
under the FFS–CR participant’s
direction and control to the FFS–CR
beneficiary during an AMI care period
or CABG care period.
• The item or service provided must
be reasonably connected to medical care
provided to an FFS–CR beneficiary
during an AMI care period or CABG
care period.
• The item or service must be a
preventive care item or service or an
item or service that advances a clinical
goal, as listed later in this section, for a
beneficiary during an AMI care period
or CABG care by engaging the
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beneficiary in better managing his or her
own health.
• The item or service must not be tied
to the receipt of items or services
outside the AMI care periods or CABG
care periods.
• The item or service must not be tied
to the receipt of items or services from
a particular provider or supplier.
• The availability of items or services
must not be advertised or promoted
except that a beneficiary may be made
aware of the availability of items or
services at the time the beneficiary
could reasonably benefit from them.
• The cost of the item or service must
not be shifted to another federal health
care program, as defined at section
1128B(f) of the Act.
Beneficiary engagement incentives
involving technology are subject to the
following additional conditions:
• Items or services involving
technology provided to a beneficiary
may not exceed $1,000 in retail value
for any one beneficiary in any one AMI
care period or CABG care period.
• Items or services involving
technology provided to a beneficiary
must be the minimum necessary to
advance a clinical goal, as listed in
paragraph (c) of this section, for a
beneficiary in an AMI care period or
CABG care period.
• Items of technology exceeding $100
in retail value must—
++ Remain the property of the FFS–
CR participant; and
++ Be retrieved from the beneficiary
at the end of the AMI care period or
CABG care period. The FFS–CR
participant must document all retrieval
attempts, including the ultimate date of
retrieval. Documented, diligent, good
faith attempts to retrieve items of
technology will be deemed to meet the
retrieval requirement.
The following are the clinical goals of
the CR incentive payment model, which
may be advanced through beneficiary
incentives:
• Beneficiary adherence to drug
regimens.
• Beneficiary adherence to a care
plan.
• Reduction of readmissions and
complications resulting from treatment
for AMI or CABG.
• Management of chronic diseases
and conditions that may be affected by
treatment for AMI or CABG.
Documentation of beneficiary
engagement incentives:
• FFS–CR participants must maintain
documentation of items and services
furnished as a beneficiary engagement
incentive that exceeds $25 in retail
value.
• The documentation established
contemporaneously with the provision
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of the items and services must include
at least the following:
++ The date the incentive is
provided.
++ The identity of the beneficiary to
whom the item or service was provided.
• The documentation regarding items
of technology exceeding $100 in retail
must also include contemporaneous
documentation of any attempt to
retrieve technology at the end of an AMI
care period or CABG care period as
described previously in this section.
• The FFS–CR participant must retain
and provide access to the required
documentation in accordance with
§ 512.715.
7. Waiver of Physician Definition for
FFS–CR Participants Furnishing CR and
ICR Services
a. Overview of Program Rule Waivers
Under an EPM
In section III.J. of this final rule, we
finalized the waivers of certain program
rules that we believe offers providers
and suppliers more flexibility so that
they may increase coordination of care
and management of beneficiaries in
EPM episodes. The purpose of such
flexibilities is to increase EPM episode
quality and decrease episode spending
or internal costs or both of providers
and suppliers that results in better, more
coordinated care for beneficiaries and
improved financial efficiencies for
Medicare, providers, and beneficiaries.
These additional flexibilities are
implemented through our waiver
authority under section 1115A of the
Act, which affords broad authority for
the Secretary to waive statutory
Medicare program requirements as
necessary to carry out the provisions of
section 1115A. We have used this
authority to implement similar program
rule waivers in other models, such as
the CJR model, as discussed in section
III.J. of this final rule.
b. General Physician Requirements for
Furnishing CR and ICR Services
A cardiac rehabilitation (CR) program,
as defined in § 410.49(a) of regulations,
means a physician-supervised program
that furnishes physician prescribed
exercise, cardiac risk factor
modification, psychosocial assessment,
and outcomes assessment. An intensive
cardiac rehabilitation (ICR) program, as
defined in § 410.49(a) of the regulations,
means a physician-supervised program
that furnishes cardiac rehabilitation and
has shown, in peer-reviewed published
research, that it improves patients’
cardiovascular disease through specific
outcome measurements described in
§ 410.49(c). A physician is defined
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under § 410.49(a), and under
§ 1861(r)(1) of the Act as a doctor of
medicine or osteopathy.
In general, the following physician
functions are required under § 410.49 in
furnishing CR/ICR services;
• Medical director—defined at
§ 410.49(a) as a physician that oversees
or supervises the cardiac rehabilitation
or intensive rehabilitation program at a
particular site;
• Supervising physician—defined at
§ 410.49(a) as a physician that is
immediately available and accessible for
medical consultations and medical
emergencies at all times items and
services are being furnished to
individuals under cardiac rehabilitation
and intensive cardiac rehabilitation
programs;
• Physician-prescribed exercise—
defined at § 410.49(a) as aerobic exercise
combined with other types of exercise
(that is, strengthening, stretching) as
determined to be appropriate for
individual patients by a physician; and
• Establish, review, and sign an
individualized treatment plan every 30
days, as described at § 410.49(b)(2)(v).
c. Waiver of Physician Definition for
EPM–CR Participants Furnishing CR
and ICR Services
In section III.J.8. of this final rule, for
cardiac rehabilitation and intensive
cardiac rehabilitation services provided
in an EPM–CR participant under the
proposed AMI and CABG models, we
are waiving the physician definition,
under § 410.49, to allow a physician or
a qualified nonphysician practitioner to
perform the functions of supervising
physician, prescribing exercise, and
establishing, reviewing, and signing an
individualized treatment plan every 30
days. A nonphysician practitioner, for
the purposes of the EPM–CR waiver is
defined as a physician assistant, nurse
practitioner, or clinical nurse specialist
as authorized under sections
1861(s)(2)(K)(i) and (ii) of the Act and
defined in section 1861(aa)(5) of the
Act, or in §§ 410.74, 410.75, and 410.76
of the regulations. We are implementing
the EPM–CR waiver to provide greater
program flexibility that might increase
the availability of CR and ICR services
to AMI and CABG model beneficiaries.
This waiver is codified at § 512.630 in
this final rule.
d. Waiver of Physician Definition for
FFS–CR Participants Furnishing CR and
ICR Services
Services provided under CR and ICR
programs may be furnished to those
beneficiaries in a FFS–CR participant
hospital eligible to receive a CR
incentive payment. To provide greater
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program flexibility that might increase
the availability of CR and ICR services
to beneficiaries in a FFS–CR participant
hospital, we proposed to provide a
waiver to the definition of a physician
to include a nonphysician practitioner
(defined for the purposes of this waiver
as a physician assistant, nurse
practitioner, or clinical nurse specialist
as authorized under sections
1861(s)(2)(K)(i) and (ii) of the Act and
defined in section 1861(aa)(5) of the
Act, or in §§ 410.74, 410.75, and 410.76
of the regulations). Thus, this proposed
waiver for FFS–CR participants would
allow, in addition to a physician, a
nonphysician practitioner to perform
the functions of supervisory physician,
prescribing exercise, and establishing,
reviewing, and signing an
individualized treatment plan in
furnishing CR and ICR services under
§ 410.49. This proposed waiver for FFS–
CR participants is similar to the
physician definition waiver for EPM–CR
participants discussed in section III.J.8.
of this final rule. All other definitions
and requirements related to a physician
or supervising physician under § 410.49
continue to apply. This proposed waiver
of the physician definition would be
terminated if the FFS–CR participant is
terminated or is not in compliance with
the CR incentive payment requirements.
This proposed waiver for FFS–CR
participants was codified at proposed
§ 512.745. We sought comments on this
proposed CR/ICR waiver to allow
nonphysician practitioners to perform
the specified physician functions for the
provision of CR/ICR services in a FFS–
CR participant.
We received a number of comments
on our proposals to provide a CR/ICR
waiver to the physician definition that
applied to both the EPM–CR
participants and FFS–CR participants,
and no comments were unique to the
FFS–CR participants. We refer to section
III.J.8. of this final rule for a summary
of the comments and our responses.
Final Decision: After consideration of
the public comments received, we are
finalizing the proposal, without
modification to allow, in addition to a
physician, a nonphysician practitioner
to perform the functions of supervisory
physician, prescribing exercise, and
establishing, reviewing, and signing an
individualized treatment plan in
furnishing CR and ICR services under
§ 410.49. This waiver for FFS–CR
participants is similar to the physician
definition waiver for EPM–CR
participants discussed in section III.J.8.
of this final rule. All other definitions
and requirements related to a physician
or supervising physician under § 410.49
continue to apply. This waiver of the
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physician definition would be
terminated if the FFS–CR participant is
terminated or is not in compliance with
the CR incentive payment model. This
waiver for FFS–CR participants is
codified at § 512.745 in this final rule.
G. Considerations Regarding Financial
Arrangements Under the CR Incentive
Payment Model
As discussed in section VI.E.2. of the
proposed rule (81 FR 50981), we
proposed to not permit the inclusion of
CR incentive payments in sharing
arrangements for EPM participants
specified in proposed § 512.500.
Similarly, we did not propose to allow
specific financial arrangements for FFS–
CR participants. Thus, financial
arrangements regarding CR incentive
payments paid by CMS to CR
participants would be subject to all
existing laws and regulations, including
all fraud and abuse laws and applicable
CR payment and coverage requirements.
Given that more than 95 percent of CR/
ICR services were historically furnished
by hospital outpatient departments
(HOPDs) to beneficiaries in the 90 days
following discharge from a
hospitalization for AMI or CABG, in the
proposed rule we described our
expectation that in many cases the CR
participant that would be accountable
under the CR incentive payment model
would itself carry out the model
implementation activities, including
coordination of CR/ICR services to CR
beneficiaries, through the hospital’s
own CR program.179 However, in other
cases, depending on beneficiary choices
and the availability of CR/ICR services
and expertise in a CR participant’s local
community, CR participants might wish
to engage other individuals and entities,
including individuals and entities that
are not providers and suppliers, in order
to advance the CR incentive payment
model goals of increased CR/ICR service
care coordination and the medically
necessary utilization of CR/ICR services
in AMI and CABG model episodes and
AMI care periods and CABG care
periods. Thus, we expected that all
financial relationships with other
individuals and entities under the CR
incentive payment model would be
narrowly focused on certain activities
related to the CR participant’s specific
plan to advance the goals of model.
For example, we expected that CR
participants may choose to engage with
providers, suppliers, and other
179 Analysis of cardiac rehabilitation utilization in
care periods for AMI and CABG beneficiaries
initiated by all U.S. IPPS hospitals not in Maryland
and constructed using standardized Medicare FFS
Parts A and B claims, as proposed in this rule that
began in CYs 2012 through 2014.
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593
organizations that are neither providers
nor suppliers to assist with matters such
as CR/ICR service utilization data
analysis; beneficiary outreach; CR
beneficiary care coordination and
management for CR/ICR service referral
and adherence to a treatment plan; CR
participant compliance with the terms
and conditions of the CR incentive
payment model; or other model
activities. These individuals and entities
might play important roles in a CR
participant’s plans to implement the CR
incentive payment model based on their
direct clinical care for beneficiaries in
AMI or CABG model episodes or AMI
care periods or CABG care periods; their
prior experience with cardiovascular
risk-factor reduction and management
initiatives; their care coordination
expertise; or their familiarity with the
local community and access to
resources that may reduce barriers to
beneficiary utilization of CR/ICR
services. We expected that all
relationships established between CR
participants and other individuals and
entities for such purposes of the CR
incentive payment model would only be
those permitted under existing law and
regulation. We would also expect that
all of these relationships would solely
be based on the level of engagement of
the individual’s or entity’s resources to
directly support the CR participant’s CR
incentive payment model
implementation.
We recognized in the proposed rule,
however, that we do not have precedent
with other CMS models and programs
that have a similar design to the CR
incentive payment model. Thus, we
sought comment on whether there are
other types of financial arrangements
that CR participants would wish to
pursue in advancing the model goals of
increased CR/ICR service care
coordination and the medically
necessary utilization of CR/ICR services
in AMI and CABG model episodes and
AMI care periods and CABG care
periods. We specifically requested
comments on which individuals and
entities would be parties to the financial
arrangements; what specific CR
incentive payment model
implementation activities would be
included in the financial arrangements;
and what methodologies would be used
for sharing the CR incentive payment
under such financial arrangements. In
addition, we sought comment on what
safeguards would be needed to ensure
program integrity, protect against abuse,
and ensure that the goals of the CR
incentive payment model would be met.
Based on comments and our early
implementation experience with the CR
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incentive payment model, we noted that
we may make specific proposals around
CR incentive payment model financial
arrangements in future rulemaking.
The following is a summary of the
comments received and our responses.
Comment: Several commenters urged
CMS to allow CR participants to share
CR incentive payments with other
providers under the CR incentive
payment model to assist CR participants
in meeting the model goals of increasing
CR/ICR service care coordination and
the medically necessary utilization of
CR/ICR services for beneficiaries
following hospitalization for AMI or
CABG. Without sharing arrangements
that are not permissible under existing
fraud and abuse laws, the commenters
believe the model goals may be
challenging to achieve while retaining
beneficiary freedom of choice of CR/ICR
service provider, especially in some
geographic areas of the country. In one
example provided by a commenter, a
tertiary referral center could receive
patients for CABG or treatment of AMI
from distant hospitals with more limited
cardiac capacity. While the tertiary
referral center would be the EPM–CR or
FFS–CR participant in the CR incentive
payment model, the beneficiary would
commonly return home to their
community for CR/ICR services. The
commenter claimed that the opportunity
for the tertiary referral center to share
some of the CR incentive payment with
the referring community hospital to
augment the available resources of the
local CR/ICR program to facilitate
service availability and beneficiary
adherence to the CR/ICR treatment plan
would be valuable. Some commenters
expressed concern that without
permitting sharing arrangements of the
CR incentive payment between the CR
participant and other providers of CR/
ICR services, the CR incentive payment
model would not incentivize adherence
to CR/ICR programs at rural hospitals,
CAHs, and any other CR program that is
not a CR participant. The commenters
believe that beneficiaries should have
the choice to select where they receive
CR/ICR services, and encouraged CMS
to design the model such that it
supports and incentivizes this choice. In
general, a number of commenters urged
CMS to adopt flexibility in the financial
arrangements permitted under the CR
incentive payment model, which they
believe would lead to broader
utilization of CR/ICR services.
Response: We appreciate the
information provided by the
commenters about the potential benefits
of certain financial arrangements under
the CR incentive payment model. In
response to the commenters who
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expressed concerns about beneficiary
freedom of choice of CR/ICR provider
under the CR incentive payment model,
we do not agree that the absence of
specific financial arrangements being
permitted under the model is a risk to
beneficiary freedom of choice or results
in the model not incentivizing CR/ICR
treatment plan adherence at any CR
provider that is not a CR participant.
The CR participant will receive a CR
incentive payment based on the totality
of CR/ICR services furnished to
beneficiaries in AMI and CABG
episodes or AMI care periods and CABG
care periods, regardless of where the
beneficiary receives CR/ICR services.
Therefore, the model provides a
financial incentive to CR participants to
coordinate CR/ICR services with any
CR/ICR program selected by the
beneficiary, although as we noted in the
proposed rule (81 FR 50989),
historically that CR program has been
most commonly that of the discharging
hospital who would be the CR
participant. We also expect that CR
participants will support the
beneficiary’s choice of CR/ICR provider
that is most likely to result in greater
beneficiary adherence to the CR/ICR
treatment plan, and that the choice of a
local CR/ICR provider would often be of
mutual benefit to the beneficiary and CR
participant by increasing the likelihood
that the beneficiary will receive more
CR/ICR services than at a remote CR
program. While we appreciate the
interest of some commenters in sharing
the CR incentive payment with other
providers, our model design generally
relies on the CR participant who is
accountable under the CR incentive
payment model itself carrying out the
model implementation activities,
including coordination of CR/ICR
services to CR beneficiaries. To the
extent CR participants may wish to
engage other individuals and entities to
advance the CR incentive payment
model goals of increased CR/ICR service
care coordination and the medically
necessary utilization of CR/ICR services,
we expect that financial relationships
with these individuals and entities will
be narrowly focused on certain activities
related to the CR participant’s specific
plan to advance the goals of the model.
We also expect that all of these
relationships will solely be based on the
level of engagement of the individual’s
or entity’s resource to directly support
the CR participant’s CR incentive
payment model implementation.
We made no proposals for financial
arrangements under the CR incentive
payment model. As we stated in the
proposed rule (81 FR 50989), based on
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the comments on this rulemaking and
our early implementation experience
with the CR incentive payment model,
we may make specific proposals around
CR incentive payment model financial
arrangements in future rulemaking. We
especially need to consider the
safeguards that would be needed for
such financial arrangements to ensure
program integrity, protect against abuse,
and ensure that the goals of the CR
incentive payment model would be met,
because we do not have precedent with
other CMS models and programs that
have a similar design to the CR
incentive payment model. Thus, we
expect that all relationships established
between CR participants and other
individuals and entities for purposes of
the CR incentive payment model will
only be those permitted under existing
law and regulation.
Final Decision: We made no specific
proposals for financial arrangements
under the CR incentive payment model
that would allow CR participants to
enter into financial arrangements with
other individuals and entities to share
CR incentive payments, beyond
relationships permitted under existing
law and regulation. We will consider
the information provided by the
commenters and our early experience
with implementation of the model and
we make proposals about financial
arrangements in future rulemaking.
VII. Collection of Information
Requirements
As stated in section1115A(d)(3) of the
Act, Chapter 35 of title 44, United States
Code, shall not apply to the testing and
evaluation of models under section
1115A of the Act. As a result, the
information collection requirements
contained in this final rule need not be
reviewed by the Office of Management
and Budget. However, we have
summarized the anticipated information
collection requirements in the
Regulatory Impact Analysis.
VIII. Regulatory Impact Analysis
We have examined the impact of this
rule as required by Executive Order
12866 and other laws and Executive
Orders requiring economic analysis of
the effects of final rules.
A. Statement of Need
1. Need for EPM Final Rule
This final rule is necessary in order to
implement and test three new EPMs
under the authority of section 1115A of
the Act, which allows the Innovation
Center to test innovative payment and
service delivery models in order to
‘‘reduce program expenditures while
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preserving or enhancing the quality of
care furnished to individuals.’’ Under
the FFS program, Medicare makes
separate payments to providers and
suppliers for the items and services
furnished to a beneficiary over the
course of treatment (an episode of care).
With the amount of payments
dependent on the volume of services
delivered, providers may not have
incentives to invest in qualityimprovement and care-coordination
activities. As a result, care may be
fragmented, unnecessary, or duplicative.
The goal for the EPMs we are finalizing
in this rule is to improve the quality of
care provided to beneficiaries in an
applicable episode while reducing
episode spending through financial
accountability.
Payment approaches that reward
providers for assuming financial and
performance accountability for a
particular episode of care can create
incentives for the implementation and
coordination of care redesign between
participants and other providers and
suppliers such as physicians and postacute care providers. Under the EPMs
we are finalizing in this rule, CMS will
test whether an EPM for AMI, CABG,
and SHFFT episodes of care will reduce
Medicare expenditures while preserving
or enhancing the quality of care for
Medicare beneficiaries. We believe the
EPM models have the potential to
benefit Medicare beneficiaries by
improving the coordination and
transition of care, improving the
coordination of items and services paid
for through FFS Medicare, encouraging
more provider investment in
infrastructure and redesigned care
processes for higher-quality and more
efficient service delivery, and
incentivizing higher-value care across
the inpatient and post-acute care
spectrum. The goal for the EPMs we are
finalizing in this rule is to improve the
quality of care provided to beneficiaries
in an applicable episode while reducing
episode spending.
The AMI, CABG, and SHFFT models
require the participation of hospitals in
multiple geographic areas that might not
otherwise participate in testing episode
payment for the EPM episodes of care.
CMS is testing other episode payment
models with the BPCI initiative and the
CJR model. The BPCI initiative is
voluntary; risk-bearing organizations
applied to participate and chose from 48
clinical episodes. In the CJR model,
acute care hospitals in selected
geographic areas are required to
participate in the CJR model for all
eligible LEJR episodes that initiate at a
CJR model participant hospital.
Realizing the full potential of the new
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EPMs requires the engagement of an
even broader set of providers than have
participated to date in our episode
payment models such as the BPCI
initiative and the CJR model. As such,
we will test and evaluate the impact of
episode payment for three EPMs (AMI,
CABG, and SHFFT models) in a variety
of circumstances, including those
hospitals that may not otherwise
participate in such a test.
2. Need for CJR Modifications
This final rule also includes
modifications to the CJR model. Acute
care hospitals in selected geographic
areas are required to participate in the
CJR model for LEJR episodes that
initiate at a CJR model participant
hospital. The modifications finalized in
this rule clarify and update provisions
of the CJR model and create alignment
between CJR and the AMI, CABG, and
SHFFT models. The primary impact of
these changes are: (1) Incorporation of
BPCI and CJR reconciliation payments
and Medicare repayments in setting
quality-adjusted target prices in
performance years 3–5; and (2) updates
to the calculation of composite quality
scores.
3. Need for CR Incentive Payment
Model
CR and intensive CR services are
capable of achieving significant
improvements in patient outcomes
beyond the AMI and CABG model 90day post-discharge care period. Despite
evidence from multiple studies that CR
services improve health outcomes, these
services remain underutilized.
Beneficiaries with CAD often receive
care in many different settings from
multiple providers over the long-term
and subsequently commonly experience
care that is fragmented and
uncoordinated. Lack of coordination, of
both care and financial incentives,
across the continuum of CAD care,
results in higher than necessary rates of
adverse drug events, hospital
readmissions, diagnostic errors, and
other adverse outcomes, as well as
lower than appropriate utilization of
evidence-based treatments. The CR
incentive payment model will test
whether a financial incentive for
hospitals that encourages the
management of beneficiaries that have
had an AMI or a CABG in ways that may
contribute to long-term improvements
in quality and reductions in Medicare
spending.
4. Aggregate Impact of EPMs, CJR, and
CR Incentive Payment Model
As detailed in Table 57, we estimate
a total aggregate impact of $159 million
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595
in net Medicare savings over the
duration of the AMI, CABG, and SHFFT
models, July 2017 through December
2021. As detailed in Table 59, we
estimate the changes in the CJR model
finalized in this final rule, along with
the revised assumption about the
percentage of participating hospitals
that will report voluntary quality data
during the performance years, will
lower the net Medicare savings by $26
million over the duration of the CJR
model (April 2016 through December
2020) relative to the financial estimate
published in the CJR final rule (80 FR
73288). These estimated impacts
represent the net effect of federal
transfers that incent hospitals for
improving care while making it more
efficient. Furthermore, the AMI, CABG,
and SHFFT models may benefit
beneficiaries since the models require
participants to be accountable for
episodes extending 90 days posthospital discharge, which may
potentially improve the coordination of
FFS items and services, and encourage
investment in infrastructure and
redesigned care processes for high
quality and efficient service delivery
that demonstrate a dedication and focus
toward patient-centered care. Although
it is possible that participants may
respond to the model test through
improvements in the efficiency of care
that reduce FFS Medicare spending
during these episodes, such reductions
in Medicare spending will be largely
offset through greater reconciliation
payments paid by the Medicare program
to the participating hospital. As long as
reductions in Medicare FFS spending
for participating hospitals are equally
offset through greater reconciliation
payments from the Medicare program to
those participating hospitals, the
financial impact to the Medicare
program should not be significantly
different from our estimate.
As detailed in Table 60, we estimate
a total aggregate impact between $29
million in net Medicare costs and $32
million in net Medicare savings from
July 2017 through December 2024
through the cardiac rehabilitation
incentive payment model. These
estimated impacts represent the net
effect of federal transfers to CR–EPM
and CR–FFS participants and savings
related to decreased future utilization in
beneficiaries who receive CR/ICR
services. A range of potential impacts is
provided due to uncertainty in the
likely increase in CR/ICR utilization
based on the CR incentive provided.
B. Overall Impact
We have examined the impacts of this
rule as required by Executive Order
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12866 on Regulatory Planning and
Review (September 30, 1993), Executive
Order 13563 on Improving Regulation
and Regulatory Review (January 18,
2011), the Regulatory Flexibility Act
(RFA) (September 19, 1980, Pub. L. 96–
354), section 1102(b) of the Social
Security Act, section 202 of the
Unfunded Mandates Reform Act of 1995
(March 22, 1995; Pub. L. 104–4),
Executive Order 13132 on Federalism
(August 4, 1999) and the Congressional
Review Act (5 U.S.C. 804(2)).
Executive Orders 12866 and 13563
direct agencies to assess all costs and
benefits of available regulatory
alternatives and, if regulation is
necessary, to select regulatory
approaches that maximize net benefits
(including potential economic,
environmental, public health and safety
effects, distributive impacts, and
equity). Section 3(f) of Executive Order
12866 defines a ‘‘significant regulatory
action’’ as an action that is likely to
result in a rule: (1) Having an annual
effect on the economy of $100 million
or more in any 1 year, or adversely and
materially affecting a sector of the
economy, productivity, competition,
jobs, the environment, public health or
safety, or state, local or tribal
governments or communities (also
referred to as ‘‘economically
significant’’); (2) creating a serious
inconsistency or otherwise interfering
with an action taken or planned by
another agency; (3) materially altering
the budgetary impacts of entitlement
grants, user fees, or loan programs or the
rights and obligations of recipients
thereof; or (4) raising novel legal or
policy issues arising out of legal
mandates, the President’s priorities, or
the principles set forth in the Executive
Order. This final rule triggers these
criteria.
Executive Order 13132 establishes
certain requirements that an agency
must meet when it publishes a proposed
rule and subsequent final rule that
imposes substantial direct requirement
costs on state and local governments,
pre-empts state law, or otherwise has
federalism implications. We do not
believe that there is anything in this
final rule that either explicitly or
implicitly pre-empts any state law, and
furthermore we do not believe that this
final rule will have a substantial direct
effect on state or local governments,
preempt states law, or otherwise have a
federalism implication.
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C. Anticipated Effects
b. CJR
1. Overall Magnitude of the Model and
Its Effects on the Market
The overall magnitude of the CJR
model is described in the CJR final rule
(80 FR 73288). The modifications
finalized in this rule are not related to
episode definition or hospital selection
and therefore do not affect the number
of episodes included in the model or the
mean episode payment. The primary
impact of the changes we finalized
relate to the calculation of qualityadjusted target prices, which will now
incorporate reconciliation payments and
Medicare repayments in years 3 through
5 of the model and include
modifications to the calculation of
composite quality scores. For the CJR
final rule we assumed that hospitals
would not report voluntary THA/TKA
patient-reported outcome-based data to
CMS. Given our experience with
performance year 1 of CJR, we revised
our assumption for this analysis to
assume that 27 percent of participants
in performance years 1 and 2, 63
percent of participants in performance
year 3, and 99 percent of participants in
performance years 4 and 5 will report
this quality data. These modifications
along with the revised assumptions
regarding quality reporting raise the
costs estimated to the Medicare program
by $26 million from the estimate of $343
million in savings as published in the
CJR final rule (80 FR 73288).
a. EPMs
Nationally, the total number of
historical episodes ending in CY 2014
that began with IPPS hospitalizations
and extended 90 days post-hospital
discharge were approximately 168,000
for AMI; 48,000 for CABG; and 109,000
for SHFFT. The total Medicare spending
for these historical episodes was
approximately $4.1 billion, $2.3 billion,
and $4.7 billion, respectively. Based on
analysis of Medicare claims for
historical episodes in 2012–2014, the
mean estimated total payment for AMI
episodes (defined based on ICD–CM
diagnosis code and DRGs as described
in section III.C of this final rule) is about
$24,000, where approximately 61
percent of the spending is attributable to
hospital inpatient services, 18 percent is
attributable to post-acute care services
and 21 percent to physician, outpatient
hospital and other spending. For CABG
episodes (defined based on DRGs as
described in section III.C. of this final
rule) the mean estimated total payment
is about $47,000, where approximately
68 percent of the spending is
attributable to hospital inpatient
services, 12 percent is attributable to
post-acute care services and 20 percent
to physician, outpatient hospital and
other spending. For SHFFT episodes
(defined based on DRGs as described in
section III.C. of this final rule) the mean
estimated total payment is about
$43,000, where approximately 33
percent of the spending is attributable to
hospital inpatient services, 50 percent is
attributable to post-acute care services
and 17 percent to physician, outpatient
hospital and other spending.
We finalized our proposal to test the
AMI and CABG models in 98 MSAs out
of 293 MSAs (we proposed to use 294
MSAs, however, due to the Vermont All
Payer model being exempted from the
final EPMs as discussed in section
III.B.2 of this final rule, the number of
eligible MSAs dropped to 293) eligible
for selection, as described in section
III.B.5. of this final rule; we finalized
our proposal to test the SHFFT model in
67 MSAs in which CJR is currently
operating as discussed in section III.B.4.
of this final rule. In the 2014 calendar
year there were 136,000 episodes for
AMI, and 42,000 for CABG in the 294
MSAs proposed as eligible for selection,
and 33,000 episodes for SHFFT in the
67 MSAs eligible for participation.
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c. CR Incentive Payment Model
We finalized our proposal to test the
CR incentive payment model in 45 of
the 98 MSAs selected for the AMI and
CABG EPMs, as well as 45 FFS MSAs
selected through stratified random
sampling, as described in section VI of
this final rule. As discussed
subsequently in this analysis and
displayed in Table 60, this is likely to
result in an impact between $29 million
in net Medicare costs and $32 million
in net Medicare savings from July 2017
through December 2024.
d. Aggregate Effects on the Market
There may also be spillover effects in
the non-Medicare market, or even in the
Medicare market in other areas as a
result of the EPM and CR models.
Changes in Medicare payment policy
often have substantial implications for
non-Medicare payers. As an example,
non-Medicare patients may benefit if
participating EPM hospitals introduce
system wide changes that improve the
coordination and quality of health care.
Other payers may also be developing
episode payment models and may align
their payment structures with the EPM
and CR models or may utilize results
from CMS evaluations of these models.
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Because it is unclear whether and how
spillover effects may apply to a test of
a new payment model (as opposed to a
change in permanent policy), our
analyses assume that spillovers effects
on non-Medicare payers will not occur,
although this assumption is subject to
considerable uncertainty.
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2. Effects on the Medicare Program
a. EPMs
Under this final rule, we will test
whether an EPM for AMI, CABG, and
SHFFT episodes of care will reduce
Medicare expenditures while preserving
or enhancing the quality of care for
Medicare beneficiaries. Payment
approaches that reward providers for
assuming financial and performance
accountability for a particular episode of
care can potentially create incentives for
the implementation and coordination of
care redesign between participants and
other providers and suppliers such as
physicians and post-acute care
providers. The EPMs could enable
hospitals to consider the most
appropriate strategies for care redesign,
including—(1) increasing posthospitalization follow-up and medical
management for patients; (2)
coordinating across the inpatient and
post-acute care spectrum; (3) conducting
appropriate discharge planning; (4)
improving adherence to treatment or
drug regimens; (5) reducing
readmissions and complications during
the post-discharge period; (6) managing
chronic diseases and conditions that
may be related to the proposed EPM
episodes; (7) choosing the most
appropriate post-acute care setting; and
(8) coordinating between providers and
suppliers such as hospitals, physicians,
and post-acute care providers.
We will test and evaluate the impact
of episode payment for the AMI, CABG,
and SHFFT models in a variety of
circumstances, including those
hospitals that may not otherwise
participate in such a test. The clinical
circumstances of these episodes differ in
important ways from the LEJR episodes
included in the CJR model. We expect
the patient population included in these
episodes would be substantially
different from the patient population in
CJR episodes, due to the clinical nature
of the cardiac and SHFFT episodes.
Beneficiaries in these episodes
commonly have chronic conditions that
contribute to the initiation of the
episodes, and need both planned and
unplanned care throughout the EPM
episode following discharge from the
initial hospitalization that begins the
episode. Both AMI and CABG model
episodes primarily include beneficiaries
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with cardiovascular disease, a chronic
condition which likely contributed to
the acute events or procedures that
initiate the episodes. About half the
average AMI model historical episode
spending was for the initial
hospitalization, with the majority of
spending following discharge from the
initial hospitalization due to hospital
readmissions, while there was relatively
less spending on SNF services, Part B
professional services, and hospital
outpatient services. In CABG model
historical episodes, about three-quarters
of episode spending was for the initial
hospitalization, with the remaining
episode spending relatively evenly
divided between Part B professional
services and hospital readmissions, and
a lesser percentage on SNF services.
Similar to AMI episodes, post-acute care
provider use was relatively uncommon
in CABG model historical episodes,
while hospital readmissions during
CABG model historical episodes were
relatively common. SHFFT model
historical episodes also were
accompanied by substantial spending
for hospital readmissions, and postacute care provider use in these
episodes also was high.180
We believe that by requiring
participation by a large number of
hospitals with diverse characteristics,
the EPMs will result in a robust data set
for evaluating this payment approach,
and will stimulate the rapid
development of new evidence-based
knowledge. Testing the EPMs in this
manner will also allow us to learn more
about patterns of inefficient utilization
of health care services and how to
possibly incentivize quality
improvement for beneficiaries receiving
services in AMI, CABG, and SHFFT
episodes.
Under the EPMs, as described further
in section III.B.2. of this final rule, an
AMI, CABG, or SHFFT model episode
would begin with an inpatient
admission assigned to one of the
following MS–DRGs upon beneficiary
discharge: For AMI episodes, AMI MS–
DRGs (280–282) and those PCI MS–
DRGs (246–251) representing IPPS
admissions for AMI that are treated with
PCIs; CABG MS–DRGs (231–236); and
SHFFT MS–DRGs (480–482). Episodes
will end 90 days after the date of
discharge from the anchor
hospitalization. The EPM episodes will
include the inpatient stays and all
related care covered under Medicare
Parts A and B within the 90 days after
180 Episodes for AMI, CABG, and SHFFT
beneficiaries initiated by all U.S. IPPS hospitals not
in Maryland and constructed using standardized
Medicare FFS Parts A and B claims, as proposed in
this rule that end in CY 2014.
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597
discharge, including hospital care, postacute care, and physician services.
Furthermore, we have designated EPM
participant hospitals to be the episode
initiators and to be financially
responsible for episode cost under the
proposed EPMs. We require all hospitals
paid under the IPPS and physically
located in selected geographic areas to
participate, with limited exceptions.
Eligible beneficiaries who receive care
at these hospitals will automatically be
included in the models. Participating
geographic areas, based on MSAs, were
selected through a random sampling
methodology. We believe the EPMs may
have financial and quality of care effects
on non-hospital providers that are
involved in the care of Medicare
beneficiaries during model episodes,
improving the coordination of items and
services paid for through Medicare FFS,
encouraging more provider investment
in infrastructure and redesigned care
processes for higher quality and more
efficient service delivery, and
incentivizing higher value across the
inpatient and post-acute care spectrum
spanning the episode of care.
As described in section III.D.3. of this
final rule, we will continue paying
hospitals and other providers and
suppliers according to the usual
Medicare FFS payment systems. After
the completion of a performance year,
the Medicare claims payments for
services furnished to the beneficiary
during the EPM episode, based on
claims data, will be combined to
calculate an actual EPM episode
payment. The actual EPM episode
payment will then be reconciled against
an established EPM quality-adjusted
target price. The amount of this
calculation, if positive, will be paid to
the participant in a reconciliation
payment. If negative, we will require
repayment from the participant
beginning in performance year 2 of the
EPMs for participants who elect early
downside risk and performance year 3
for participants who do not elect early
downside risk. EPM participants’
quality performance also will be
assessed at reconciliation; each
participant would receive a composite
quality score and a corresponding
quality category. EPM participants
achieving a quality category of
‘‘acceptable’’ or higher will be eligible
for a reconciliation payment.
We will phase in the requirement that
participants whose actual EPM episode
payments exceed the quality-adjusted
target price pay the difference back to
Medicare during performance years 2, 3
and 4 for participants who elect early
downside risk and during performance
years 3 and 4 for those who do not elect
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early downside risk. Under this final
rule, Medicare will not require
repayment from participants for
performance year 1 for actual EPM
episode payments that exceed their
quality-adjusted target price in
performance year 1, and an applicable
discount factor would be used for
calculating repayment amounts for
performance years 2, 3 and 4 for
participants who elect early downside
risk beginning January 1, 2018 and for
performance years 3 and 4 for
participants who do not elect early
downside risk.
Due to the clinical characteristics and
common patterns of care in AMI model
episodes, we will perform payment
adjustments in the cases of certain
transfers and readmissions of
beneficiaries to inpatient hospitals for
these episodes. These payment
adjustments are discussed in detail in
section III.D. of this final rule. We also
will limit how much a participant can
gain or lose based on its actual EPM
episode payments relative to qualityadjusted target prices; we are finalizing
additional policies to further limit the
risk of high payment cases for all EPM
participants and for special categories of
EPM participants as described in section
III.D. of this final rule.
Based on the mix of financial and
quality incentives, the EPMs could
result in a range of possible outcomes
for participants. The effects on hospitals
of potential savings and liabilities will
have varying degrees.
(1) Assumptions
We used standardized Medicare
claims data from January 2013 through
March 2016 to simulate the impact that
the EPMs would have on Medicare
spending for AMI, CABG, and SHFFT
model episodes. Specifically, we
applied the methodology provided in
this final rule for calculating qualityadjusted target prices. For the SHFFT
model, we applied this methodology to
hospitals in the MSAs in which CJR is
currently operating which have
historical data for SHFFT procedures.
For the AMI and CABG models, we
applied this methodology to the
hospitals in the 98 MSAs selected for
participation in the cardiac EPMs.
Quality-adjusted target prices were
calculated based on hospital
performance from 90-day episodes
starting between January 2013 and
December 2015. Specifically, all IPPS
hospitals in the selected MSAs were
included in this analysis after applying
the model-specific hospital exclusions
based on participation in BPCI Models
2 or 4 for the AMI, PCI, CABG, or
SHFFT models, as appropriate, as
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established in this final rule. Individual
episodes were removed if they initiated
a BPCI episode that had precedence
over the EPM.
We identified the anchor
hospitalization based on episode
definition criteria in section III.C. of this
final rule and included the related
spending that occurred 90 days after
discharge. We removed payments
excluded from the episode as unrelated
to the EPM episode diagnosis and
procedures based on clinical rationale,
as defined in section III.C.3.b. of this
final rule. Payments during the 90-day
episodes were calculated using
standardized Medicare payment
amounts.
We trended utilization and prices in
the prior years to match national
performance for episodes starting from
January 2015 through December 2015.
BPCI reconciliation payments were then
credited to BPCI episodes during this
time frame. We then incorporated the
final outlier policy to cap spending for
high cost outlier episodes such that
payments were capped at the price MS–
DRG anchor value that is 2 standard
deviations above the regional mean as
described in section III.D. of this final
rule.
After we pooled episodes for each
price MS–DRG, we calculated average
episode prices for each hospital and
region, as well as a hospital-specific
weight representing a case mix value for
each hospital that is dependent only on
episode volume for a given price MS–
DRG and the national anchor factor. We
then calculated blended prices for each
hospital, with prices set at two-thirds of
the hospital’s experience and one-third
of the region’s average experience for
performance years 1 and 2 of the model,
as one-third of the hospital’s experience
and two-thirds of the region’s
experience performance year 3 of the
model, and as the region’s average
experience for performance years 4 and
5 of the model. We made an exception
for hospitals with low historical episode
volume across the 3 historical years,
with low volume as defined in section
III.D.7.c. of this final rule, by setting
their episode benchmark price as the
region’s experience. These average
prices were then disaggregated based on
the national severity factor of average
episode spending as described in
section III.D. of this final rule. The
computed hospital-specific weight, the
hospital’s wage index, and a discount
specific to the hospital’s quality
category based on historical quality
performance for EPM participants was
then applied back to the price.
After calculating quality-adjusted
target prices for applicable MS–DRGs
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for each hospital for performance years
1 and 2, we compared these qualityadjusted target prices against actual
performance between January 2015 and
December 2015. We capped actual
spending for individual episodes based
on the methodology in this final rule for
high cost outlier spending episodes.
After incorporating the outlier policy,
total Medicare FFS spending was
reconciled against the quality-adjusted
target price and total number of
episodes for the hospital. The aggregate
impacts were then determined by
multiplying by the total episodes for
each price MS–DRG.
We summed the difference between
each episode’s actual payment and the
relevant quality-adjusted target price
(calculated as quality-adjusted target
price subtracted by actual episode
payment) and aggregated the difference
for all episodes for a participant within
the performance year, creating the
NPRA. Any positive NPRA amount
greater than the stop-gain limit was
capped at the stop-gain limit of 5
percent in performance years 1, 2, and
3, 10 percent in performance year 4, and
20 percent in performance year 5. In
addition, any negative NPRA amount
exceeding the stop-loss limit was
capped at the stop-loss limit as
described in section III.D. of this final
rule, with a 5 percent repayment limit
in performance year 2 (for participants
who elect early downside risk), 5
percent repayment limit in performance
year 3, 10 percent repayment limit in
performance year 4, and 20 percent
repayment limit in performance year 5.
For rural hospitals, MDHS, SCHs and
RRCs, the repayment limit was capped
at the stop-loss limit as described in
section III.A.2.a. of this final rule, with
a 3 percent repayment limit in
performance year 2 (for participants
who elect early downside risk), 3
percent repayment limit in performance
year 3, and 5 percent repayment limit in
performance years 4 and 5. As described
in section III.D.7.e. of this final rule, if
average 30-day post-episode spending
for an EPM participant in any given
EPM performance year is greater than 3
standard deviations above the regional
average 30-day post-episode spending,
based on the 30-day post-episode
spending for episodes attributed to all
regional hospitals in the same region as
the EPM participant hospital, the EPM
participant hospital must repay
Medicare for the difference. Assuming
no change in hospital behavior, very few
hospitals are expected to have average
post-episode spending exceeding 3
standard deviations from their regional
mean. Based on an analysis of 30-day
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post episode spending for EPMs starting
in the 2015 calendar year, very few
hospitals in the MSAs selected for the
EPM had average post-episode spending
exceeding 3 standard deviations. The
estimates in the impact analysis are
rounded to the nearest million, and the
estimated post-episode reconciliation
payments to be made from hospitals to
the Medicare program are minimal and
estimated to round down to 0 million.
As described in section III.E. of this
final rule, we are finalizing the use of a
composite quality score for each EPM,
where the composite quality score
reflects a combination of outcome and
patient experience measures, and, as
described later in this section, we have
incorporated this approach in our
estimate of impacts. Under the EPMs,
points for quality performance and
improvement (as applicable) will be
awarded for each episode measure and
then summed to develop a composite
quality score that will determine the
EPM participant’s quality category for
the episode. Quality performance will
make up the majority of available points
in the composite quality score, with
improvement points available as
‘‘bonus’’ points for the measure.
Additionally, participants may
voluntarily submit outcome measures
data all EPMs, resulting in an extra 2
points in their overall quality scores, up
to a maximum score of 20. The
composite quality score will be used as
part of a pay-for-performance
methodology to assign respective EPM
participants to four quality categories.
Hospitals assigned as ‘below
acceptable’ will not be eligible for a
reconciliation payment and will be
subject to a 3 percent discount.
Hospitals assigned as ‘acceptable’ will
be eligible for a reconciliation payment
and will be subject to a 3 percent
discount. Hospitals assigned as ‘good’
will be eligible for a reconciliation
payment and will be subject to a 2
percent discount. Lastly, hospitals
assigned as ‘excellent’ will be eligible
for a reconciliation payment and will be
subject to a 1.5 percent discount. We
note that for participants who elect early
downside risk, in performance years 2,
3 and 4, the applicable discount for
repayment would be 1 percentage point
less than the effective discount applied
for a reconciliation payment while for
hospitals who do not elect early
downside risk the applicable discount
for repayment in years 3 and 4 will be
1 percentage point less than the
effective discount applied for a
reconciliation payment.
In general, we used quality data as
publicly reported on Hospital Compare
in 2015 and 2016 to model the impact
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of this policy, with 2016 measures used
to calculate performance and the
difference between 2015 and 2016
measures used to calculate
improvement. As discussed in section
III.E. of this final rule, we calculated the
HLMR by using 10 of the 11 publicly
reported measures, taking the average of
all publicly reported measures except
how well hospital staff help patients
manage pain, consistent with revisions
under consideration for this HCAHPS
measure.
Specifically, we used the following
data to model the impact of this policy:
• To calculate performance for the
AMI model, we utilized: Hospital 30day, all-cause, risk-standardized
mortality rate following acute
myocardial infarction hospitalization
(NQF #0230) measure results based on
the performance period of April 1, 2012
through March 31, 2015; excess days in
acute care after hospitalization for acute
myocardial infarction measure results
based on the performance period of
April 1, 2012 through March 31, 2015;
and HCAHPS survey data (NQF #0166)
2015 based on the performance period
of January 1, 2015 through December 31,
2015.
• To calculate improvement for the
AMI model, we utilized: Hospital 30day, all-cause, risk-standardized
mortality rate following acute
myocardial infarction hospitalization
(NQF #0230) measure results based on
the performance period of April 1, 2011
through March 31, 2014; excess days in
acute care after hospitalization for acute
myocardial infarction measure results
based on the performance period of
April 1, 2011 through March 31, 2014;
and HCAHPS survey data (NQF #0166)
2015 based on the performance period
of January 1, 2014 through December 31,
2014.
• To calculate performance for the
CABG model, we utilized hospital 30day, all-cause, risk-standardized
mortality rate following coronary artery
bypass graft surgery (NQF #2558)
measure results based on the
performance period of April 1, 2012
through March 31, 2015 and HCAHPS
survey data (NQF #0166) 2015 based on
the performance period of January 1,
2015 through December 31, 2015.
• To calculate improvement for the
CABG model, we utilized hospital 30day, all-cause, risk-standardized
mortality rate following coronary artery
bypass graft surgery (NQF #2558)
measure results based on the
performance period of April 1, 2011
through March 31, 2014 and HCAHPS
survey data (NQF #0166) 2015 based on
the performance period of January 1,
2014 through December 31, 2014.
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599
• To calculate performance for the
SHFFT model, we utilized hospitallevel risk-standardized complication
rate following elective primary total hip
arthroplasty (THA) and/or total knee
arthroplasty (TKA) measure results
based on the performance period of
April 1, 2012 through March 31, 2015
and HCAHPS survey data (NQF #0166)
2015 based on the performance period
of January 1, 2015 through December 31,
2015.
• To calculate improvement for
SHFFT, we utilized hospital-level riskstandardized complication rate
following elective primary total hip
arthroplasty (THA) and/or total knee
arthroplasty (TKA) measure results
based on the performance periods of
April 1, 2011 through March 31, 2015
and HCAHPS survey data (NQF #0166)
2015 based on the performance period
of January 1, 2014 through December 31,
2014.
Early experience in CJR shows that 27
percent of hospitals submitted voluntary
quality data in performance year 1. In
addition, prior experience in the
Medicare program indicates that when
payment is tied to voluntary reporting of
quality measures most hospitals report
such measures. For this analysis, we
assume that hospitals will report
voluntary measure increasingly
throughout the performance years and
that most hospitals in the EPMs will
submit voluntary measures to qualify for
the reduced discount by the fourth and
fifth performance year. Therefore, for
this analysis we assume in performance
year 1 and 2 that 27 percent of hospitals
will submit voluntary quality data. We
anticipate that 27 percent will submit
quality data in performance year 2, and
assume 63 percent submission of quality
data in performance year 3, and 99
percent in performance years 4 and 5 for
the EPM and CJR models. For the AMI
and CABG models, we developed
composite quality scores for all eligible
hospitals among the 98 selected MSAs.
Hospitals in these MSAs were assigned
to a performance percentile and
assigned the corresponding quality
performance score points listed in
Tables 24 and 28 of this final rule, based
on their performance in the historical
performance data described earlier.
Hospitals that did not have a reported
measure result were assigned to the 50th
performance percentile. Hospitals
assigned a quality measure performance
percentile for the most recent year that
were in the top 10 percent of the
improvement distribution received
quality improvement points. Because
2015 data were not available for the
AMI excess days measure, we randomly
assigned improvement points for this
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measure (0.5 points) to 10 percent of
hospitals. For SHFFT, hospitals in the
participating MSAs were assigned to a
performance percentile and assigned the
corresponding quality performance
score points listed in Table 30 of this
final rule, based on their performance in
the historical performance data
described earlier. Hospitals that did not
have a reported measure result were
assigned to the 50th performance
percentile. Hospitals assigned a quality
measure performance percentile for the
most recent year that improved by at
least 2 deciles from the prior year
received quality improvement points.
Based on these composite quality
scores, hospitals were assigned to a
quality category of ‘‘below acceptable’’,
‘‘acceptable’’, ‘‘good’’ or ‘‘excellent’’
based on their composite quality scores.
As discussed in section III.E. of this
final rule, composite quality scores will
affect hospitals’ eligibility for
reconciliation payments and determine
hospitals’ effective discount percentages
at reconciliation.
To simulate the impact for
performance year 1 (July 1, 2017
through December 31, 2017), we
calculated the NPRA using a blended
quality-adjusted target price calculated
for performance year 1, that is twothirds hospital experience and one-third
region experience, and applied no
downside risk to participants as
described in section III.D. of this final
rule. Additionally, as part of this
estimate, we accounted for whether a
participant met the minimum composite
quality score to be eligible for a
reconciliation payment. Lastly, we
applied the 5 percent stop-gain limit on
the estimated reconciliation payments
made to participants with a 3 percent
cap for rural hospitals, sole community
hospitals, Medicare dependent
hospitals, and rural referral centers.
For the simulation in performance
year 2, we used a blended qualityadjusted target price calculated for
performance year 2 that is two-thirds
hospital experience and one-third
regional experience. A 5 percent stoploss and stop-gain limit was applied to
reconciliation payments and
repayments for 1 percent of the
hospitals to model an estimated rate of
participants who will elect voluntary
downside risk, a 5 percent stop-gain
limit was applied to reconciliation
payments for the remaining 99 percent
of participants to model those who will
not elect voluntary downside risk.
Finally, a 3 percent stop-loss and stopgain limit was applied for rural
hospitals, sole community hospitals,
Medicare dependent hospitals, rural
referral centers and low-volume
participants as defined in section
III.D.2.c. of this final rule.
For the simulation in performance
year 3, we rebased episode prices to
incorporate the reconciliation payments
(as described in section III.D. of this
final rule) simulated from the first
performance year. To simulate
reconciliation for performance year 3,
we used the quality-adjusted target price
calculated as one-third of the hospital’s
experience and two-thirds of the
regional experience. We included a 5
percent stop-loss and stop-gain limit on
reconciliation payments and
repayments for participants with the
exception of a 3 percent stop-loss and
stop-gain limit on reconciliation
payments and repayments from rural
hospitals, sole community hospitals,
Medicare dependent hospitals, rural
referral centers, and certain low-volume
hospitals as defined in section
III.D.2.c.of this final rule. For
performance year 4, we simulated the
reconciliation process using the episode
quality-adjusted target price based on
100 percent of the regional experience,
and a stop-loss and stop-gain limit set to
10 percent for all participants, with the
exception of a 5 percent stop-loss and
stop-gain limit for rural hospitals, sole
community hospitals, Medicare
dependent hospitals, rural referral
centers, and low-volume hospitals as
defined in section III.D.2.c of this final
rule.
For performance year 5, we rebased
prices to include the simulated EPM
reconciliation payments and
repayments from performance years 1,
2, and 3. We simulated reconciliation in
the fifth performance year using qualityadjusted target prices that are based on
100 percent of the regional experience,
and applied the stop-loss and stop-gain
limits of 20 percent for all participants,
with the exception of a 5 percent stoploss and stop-gain limit for rural
hospitals, sole community hospitals,
Medicare dependent hospitals, rural
referral centers, and certain low-volume
hospitals as defined in section III.D.2.c
of this final rule.
The final results were then adjusted
under the assumption that the
percentage of EPM episodes excluded
due to enrollment in Next Generation
ACOs, Shared Savings Program ACOs in
Track 3, and End Stage Renal Disease
(ESRD) Seamless Care Organizations for
performance years 1 through 5 would
match the percentage of the FFS
population prospectively assigned to
these models for 2017. It was also
assumed that 99 percent of EPM
revenue would come from hospitals that
choose not to elect downside risk in
year 2.
(2) Analyses
TABLE 57—ESTIMATES OF IMPACT ON THE MEDICARE PROGRAM BY THE FINAL EPM *
Year(s)
2017
2018
2019
2020
Across all 5
years
of proposed
models
2021
3
3
5
9
6
11
(8)
(5)
(21)
(10)
(6)
(32)
(27)
(14)
(71)
(34)
(16)
(109)
Total: Net financial impact of all
EPM proposals ..............................
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AMI net financial impact ..........................
CABG net financial impact .......................
SHFFT net financial impact .....................
10
25
(34)
(49)
(112)
(159)
* Note: In millions. Totals do not necessarily equal the sums of rounded components.
Table 57 summarizes the estimated
impact for the AMI, CABG, and SHFFT
models. Our model estimates that the
Medicare program will save $159
million over the 5 performance years
(2017 through 2021).
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The first performance year of the
EPMs is expected to cost the Medicare
program $10 million in reconciliation
payments made to participants.
Participants that receive reconciliation
payments must earn a quality rating of
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‘‘Acceptable’’ or better and are the
participants that provide lower cost care
relative to quality adjusted target prices,
which reflect both hospital and regional
historical spending.
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In the second performance year of the
EPMs, the Medicare program on net is
expected to pay $25 million to
participants. This includes $26 million
in reconciliation payments made by the
Medicare program to participants, and
$1 million in payments made to the
Medicare program from participants that
elect downside risk in year 2.
Participants may elect early downside
risk beginning January 1, 2018 as
discussed in section III.D.2.c. of this
final rule. For participants who do not
elect early downside risk, downside risk
will not be applied for the entirety of
the second performance year. For
participants who elect early downside
risk in performance year 2, a 5 percent
stop-loss and stop-gain limit will apply,
subject to a 3 percent stop-loss and stopgain limit for rural hospitals, sole
community hospitals, Medicare
dependent hospitals, rural referral
center hospitals and certain low-volume
hospitals. These limits would cap the
total amount of repayments paid by
participants to the Medicare program.
For this analysis, we assumed 10
percent of participants will elect early
downside risk.
In the third performance year of the
models, net reconciliation payments are
expected to be $34 million in savings to
the Medicare program. This includes
$33 million in payments from the
Medicare program to participants, and
$67 million in payments from
participants to the Medicare program.
For performance years 4 and 5 of the
models, the episode quality-adjusted
target price will be based on full
regional pricing. This is expected to
create greater variation between the
quality-adjusted target price and
participants’ own experience. The stopgain and stop-loss limits of 20 percent
for performance year 5 apply, with a
stop-gain and stop-loss limit of 5
percent for rural hospitals, sole
community hospitals, Medicare
dependent hospitals, rural referral
centers hospitals, and certain lowvolume hospitals. As a result, net
payments are expected to be $49 million
601
from participants to the Medicare
program in the fourth year and $112
million in the fifth year. In performance
year 4 this includes $59 million in
payments from the Medicare program to
participants, and $108 million in
payments from participants to the
Medicare program. In performance year
5 this includes $59 million in payments
from the Medicare program to
participants, and $171 million in
payments from participants to the
Medicare program. These estimated
savings in years 4 and 5 represent an
average of 2.1 percent of total episode
spending in those years. The total
savings to the Medicare program after
the 5 performance years is expected to
be $159 million out of $15.0 billion or
1.0 percent of total episode spending.
Table 58 summarizes the estimated
reconciliation payments for the AMI,
CABG, and SHFFT models over the 5
performance years (2017 through 2021)
for the selected MSAs.
TABLE 58—ESTIMATES OF RECONCILIATION PAYMENTS
Performance Period
Numbers in millions
July 2017–December 2017
2018
2019
2020
2021
Over 5 years
All EPM episodes
Total dollars included in NRPA calculation ........................................................
Net reconciliation and repayment dollars
Payments from CMS to hospitals ............
Repayments from hospitals to CMS ........
Financial impact as a percentage of dollars included in model ..........................
$743
10
10
0
$3,259
25
26
¥1
$3,440
¥34
33
¥67
$3,670
¥49
59
¥108
$3,912
¥112
59
¥171
$15,023
¥159
187
¥346
1.4%
0.8%
¥1.0%
¥1.3%
¥2.9%
¥1.1%
Acute Myocardial Infarction episodes
Total dollars included in NRPA calculation ........................................................
Net reconciliation and repayment dollars
Payments from CMS to hospitals ............
Repayments from hospitals to CMS ........
Financial impact as a percentage of dollars included in model ..........................
235
3
3
0
1,026
9
9
0
1,079
¥8
13
¥21
1,151
¥10
22
¥32
1,227
¥27
22
¥49
4,718
¥34
68
¥102
1.3%
0.9%
¥0.7%
¥0.9%
¥2.2%
¥0.7%
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Coronary Artery Bypass Grafting episodes
Total dollars included in NRPA calculation ........................................................
Net reconciliation and repayment dollars
Payments from CMS to hospitals ............
Repayments from hospitals to CMS ........
Financial impact as a percentage of dollars included in model ..........................
146
3
3
0
669
6
6
0
704
¥5
6
¥11
751
¥6
12
¥18
800
¥14
12
¥26
3,070
¥16
38
¥55
1.8%
0.9%
¥0.7%
¥0.8%
¥1.7%
¥0.5%
1,768
¥32
26
¥58
1,884
¥71
26
¥97
7,235
¥109
81
¥190
Hip and Femur Procedures Except Major Joint episodes
Total dollars included in NRPA calculation ........................................................
Net reconciliation and repayment dollars
Payments from CMS to hospitals ............
Repayments from hospitals to CMS ........
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5
5
0
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1,564
11
11
0
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1,657
¥21
14
¥35
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TABLE 58—ESTIMATES OF RECONCILIATION PAYMENTS—Continued
Performance Period
Numbers in millions
July 2017–December 2017
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Financial impact as a percentage of dollars included in model ..........................
1.2%
(3) Uncertainties
These estimates are somewhat
uncertain. As a result, the EPMs could
produce more Medicare savings or
could result in additional costs to the
Medicare program. This analysis
assumes that the incentives under the
models drive no change in utilization of
services within the episode, as this
would not materially affect the
estimated financial impacts to the
Medicare program. The prospective
prices for the episodes incorporate price
updates from the FFS payment systems,
but no change in utilization for the
performance years is assumed. If there
is a national increase in utilization
within each episode that is not driven
by the incentives under the models,
then savings to the Medicare program
may increase due to greater repayments
paid back to Medicare. If there is a
national decrease in utilization within
each episode that is not driven by the
incentives under the models, then costs
to the Medicare program may increase
due to greater reconciliation payments
paid by Medicare to participants.
We also assume that 27 percent of
hospitals will submit voluntary
measures in performance years 1 and 2,
consistent with current experience in
performance year 1 for CJR. We assume
the percentage of hospitals that submit
quality data will increase in 63 percent
in performance year 3, and 99 percent
in performance years 4 and 5 to qualify
for the reduced discount. As a
sensitivity test, if no hospitals report the
voluntary measures for any of the three
EPMs, the models together are estimated
to save the Medicare program an
additional $27 million over the 5
performance years.
Additionally, we were unable to fully
estimate the impact of the proposal in
section III.D. of this final rule which
addresses beneficiaries in EPMs who are
also aligned or attributed to a Medicare
Shared Savings Program participant or a
participant in an ACO model initiated
by the CMS Innovation Center. Savings
achieved during an EPM episode will be
attributed to the EPM participant, with
EPM reconciliation payments for ACOaligned beneficiaries treated as ACO
expenditures, which should serve to
minimize the financial impact of ACO
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2018
2019
0.7%
¥1.3%
overlap on overall savings. As described
in section III.D.6. of this final rule,
beginning in July 2017 we will exclude
from AMI, CABG, and SHFFT episodes
beneficiaries aligned to ACOs in the
Next Generation ACO model, Shared
Savings Program Track 3, and ESRD
ESCOs in the Comprehensive ESRD
Care Initiative in tracks with downside
risk for financial losses. Excluding these
beneficiaries from the EPMs will have
the effect of reducing the number of
eligible episodes and therefore the
expected savings generated by
implementation of the EPMs. To model
the impact of these exclusions, we
assume that the percentage of the FFS
population aligned to the Next
Generation ACO model, Shared Savings
Program Track 3, and ESRD ESCOs in
the Comprehensive ESRD Care initiative
remains constant over the 5
performance years of the EPM model,
and is similar to the distribution of
beneficiaries aligned to these models for
the 2017 calendar year.
Due to the uncertainty of estimating
the impacts of the EPMs, actual results
could be higher or lower than these
estimates. Additionally, we note that for
these estimates, we did not make
assumptions for changes in efficiency or
utilization over the course of the
performance period. Our analysis
presents the cost and transfer payment
effects of this final rule to the best of our
ability. We solicited comments on the
assumptions and analysis presented.
The following is a summary of the
comments received and our responses.
Comment: A commenter noted that
the impacts in the proposed rule did not
present costs and savings attributable to
the cardiac rehabilitation incentive
payment model separate from the AMI,
CABG and SHFFT EPM costs and
savings and requested that we provide
this information.
Response: We appreciate the interest
of the commenter to obtain a breakdown
of costs and savings attributable to the
cardiac rehabilitation incentive payment
model. We have presented disaggregated
cardiac rehabilitation incentive payment
model costs and savings in this final
rule.
Comment: One commenter expressed
concern for the potential economic
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2020
2021
¥1.8%
¥3.8%
Over 5 years
¥1.5%
impact that the EPMs may have on
beneficiaries’ families and family
caregivers such as increased home
health care needs. The commenter
stated that they believe there is a great
deal of economic impact on families due
to missed work or other out of pocket
costs which might increase due to
shortened stays at inpatient or
rehabilitation facilities resulting from
the EPMs. The commenter requested
that CMS provide detailed modeling of
the economic impacts on family
caregivers, including direct out of
pocket costs and missed work
associated with caring for family
members who are beneficiaries in an
EPM.
Response: We appreciate the
commenter’s concern for the potential
economic impact on in-home family
care providers. However, we do not
believe that this is something that can
be accurately modeled given the high
amount of uncertainty regarding the
volume of additional in-home familyprovided care that might potentially be
spurred by the EPMs.
Comment: A commenter requested
that we provide greater detail with
regard to the modeling methods utilized
in our estimates. The commenter
requested that we further explain the
implication on physician practice under
the model.
Response: Our estimates of the
impacts of the EPMs do not include
assumptions about behavioral change on
the part of providers and suppliers or
other entities other than participating
hospitals as a result of the EPMs. The
EPMs could enable participants to
consider the most appropriate strategies
for care redesign with collaborating
entities including physicians, such as—
(1) increasing post-hospitalization
follow-up and medical management for
patients; (2) coordinating across the
inpatient and post-acute care spectrum;
(3) conducting appropriate discharge
planning; (4) improving adherence to
treatment or drug regimens; (5) reducing
readmissions and complications during
the post-discharge period; (6) managing
chronic diseases and conditions that
may be related to the proposed EPM
episodes; (7) choosing the most
appropriate post-acute care setting; and
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(8) coordinating between providers and
suppliers such as hospitals, physicians,
and post-acute care providers.
In addition, as discussed in section
I.B.5. of this final rule, the EPMs create
an opportunity for physicians to
collaborate in order to participate in
Track 1 of the EPMs to be eligible for
qualification for Advanced APM. For
purposes of modeling impacts, we have
assumed that only 1 percent of
participants will elect to take on
downside risk in performance year 2 to
qualify as an Advanced APM.
Participation in the Advanced APMs
may result in net profits or losses for
collaborating physicians. For more
information on Advanced APMs, please
see the MIPS and Alternative Payment
Model (APM) Incentive Under the
Physician Fee Schedule, and Criteria for
Physician-Focused Payment Models
final rule with comment period (81 FR
77008 through 77831). We refer readers
to Table 57, where we provide the
estimated impact associated with the
implementation of the EPMs.
b. CJR
We are finalizing our proposal to
modify the CJR model to include
reconciliation payments and Medicare
repayments in our calculations when
updating CJR episode quality-adjusted
target prices for performance years 3
through 5. We are also finalizing our
proposal to create consistency between
the CJR composite quality scores and
SHFFT composite quality scores by—(1)
awarding quality improvement points
based on an improvement of 2 deciles
(rather than 3 deciles as in the final CJR
rule); (2) capping the total composite
quality score at 20; and (3) utilizing an
updated HCAHPS algorithm.
(1) Assumptions and Uncertainties
We used final action Medicare claims
data from January 1, 2012 through
December 31, 2014 to update the impact
originally outlined in the CJR final rule
(80 FR 73288) to reflect the changes
finalized in this final rule for the CJR
model. Specifically, we estimated the
effect of including BPCI and CJR
reconciliation payments and Medicare
repayments in setting quality-adjusted
target prices for performance years 3–5.
We also updated our prior assumption
regarding CJR participation with
voluntary reporting of quality data to be
more consistent with prior experience.
The estimates assume that 27 percent of
CJR participants will submit quality
data in performance years 1 and 2,
consistent with preliminary results
regarding quality reporting in
performance year 1. The model then
assumes that more hospitals will submit
quality data over time to qualify for a
lower discount, with 63 percent
reporting quality data in performance
year 3, and 99 percent in performance
years 4 and 5.
To simulate changes in the
calculation of the CJR composite scores,
we used quality data as publicly
reported on Hospital Compare in 2015
and 2016 to estimate the impact of this
policy, with 2016 measures used to
calculate performance and the
difference between 2015 and 2016
measures used to calculate
improvement. We calculated the HLMR
by using 10 of the 11 publicly reported
measures, taking the average of all
publicly reported measures except how
well hospital staff help patients manage
pain, consistent with revisions under
consideration for this HCAHPS
measure. Calculations are as follows:
• To calculate performance for the
CJR model, we utilized hospital-level
risk-standardized complication rate
following elective primary total hip
arthroplasty (THA) and/or total knee
arthroplasty (TKA) measure results
based on the performance period of
April 1, 2012 through March 31, 2015
and HCAHPS survey data (NQF #0166)
2015 based on the performance period
of January 1, 2015 through December 31,
2015.
603
• To calculate improvement for CJR,
we utilized hospital-level riskstandardized complication rate
following elective primary total hip
arthroplasty (THA) and/or total knee
arthroplasty (TKA) measure results
based on the performance periods of
April 1, 2011 through March 31, 2015
and HCAHPS survey data (NQF #0166)
2015 based on the performance period
of January 1, 2014 through December 31,
2014.
For the purpose of this analysis, we
assumed that 99 percent of hospitals
participating in the CJR model will
voluntarily submit patient-reported
outcome measures to qualify for the
lower discount by performance year 4.
CJR participants were assigned to a
performance percentile and assigned the
corresponding quality performance
score as described in the CJR final rule
(80 FR 73288). Hospitals that did not
have a reported measure result were
assigned to the 50th performance
percentile. Hospitals assigned a quality
measure performance percentile for the
most recent year that improved by at
least 2 deciles from the prior year
received quality improvement points,
with the total composite quality score
capped at 20. These composite quality
scores, consistent with the methodology
finalized in section III.E., were then
applied to the development of qualityadjusted target prices as described in the
CJR final rule (80 FR 73288).
We note that we finalized a
modification to the application of the
stop-loss and stop-gain limits to exclude
hospital responsibility for post-episode
spending from the application of these
limits. The number of hospitals
estimated to be affected by the postepisode spending calculation is
anticipated to be small, and the
estimated post-episode reconciliation
amount is estimated to round down to
0 million.
(2) Analyses
TABLE 59—ESTIMATES OF IMPACT ON THE MEDICARE PROGRAM BY THE CJR MODEL *
Year(s)
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2016
Original CJR net financial impact from
final rule ................................................
CJR modifications net financial impact ....
2017
11
1
2018
(36)
2
2019
(71)
10
2020
(120)
11
(127)
2
Across all 5
years of the
proposed
model
(343)
26
* In millions. Totals do not necessarily equal the sums of rounded components.
Modifications to the CJR model as
established in this final rule would
begin at the time of reconciliation for
performance year 1 and therefore affect
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estimates of the impact of the model
from April 2016–December 2020. The
change in the estimated net financial
impact to the Medicare program from
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the CJR model modifications in this
final rule is $22 million in spending,
and the updated assumptions regarding
the number of hospitals that will report
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quality data result in an increase of $4
million in spending. The total estimated
net financial impact to the Medicare
program from both the modifications in
the final rule and revised assumptions
are $26 million in Medicare spending.
Due to the uncertainty of estimating the
impacts of this model, actual results
could be higher or lower than this
estimate. We are also unable at this time
to estimate the impacts of considering
certain CJR and EPM providers and
Affiliated Practitioners to be
participating in Advanced APMs.
Eligible clinicians that qualify as QPs
for a year through participation in EPMs
and CJR will receive a bonus equal to 5
percent of their prior year Medicare
payments, thereby increasing Medicare
expenditures.
c. CR Incentive Payment Model
As detailed in section VI of this final
rule, the CR incentive payment model
will test whether a financial incentive
for hospitals that encourages the
management of beneficiaries that have
had an AMI or a CABG in ways that may
contribute to long-term improvements
in quality and reductions in Medicare
spending. The CR incentive payment
model will test the effects on quality of
care and Medicare expenditures of
providing explicit financial incentives
to CR participants for beneficiaries
hospitalized for treatment of AMI or
CABG to encourage care coordination
and greater utilization of medically
necessary CR/ICR services for 90 days
post-hospital discharge where the
beneficiary’s overall care is paid under
either an EPM or the Medicare FFS
program.
Under the CR incentive payment
model, we will provide a CR incentive
payment to selected hospitals with
financial responsibility for AMI or
CABG model episodes (hereinafter
EPM–CR participants) because they are
already engaged in managing the AMI or
CABG model beneficiary’s overall care
for a period of time following hospital
discharge. We will also provide a CR
incentive payment to selected hospitals
that are not AMI or CABG model
participants (hereinafter FFS–CR
participants), enabling us to test and
improve our understanding of the
effects of the CR incentive payment
within the context of an EPM and the
Medicare FFS program, as well as to
identify potential interactions between
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the CR incentive payment and the
underlying EPM and FFS payment
methodologies. We will test the CR
incentive payment model in 45 of the 98
MSAs selected for the AMI and CABG
EPMs, as well as 45 FFS MSAs selected
through stratified random sampling.
(1) Assumptions and Uncertainties
We used final action Medicare claims
data from January 1, 2012 through
December 31, 2015 to identify CR and
ICR services that count towards CR
incentive payments on the basis of the
presence of the HCPCS codes on PFS
and OPPS claims and APC codes on
OPPS claims that report CR/ICR
services. We then compared total
Medicare spending over 3 years post
hospital discharge for AMI and CABG
for beneficiaries that received cardiac
rehabilitation services within 90 days of
discharge, to beneficiaries that did not
receive cardiac rehabilitation services
within 90 days of discharge. We found
that among beneficiaries continuously
enrolled over 3 years in FFS Medicare
Part A and B those receiving cardiac
rehabilitation services within 90 days of
discharge from an AMI and or CABG
hospitalization had lower Medicare
spending relative to beneficiaries whom
did not receive cardiac rehabilitation
services post discharge from an AMI
and or CABG hospitalization, even after
adjusting for differences in age, sex, and
case-mix between the two populations.
The difference in average spending
between the group that received cardiac
rehabilitation services and the group
that did not receive cardiac
rehabilitation services within 90 days of
discharge represents the reduction in
Medicare spending we would anticipate
from an additional beneficiary receiving
cardiac rehabilitation services due to the
cardiac rehabilitation incentive payment
model. However, adjusting for age, sex
and case-mix may not fully account for
other characteristics in the cardiac
rehabilitation population compared to
patients who did not receive such
services that may account for the
difference in Medicare spending.
CR incentive payments apply to CR/
ICR sessions during the 90-day episode
(for EPM participants) or 90-day care
period (for FFS participants) from date
of discharge. CR and ICR services paid
by Medicare to any provider or supplier
for model beneficiaries during AMI or
CABG model episodes/care periods
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would result in participant eligibility for
CR incentive payments. To model the
impact of the cardiac rehabilitation
incentive payment model, we calculated
the costs of the incentive payments for
beneficiaries receiving cardiac
rehabilitation services, as well as any
reduction in Medicare spending due to
more beneficiaries receiving cardiac
rehabilitation services. For the 90 MSAs
selected for the cardiac rehabilitation
incentive payment model, we used final
action Medicare claims data for the 2015
calendar year to calculate what the
cardiac rehabilitation incentive
payments would be for all beneficiaries
receiving cardiac rehabilitation services
within 90 days of an AMI and CABG
hospitalization. For a given increase in
the proportion of beneficiaries observed
in the 2015 calendar year that received
cardiac rehabilitation services (see table
60), we calculated both the cost of the
cardiac rehabilitation incentive
payments for these additional
beneficiaries, as well as the estimated
reduction in Medicare spending over a
3-year period due to these additional
beneficiaries receiving cardiac
rehabilitation services. We estimated
spending based on the pricing structure
described in section VI.E. of this final
rule. For a given rate of beneficiaries
receiving cardiac rehabilitation services,
we summed the costs of CR incentive
payments. We then subtracted the
estimated reduction in Medicare
spending due to the increase in the rate
of beneficiaries receiving cardiac
rehabilitation services relative to the
rate receiving such services in the 2015
calendar year to arrive at the net
financial impact. This analysis
considers the impact of increased
utilization on transfer payments from
Medicare to providers, as well as
beneficiary copays and coinsurance.
We recognize that utilization of CR/
ICR services is driven by many factors,
and we lack sufficient data to reliably
estimate the effect of a CR incentive
payment on beneficiary utilization of
CR/ICR services, particularly during the
90-day episode/care period. Therefore,
we calculated a range of potential
impacts based on alternatives in the
increase in cardiac rehabilitation
utilization, ranging from no change to
an increase in utilization of 4 percentage
points.
(2) Analyses
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605
TABLE 60—RANGE OF POTENTIAL LONG-TERM IMPACT OF CARDIAC REHABILITATION INCENTIVE PAYMENT MODEL *
Increase in cardiac rehabilitation utilization
Year
No increase
2017
2018
2019
2020
2021
2022
2023
2024
2 percentage
points
4 percentage
points
.............................................................................................................................................
.............................................................................................................................................
.............................................................................................................................................
.............................................................................................................................................
.............................................................................................................................................
.............................................................................................................................................
.............................................................................................................................................
.............................................................................................................................................
2
6
7
7
8
........................
........................
........................
2
6
4
2
1
(8)
(5)
(3)
2
6
1
(3)
(7)
(16)
(10)
(5)
Total: 2017–2024 ..................................................................................................................
29
(1)
(32)
* In millions of dollars. Totals do not necessarily equal the sums of rounded components.
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Table 60 summarizes the estimated
impact for the CR incentive payment
model. Our model estimates that the
impact on Medicare spending may range
from up to $29 million of spending to
$32 million of savings between 2017
and 2024, depending on the change in
utilization of CR/ICR services under the
model. The estimate only considers the
financial effects of additional
beneficiaries receiving CR/ICR services,
and does not take into account potential
changes in the volume of CR/ICR
services that beneficiaries may receive
within 90-days of hospital discharge.
Increasing CR/ICR services within 90
days of hospital discharge will increase
CR/ICR incentive payments, and may
influence Medicare spending after the
90 day episode. Due to the uncertainty
of estimating the impacts of this model,
actual results could be higher or lower
than this estimate. Our analysis presents
the cost and transfer payment effects of
this final rule to the best of our ability.
We solicited comments on our
assumptions and analysis presented in
the proposed rule (81 FR 50989 through
51002). However, we did not receive
comments on this topic.
d. Further Consideration
We can use our experience in
previous implementation of bundled
payment models to help inform our
impact analyses. We have previously
used our statutory authority to create
payment models such as the BPCI
initiative and the ACE Demonstration to
test bundled payments, as well as the
CJR model. Under the authority of
section 1866C of the Act, the Medicare
program funded a 3-year demonstration,
the ACE Demonstration. The
demonstration used a prospective global
payment for a single episode-of-care as
an alternative approach to payment for
service delivery under traditional
Medicare FFS. The episode-of-care was
defined as a combination of Parts A and
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B services furnished to Medicare FFS
beneficiaries during an inpatient
hospital stay for any one of a specified
set of cardiac and orthopedic MS–DRGs.
The discounted bundled payments
generated an average gross savings to
Medicare of $585 per episode for a total
of $7.3 million across all episodes
(12,501 episodes) or 3.1 percent of the
total expected costs for these episodes.
After netting out the savings produced
by the Medicare Parts A and B
discounted payments and some
increased PAC costs that were observed
at two sites, Medicare saved
approximately $4 million, or 1.72
percent of the total expected Medicare
spending.
Additionally, we are currently testing
the BPCI initiative. Under this initiative,
entities enter into payment
arrangements with CMS that include
financial and performance
accountability for episodes of care. The
BPCI initiative is evaluating the effects
of episode-based payment approaches
on patient experience of care, outcomes,
and cost of care for Medicare FFS
beneficiaries. We believe that our
experiences with BPCI support the
design of the EPMs.
Although there is some evidence from
BPCI and ACE suggesting that providers
may improve their performance, the
participants that volunteered to
participate may be in a better position
to reduce episode spending relative to
the average provider. The CJR model is
testing the first bundled payment model
under the Innovation Center authority
in which providers are required to
participate. The CJR model test began in
April 2016 and we are finalizing
refinements to the CJR in this final rule
to support successful implementation.
The design of the EPMs finalized in this
rule incorporates early learnings from
the CJR model.
Finally, although we project savings
to Medicare under the EPMs and
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updated CJR, as stated earlier, we note
that under section 1115A(b)(3)(B) of the
Act, the Secretary is required to
terminate or modify a model unless
certain findings can be made with
respect to savings and quality after the
model has begun. If during the course of
testing it is determined that termination
or modification is necessary, such
actions would be undertaken through
rulemaking.
3. Effects on Beneficiaries
We believe that episode payment
models may have the potential to
benefit beneficiaries because the intent
of the models is to test whether
providers under episode payment
models are able to improve the
coordination and transition of care,
invest in infrastructure and redesigned
care processes for high quality and
efficient service delivery, and
incentivize higher value care across the
inpatient and post-acute care spectrum
spanning the episode of care. We
believe that episode payment models
have a patient-centered focus such that
they incentivize improved healthcare
delivery and communication delivered
around the needs of the beneficiary,
thus potentially benefitting the
beneficiary community. However, the
EPMs do not affect beneficiary cost
sharing for services or premiums paid
by beneficiaries. If there is a shift in
services utilized within each episode,
then beneficiary cost sharing could be
higher or lower than would otherwise
be experienced.
We finalized the use of several patient
outcomes and patient experience
measures to tie payment to quality
performance with the intent that this
approach encourages the provider
community to focus on and deliver
improved quality care for Medicare
beneficiaries. Additionally, participants
must meet an acceptable level of quality
performance in order to qualify to
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receive a reconciliation payment. The
accountability of participants for both
quality and cost of care provided for
Medicare beneficiaries within episodes
provides participants with new
incentives to improve the health and
well-being of the Medicare beneficiaries
they treat.
Additionally, the EPMs and CJR do
not affect the beneficiary’s freedom of
choice to obtain health services from
any individual or organization qualified
to participate in the Medicare program
guaranteed under section 1802 of the
Act. Eligible beneficiaries who choose to
receive services from a participant
would not have the option to opt out of
inclusion in the models. Although the
EPMs and CJR allow participants to
enter into risk-sharing arrangements
with certain other providers, and
participants may recommend those
providers to the beneficiary,
participants may not prevent or restrict
beneficiaries to any list of preferred or
recommended providers.
Many controls exist under Medicare
to ensure beneficiary access and quality,
and we have proposed to use our
existing authority, if necessary, to audit
participants if claims analysis indicates
an inappropriate change in delivered
services. As described in section III.G. of
this final rule, given that participants
would receive a reconciliation payment
when they are able to reduce average
spending per episode and achieve
acceptable or greater quality
performance, they could have an
incentive to avoid complex, high cost
cases by referring them to nearby
facilities or specialty referral centers.
We intend to monitor the claims data
from participants—for example, to
compare a hospital’s case mix relative to
a pre-model historical baseline to
determine whether complex cases are
being systematically excluded.
Furthermore, we also proposed to
require providers to supply beneficiaries
with written information regarding the
design and implications of these EPMs
as well as their rights under Medicare,
including their right to use their
provider of choice.
We have proposed to implement
several safeguards to ensure that
Medicare beneficiaries do not
experience a delay in services. We
believe that the longer the episode
duration, the lower the risk of delaying
care beyond the episode duration, and
we believe that a 90-day post-hospital
discharge episode duration is
sufficiently long to minimize the risk
that any episode-related care will be
delayed beyond the end of the episode.
Moreover, we are finalizing that as part
of the payment definition (see section
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III.D. of this final rule) that participants
would be financially responsible for
certain outlier post-episode payments
occurring in the 30-day window
subsequent to the end of the 90-day
episode.
Lastly, we note that Medicare
payments for services will continue to
be made for each Medicare FFS
payment system under the CJR model
and the EPMs. Because we are finalizing
our proposal to waive beneficiary
coinsurance for reconciliation payments
and repayments, beneficiaries will be
subject to copayments, deductibles, and
coinsurance consistent with Medicare
FFS payments, rather than as
determined by quality-adjusted target
prices. In our analysis of impacts, we
assume that beneficiary payments will
not be affected, as only the participant
will be subject to the reconciliation
process. If participants are successful in
improving quality or care while
reducing costs, beneficiaries may benefit
through reduced out-of-pocket
expenditures across the episode.
Alternatively, if participants respond to
the incentives under the models by
shifting medical care outside of the 90day bundle, than this may negatively
impact the quality of care that
beneficiaries receive.
4. Effects on Small Rural Hospitals
Section 1102(b) of the Social Security
Act requires us to prepare a regulatory
impact analysis if a proposed rule or
final rule may have a significant impact
on the operations of a substantial
number of small rural hospitals. This
analysis must conform to the provisions
of section 604 of the RFA. For purposes
of section 1102(b) of the Act, a small
rural hospital is defined as a hospital
that is located outside of an MSA and
has fewer than 100 beds. The models
finalized in this rule do not require
participation of hospitals located
outside of MSAs. We have included a
more protective stop-loss policy for
certain IPPS hospitals that are located in
a rural area in accordance with
§ 412.64(b) or in a rural census tract
within an MSA defined at
§ 412.103(a)(1) or reclassified to rural in
accordance with § 412.103. The models
finalized in this rule will affect some
rural hospitals based on this definition.
Because of our concerns that rural
hospitals may have lower risk tolerance
and less infrastructure and support to
achieve efficiencies for high payment
episodes, we have finalized additional
financial protections for rural hospitals
(in addition to other protections under
the EPMs for Medicare Dependent
Hospitals, Rural Referral Centers, Sole
Community and certain low-volume
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participants). In performance year 2, a
rural hospital which qualifies for
reduced stop-loss and stop-gain limits
and elects downside risk could owe
Medicare no more than 3 percent of the
sum of quality-adjusted target prices for
the hospital’s episodes in an EPM. In
performance year 3, a rural hospital
could owe Medicare no more than 3
percent of quality-adjusted target prices
for the hospital’s episodes in an EPM. In
performance years 4 and 5, a rural
hospital could owe Medicare no more
than 5 percent of the sum of qualityadjusted target prices for the hospital’s
episode in an EPM. Although we are
finalizing these additional protections,
we believe that few rural hospitals will
be included in the models, and therefore
that few will need these protections.
AMI, CABG, and SHFFT episodes
account for less than 5 percent of all
discharges, and because relatively few
of these procedures are performed at
small rural hospitals, and because the
EPMs are designed to minimize adverse
effects on rural hospitals, we do not
believe that rural hospitals will
experience significant adverse economic
impacts. Accordingly, we conclude that
this final rule would not have a
significant impact on the operations of
a substantial number of small rural
hospitals.
We solicited public comments on our
estimates and analysis of the impact of
our proposals on small rural hospitals.
The following is a summary of the
comments received and our responses.
Comment: Some commenters were
concerned that this rule may have a
negative impact or create unnecessary
burden on small rural hospitals. One
commenter reported concern that the
EPMs could have a negative financial
impact on small rural hospitals. Another
commenter stated that the EPMs may
reduce access for rehabilitation services
in rural areas. This commenter stated
that they are concerned non-rural EPM
participant hospitals may encourage
beneficiaries to receive care at providers
affiliated with or within close proximity
to the non-rural EPM participant
hospital, which could negatively impact
volume of services provided by rural
hospitals. The commenter also stated
that beneficiaries living in rural settings
might therefore be forced to choose
between relocating to less rural areas to
receive appropriate care or to simply not
receive appropriate post-acute care and
follow-up.
Response: We understand the
commenters’ concern that the EPMs
may have negative financial
implications on rural hospitals. To limit
the impact on rural hospitals, we have
largely excluded them from the MSAs
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eligible for EPM. As discussed in
section III.D.7.c.(1) of this final rule, we
provide additional protections for rural
hospitals in the EPMs. We have also
established, in § 512.450, that
participants may not limit beneficiary
choice to any list of providers or
suppliers in any manner other than that
permitted under applicable statutes and
regulations including small rural
hospitals.
We recognize that rural IPPS
hospitals, SCHs, MDH and RRCs often
serve as the only sites of care for
beneficiaries living in rural areas, and
these providers may have limited
resources to contain costs under the
EPMs. Additionally, they may have a
limited number of providers and
suppliers with which to coordinate care,
such as CAHs that are reimbursed at a
higher cost-based rate. As a result, we
have provided for more protective stoploss limits for these groups of IPPS
hospitals in order to include them in the
models while alleviating some financial
risk. We believe that these models will
not have a significant impact on the
operations of a substantial number of
small rural hospitals. The discussion of
separate financial loss limits for certain
hospitals that may be less equipped to
tolerate risk is included in
§ 512.305(c)(2)(iii)(C).
We appreciate the comment regarding
the potential impact of this model on
rural providers, particularly small rural
hospitals. As we note in section
III.D.7.c.(1) of this final rule, we are
providing additional protections for
rural IPPS hospitals, SCHs, MDHs, RRCs
and certain low-volume hospitals
located in the MSAs selected for
participation in the models. As
discussed in section III.D.7.c.(1), we
note that these categories of hospitals
often have special payment protections
or additional payment benefits under
the Medicare program because we
recognize the importance of preserving
Medicare beneficiaries’ access to care
from these hospitals.
5. Effects on Small Entities
The RFA requires agencies to analyze
options for regulatory relief of small
entities, if a rule has a significant impact
on a substantial number of small
entities. For purposes of the RFA, small
entities include small businesses,
nonprofit organizations, and small
governmental jurisdictions. We estimate
that most hospitals and most other
providers and suppliers are small
entities, either by virtue of their
nonprofit status or by qualifying as
small businesses under the Small
Business Administration’s size
standards (revenues of less than $7.5 to
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$38.5 million in any 1 year; NAIC
Sector–62 series). States and individuals
are not included in the definition of a
small entity. For details, see the Small
Business Administration’s Web site at
https://www.sba.gov/content/
smallbusiness-size-standards.
For purposes of the RFA, we generally
consider all hospitals and other
providers and suppliers to be small
entities. We believe that the provisions
of this final rule relating to acute care
hospitals would have some effects on a
substantial number of other providers
involved in these episodes of care
including surgeons and other
physicians, skilled nursing facilities,
physical therapists, and other providers.
Although we acknowledge that many
of the affected entities are small entities,
and the analysis discussed throughout
this final rule discusses aspects of
episode payment models that may or
will affect them, we have no reason to
assume that these effects will reach the
threshold level of 3 percent of revenues
used by HHS to identify what are likely
to be ‘‘significant’’ impacts. We assume
that all or almost all of these entities
will continue to serve beneficiaries, and
receive payments in accordance with
Medicare FFS payment methodologies.
Accordingly, we have determined that
this final rule will not have a significant
impact on a substantial number of small
entities.
6. Effects on Collection of Information
There are three primary sets of
information collection activities that
EPM participants may be engaged in:
Activities related to quality reporting,
activities related to Advanced APM
participation, and ad hoc reporting of
beneficiary notification upon request by
CMS. Here, we briefly describe the
anticipated scope and effects of
information collection in each of these
three areas for EPM participants.
Quality reporting associated with the
EPMs includes EPM-specific quality
measures, HCAHPS, and voluntarily
reported quality measures (AMI, CABG
and SHFFT models), described in more
detail in section III.E. of this final rule.
IPPS hospitals are subject to incentives
under quality reporting incentives such
as the HVBP program and Medicare
Electronic Health Record (EHR)
Incentive Program, among others. Most
IPPS hospitals already report
information for the EPM-specific quality
measures and HCAHPS for other CMS
programs, and those hospitals that do
not otherwise report this information to
CMS would not be required to report
under the EPMs. Thus, for EPM
participants there will be no required
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607
information collection activities for the
EPMs.
For the AMI model, participants have
the option of reporting data for the
Hybrid AMI Mortality measure. This
measure includes a combination of
claims and EHR data for a total of five
EHR-based clinical data elements and
six claims-based elements. AMI
voluntary data submission must occur
within 60 days of most recent data
collection period. Successful
submission of optional Hybrid AMI
Mortality measure data will be based
upon inclusion of five key clinical data
elements.
We anticipate that participants who
choose to engage in voluntary reporting
of the Hybrid AMI Mortality measure
will engage in the following process:
• Hospitals receive the measure
authoring tool (MAT) output, a template
layout for the data reporting file, and
other artifacts that describe what they
are supposed to do and how. The only
data elements required are simple labs
and vital signs that are collected
consistently in structured fields. All
hospitals with EHRs should be able to
extract these from structured fields.
Many will have some experience based
on work with eCQMs.
• Hospitals review the MAT output
and submit questions or request
clarification via ongoing Q&A.
• Hospitals create a query for their
EHR database using the MAT output
and populate the reporting file with the
core clinical data elements (CCDE). The
hospital IT staff will typically run some
queries on a small set of admissions and
look at the corresponding charts to make
sure they are getting the right data and
may modify the query if needed.
• Hospitals submit the CCDE to CMS
on the prescribed template (QRDA,
consolidated clinical document
architecture (CCDA), or simple excel file
are all options).
• Hospitals do not need to do any
measure calculation. Once data
elements are submitted, CMS will link
with claims data to calculate measure
scores.
Given this process, the initial effort of
establishing operability will create the
majority of burden. Once the initial
effort of establishing the query is
complete, the burden will be minimal,
as the same query can be run against the
EHR for ongoing reporting. We assume
that the primary cost for a hospital will
be the IT support to set up the initial
query and ensure the correct data is
being pulled from the EHR. The data
elements should be less burdensome
than a typical eCQM because
participants do not need to create new
fields, all data is feasibly accessed in
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current EHRs without creating new
clinical workflows, and hospitals do not
need to do any measure calculation.
AMI model participants must meet
the following requirements for each
performance year in order to fulfill the
successful Hybrid AMI Mortality data
collection criterion. In performance year
1, participants will be required to
submit this data for 50 percent of
eligible AMI episodes occurring during
the 2-month period between July 1,
2017 and August 31, 2017. In
performance year 2, AMI voluntary data
submission will be for 10 months of
eligible discharges. In performance
years 3 through 5, participants will need
to submit data for the entire
performance year. Furthermore, in
performance years 2 through 5,
participants will need to submit the five
key clinical data elements for at least 90
percent of eligible AMI discharges to
receive credit for successful submission
and two additional points toward the
participant’s AMI model composite
quality score.
We are unable to provide a direct cost
estimate for hospitals at this time, but
expect to learn more as part of model
testing. The voluntary data submission
initiative will allow AMI model
participants to build processes to extract
and report the EHR data elements, as
well as support CMS testing of systems
required for Hybrid AMI Mortality
measure (NQF #2473) production
including data receiving and auditing,
the merging EHR and claims data,
calculation and production of measure
results.
For the CABG model, the voluntary
quality measure is successful
submission of data to the Society of
Thoracic Surgeons Adult Cardiac
Surgery Database (STS measure). We
anticipate that for the majority of CABG
model participants, there will be no
additional burden of reporting as the
STS measure as most CABG participants
are already submitting data for this
measure.
We do not anticipate significant
operational difficulties as we plan to
work collaboratively with the STS
Registry to receive the data files
following each data collection period as
prescribed by the STS Registry. EPM
participants who are not members of the
STS Proprietary Registry, but are a HQR
participating facility would have access
to SFT. Data files can be securely sent
via SFT in a transitional submission
format available to systems using a
spreadsheet-based approach.
We are unable to provide a direct cost
estimate for hospitals at this time, but
expect to learn more as part of the
CABG model testing.
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For the SHFFT model, the voluntary
quality measure is based on THA/TKA
patient-reported outcome-based
measure data submission, which draws
upon patient interviews to gain insights
into patient experience and related
outcomes.
We anticipate that participants who
choose to engage in voluntary reporting
of the THA/TKA patient-reported
outcome-based data will engage in the
following process:
• Participating hospitals will need to
establish a means to collect patientreported outcome data from patients
pre-operatively and, again, postoperatively. In addition, they would
need to collect select additional risk
variables from patient charts.
• The specific instruments (and risk
variables) have been vetted by a
Technical Expert Panel and public
comment: Veterans RAND 12 Item
Health Survey (VR–12) or PatientReported Outcomes Measurement
Information System (PROMIS) Global-10
generic PRO survey; Hip disability and
Osteoarthritis Outcome Score (HOOS)/
Knee injury and Osteoarthritis Outcome
Score (KOOS) Jr. or HOOS/KOOS
subscales PRO survey; additional risk
variables that can be physician-reported
or chart-abstracted.
• If hospitals select the least
burdensome instruments, data
collection requires patients to answer 16
through 17 outcome questions and 3
risk factor questions. Estimates from
instrument developers, input from the
patient members of a Technical Expert
Panel, and empirical results from a
survey of physicians collecting similar
data on THA/TKA patients support
minimal patient burden (under 5
minutes) to collect the required data.
• Pre-operative survey completion
could be arranged to be completed
online, by phone, or at pre-operative
clinic or hospital admission intake
visits. Post-operative survey completion
must occur between 270 and 365 days
after the eligible elective primary
procedure, and may occur in a variety
of ways, such as online or by phone.
• Hospitals will collect or extract 6
risk variables that are commonly
available in the medical record.
Currently available data suggests costs
associated with information collection
for this measure can vary tremendously.
We anticipate the SHFFT patientreported outcomes reporting costs to a
participant hospital would decrease
over time as the collection process is
streamlined and integrated into clinical
care workflows. A number of hospitals
are already collecting this data either as
a part of an established registry or for
participation in the existing CJR. For
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these participants, the burden of
developing data collection systems will
be minimal.
Participating hospitals must meet the
following information submission
requirements for each performance year
in order to fulfill the successful THA/
TKA patient-reported outcome-based
data collection criterion. In performance
year 1, participants must submit preoperative data for at least 60 percent of
eligible procedures or at least 75 cases
performed between September 1, 2016
and June 30, 2017. In performance year
2, participants must submit postoperative data for at least 60 percent of
eligible procedures or at least 75 cases
performed between September 1, 2016
and June 30, 2017 and also must submit
pre-operative data for at least 70 percent
of eligible procedures or at least 100
cases. In performance year 3,
participants must submit post-operative
data for at least 70 percent of eligible
procedures or at least 100 cases
performed between July 1, 2017 and
June 30, 2018 and also must submit preoperative data for at least 80 percent of
eligible procedures or at least 200 cases
performed between July 1, 2018 and
June 30, 2019. In performance year 4,
participants must submit post-operative
data for at least 80 percent of eligible
procedures or at least 200 cases
performed between July 1, 2018 and
June 30, 2019 and also must submit preoperative data for at least 80 percent of
eligible procedures or at least 200 cases
performed between July 1, 2019 and
June 30, 2020. In performance year 5,
participants must submit post-operative
data for at least 80 percent of eligible
procedures or at least 200 cases
performed between July 1, 2019 and
June 30, 2020 and also must submit preoperative data for at least 80 percent of
eligible procedures or at least 200 cases
performed between July 1, 2020 and
June 30, 2021.
We are unable to provide a direct cost
estimate for hospitals at this time, but
expect to learn more as part of SHFFT
and CJR model testing.
Overall, we anticipate the net burden
of voluntary data submissions in the
AMI, CABG and SHFFT models will be
marginal, as we anticipate hospitals will
only choose to proceed with optional
data submission if they believe the net
financial benefit will be positive.
Information collection related to the
Track 1 EPMs and the Track 1 CJR
model to meet the Advanced APM
requirements included in the Quality
Payment Program proposed rule and to
operationalize the EPMs and CJR as
Advanced APMs includes EPM and CJR
participant attestation to CEHRT and
clinician financial arrangements lists
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submission. We believe that the
selection by EPM and CJR participants
to meet and attest to the CEHRT use
requirement would create no significant
additional administrative burden on
EPM and CJR model participants. The
submission of clinician financial
arrangements lists (no more frequently
than quarterly) for Track 1 EPMs and
the Track 1 CJR model may create some
additional administrative requirements
for certain EPM and CJR participants.
Finally, we expect that participants
are able to produce lists of beneficiaries
who have received compliant
notification of participation in model.
We provided flexible guidelines for this
requirement as specific record keeping
methods can be chosen by individual
participants so long as the necessary
information is maintained readily
available to report upon request. We
sought comment on any burden derived
from this requirement. In total, we
anticipate marginal additional reporting
burden resulting from this final rule.
The following is a summary of the
comments received and our responses.
Comment: A commenter expressed
concern over increased quality data
reporting in the EPMs and the CJR
model. The commenter stated that, to
date, they have utilized extensive
resources to maintain compliance with
CJR quality reporting requirements and
are concerned about further quality
reporting requirements for the EPMs.
The commenter requested that CMS
delay quality reporting requirements
due to the resource investment
necessary to comply with EPM quality
reporting requirements.
Response: We appreciate the
commenter’s concern over potential
burden associated with quality data
reporting in the EPMs. As discussed in
section III.E.3. of this final rule, EPM
participants are not required to report
quality data for reconciliation payment
eligibility. While EPM participants may
choose to increase their financial
opportunity under the model by
successfully submitting data for future
measure development, as discussed in
sections III.E.3.d. of this final rule,
reporting data for future measure
development is not required for
reconciliation payment eligibility.
7. Unfunded Mandates
Section 202 of the Unfunded
Mandates Reform Act of 1995 (UMRA)
also requires that agencies assess
anticipated costs and benefits before
issuing any rule whose mandates
require spending in any 1 year of $100
million in 1995 dollars, updated
annually for inflation. In 2016, that is
approximately $146 million. This final
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rule does not include any mandate that
would result in spending by state, local
or tribal governments, in the aggregate,
or by the private sector in the amount
of $146 million in any 1 year.
D. Alternatives Considered
Throughout this final rule, we have
identified the policies and alternatives
that we have considered, and provided
information as to the possible effects of
these alternatives and the rationale for
each of the policies we have finalized.
We solicited and welcomed comments
on our proposals, on the alternatives we
identified, and on other alternatives that
we should consider, as well as on the
costs, benefits, or other effects of these.
We note that our estimates are limited
to hospitals in the CJR model, hospitals
that will be included in the SHFFT
model, hospitals selected to participate
in the AMI and CABG models, and the
FFS–CR participants. This final rule
will not impinge directly on hospitals
that are not participating in CJR or the
EPMs. However, it may encourage
innovations in health care delivery in
other areas or in care paid through other
payers. For example, a hospital and
affiliated providers may choose to
extend their arrangements for an EPM to
other payers, not just those beneficiaries
paid under Medicare FFS. Alternatively,
a hospital and affiliated providers in
one city may decide to hold themselves
forth as ‘‘centers of excellence’’ for
patients from other cities, both those
included and not included in the EPMs.
We welcomed comments that address
these or other possibilities.
We present the implications of
alternatives considered in the
development of the EPMs here. As
discussed in section III.C. of this final
rule, we will define beneficiary
inclusion in the AMI model by
discharge under an AMI MS–DRG (280–
282), representing those individuals
admitted with AMI who receive medical
therapy but no revascularization, and
discharge under a PCI MS–DRG (246–
251) with an ICD–10–CM diagnosis code
of AMI on the IPPS claim for the anchor
hospitalization in the principal or
secondary diagnosis code position.
Alternately, we could have defined
beneficiary inclusion based only on the
principal diagnosis code which would
have reduced the number of episodes
included in the EPMs.
As discussed in section III.E. of this
final rule, we allow participants to
qualify for a higher composite quality
score in the AMI, CABG and SHFFT
models based on submission of
voluntary measures or data. If we had
not provided the option for participants
to achieve an increased composite
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609
quality score for voluntary reporting (or
if we assume no hospitals report this
data), the AMI, CABG and SHFFT
models are estimated to result in an
additional $27 million savings over the
5 performance years.
As discussed in section VI of this final
rule, we have finalized our proposal for
the selection of CR MSAs via a modified
stratified random selection based on
several key dimensions related to CR/
ICR service provision, including percent
of eligible cases in the MSA who receive
CR/ICR services, percent who complete
CR or ICR services, and the number of
CR/ICR providers. In the proposed rule,
we outlined alternative MSA selection
strategies and solicited comments on the
MSA selection approach. We anticipate
that, because these approaches draw
from the same pool of eligible MSAs
without regard to MSA size or total cost
of care during the episode or care
period, the overall financial impact of
different selection methodologies will
be minimal, and the primary impact of
varied MSA selection approaches will
be on balance among model arms for
evaluation.
E. Accounting Statement and Table
As required by OMB Circular A–4
under Executive Order 12866 (available
at https://www.whitehouse.gov/omb/
circulars_a004_a-4) in Table 61, we
have prepared an accounting statement
showing the classification of transfers,
benefits, and costs associated with the
provisions in this final rule. The
accounting statement is based on
estimates provided in this regulatory
impact analysis. As described in Table
57, we estimate this final EPM model
will result in savings to the federal
government of $159 million over the 5
performance years of the model from
2017 to 2021. Table 58 shows the
annualized change in net federal
monetary transfers, and potential
reconciliation payments to participants
net of repayments from participants that
are associated with the EPM provisions
of this final rule as compared to
baseline. As described in Table 59, we
estimate the modifications to the CJR
model finalized in this final rule will
result in a reduced savings to the federal
government of $26 million over the 5
performance years of the model from
2016 to 2020. As described in Table 60,
we estimate the range of impact for this
final CR model to be between a cost of
$29 to a savings of $32 million over
2017 to 2024. In Table 61, the overall
annualized change in payments (for all
provisions finalized in this final rule)
based on a 7 percent and 3 percent
discount rate, results in net federal
monetary transfer from the participant
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IPPS hospitals to the federal government
of $13 million and $16 million
respectively over the period of 2016 to
2024. For purposes of the accounting
statement, we assumed no change in the
rate of beneficiaries receiving cardiac
rehabilitation services.
This final rule does not result in any
significant additional administrative
burden on participants.
TABLE 61—ACCOUNTING STATEMENT (2016–2024), ESTIMATED IMPACTS FOR EPISODE PAYMENT MODELS (2017–2021),
CHANGES TO COMPREHENSIVE CARE FOR JOINT REPLACEMENT (2016–2020), AND CARDIAC REHABILITATION INCENTIVE PAYMENT MODEL (2017–2024) ASSUMING NO CHANGE IN THE RATE OF PATIENTS RECEIVING CARDIAC REHABILITATION SERVICES
Category
Primary
estimate
(millions)
Transfers
Annualized monetized transfers: Discount rate 7% ............
........................
$13
Annualized monetized transfers: Discount rate 3% ............
16
From whom to whom? ................................................................
F. Conclusion
This analysis, together with the
remainder of this preamble, provides
the Regulatory Impact Analysis of a rule
with a significant economic effect. As a
result of this final rule, we estimate that
the financial impact of the AMI, CABG,
and SHFFT EPM models proposed here
would be net federal savings of $159
million over a 5-year performance
period (2017 through 2021), the
financial impact of the CJR model as
modified here with the revised
assumptions on hospital reporting of
quality data would be an estimated net
federal decrease in savings of $26
million over a 5-year period (2016
through 2020) relative to the estimates
published in the CJR final rule. The
financial impact of the CR incentive
payment model would be net change in
federal spending between $29 million in
additional costs and $32 million in
savings to the Medicare program over an
8-year period (2017 through 2024).
In accordance with the provisions of
Executive Order 12866, this regulation
was reviewed by the Office of
Management and Budget.
List of Subjects
asabaliauskas on DSK3SPTVN1PROD with RULES
42 CFR Part 510
Administrative Practice and
Procedure, Health facilities, Health
professions, Medicare, and Reporting
and recordkeeping requirements.
42 CFR Part 512
Administrative practice and
procedure, Health facilities, Medicare,
Reporting and recordkeeping
requirements.
■ For the reasons set forth in the
preamble, under the authority at section
1115A of the Social Security Act, the
Centers for Medicare & Medicaid
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Source citation
(RIA, preamble, etc.)
Change from baseline to final changes (Tables 57, 59, and
60).
From Participant IPPS Hospitals to Federal Government.
Services amends 42 CFR Chapter IV as
follows:
Subchapter H—Health Care Infrastructure
and Model Programs
PART 510—COMPREHENSIVE CARE
FOR JOINT REPLACEMENT MODEL
1. The authority citation for part 510
continues to read as follows:
■
Authority: Secs. 1102, 1115A, and 1871 of
the Social Security Act (42 U.S.C. 1302,
1315(a), and 1395hh).
2. Section 510.2 is amended by—
a. Adding in alphabetical order
definitions for ‘‘Applicable discount
factor’’, ‘‘Area’’, ‘‘CEHRT’’, ‘‘CJR
beneficiary,’’ and ‘‘Episode benchmark
price’’;
■ b. Removing the definition of
‘‘Episode target price’’;
■ c. Revising the definitions of
‘‘HCPCS’’, ‘‘HHA’’, and ‘‘Historical
episode payment’’;
■ d. Adding in alphabetical order a
definition for ‘‘Hospital’’;
■ e. Removing the definition of ‘‘IPPS
hospital (or hospital)’’;
■ f. Adding in alphabetical order a
definition for ‘‘Quality-adjusted target
price’’;
■ g. Revising the definition of ‘‘Quality
improvement points’’; and
■ h. Adding in alphabetical order a
definition of ‘‘Therapist in private
practice’’.
The additions and revisions read as
follows:
■
■
§ 510.2
Definitions.
*
*
*
*
*
Applicable discount factor means the
discount percentage established by the
participant hospital’s quality category as
determined in § 510.315 and that is
applied to the episode benchmark price
for purposes of determining a
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participant hospital’s Medicare
repayment in performance years 2 and
3.
Area means, as defined in § 400.200
of this chapter, the geographical area
within the boundaries of a State, or a
State or other jurisdiction, designated as
constituting an area with respect to
which a Professional Standards Review
Organization or a Utilization and
Quality Control Peer Review
Organization has been or may be
designated.
*
*
*
*
*
CEHRT means certified electronic
health record technology that meets the
requirements of 45 CFR 170.102. .
CJR beneficiary means a beneficiary
who meets the beneficiary inclusion
criteria in § 510.205 and who is in a CJR
episode.
*
*
*
*
*
Episode benchmark price means a
dollar amount assigned to CJR episodes
based on historical episode payment
data (3 years of historical Medicare
payment data grouped into CJR episodes
according to the episode definition as
described in § 510.200(b)) prior to the
application of the effective discount
factor or applicable discount factor, as
described in § 510.300(c).
*
*
*
*
*
HCPCS stands for Healthcare
Common Procedure Coding System.
HHA means a Medicare-enrolled
home health agency.
Historical episode payment means the
expenditures for historical episodes that
occurred during the historical period
used to determine the episode
benchmark price.
Hospital means a provider subject to
the prospective payment system
specified in § 412.1(a)(1) of this chapter.
*
*
*
*
*
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Quality-adjusted target price means
the dollar amount assigned to CJR
episodes as the result of adjusting the
episode benchmark price by the
participant hospital’s effective discount
factor or applicable discount factor
based on the participant hospital’s
quality category, as described in
§§ 510.300(c) and 510.315(f).
Quality improvement points are
points that CMS adds to a participant
hospital’s composite quality score for a
measure if the hospital’s performance
percentile on an individual quality
measure for performance years 2
through 5 increases from the previous
performance year by at least 2 deciles on
the performance percentile scale, as
described in § 510.315(d). For
performance year 1, CMS adds quality
improvement points to a participant
hospital’s composite quality score for a
measure if the hospital’s performance
percentile on an individual quality
measure increases from the
corresponding time period in the
previous year by at least 2 deciles on the
performance percentile scale, as
described in § 510.315(d).
*
*
*
*
*
Therapist in private practice means a
therapist that—
(1) Complies with the special
provisions for physical therapists in
private practice in § 410.60(c) of this
chapter;
(2) Complies with the special
provisions for occupational therapists in
private practice in § 410.59(c) of this
chapter; or
(3) Complies with the special
provisions for speech-language
pathologists in private practice in
§ 410.62(c) of this chapter.
*
*
*
*
*
■ 3. Section 510.2 is further amended,
effective July 1, 2017, by—
■ a. Revising the definition of ‘‘ACO’’;
■ b. Adding in alphabetical order
definitions for ‘‘ACO participant’’ and
‘‘ACO provider/supplier’’;
■ c. Revising the definition for
‘‘Alignment payment’’;
■ d. Revising the definition of ‘‘CJR
collaborator’’;
■ e. Adding in alphabetical order a
definition for ‘‘Collaboration agent’’;
■ f. Removing the definition of
‘‘Collaborator agreement’’;
■ g. Adding in alphabetical order a
definition for ‘‘CORF’’;
■ h. Revising the definitions of
‘‘Distribution arrangement’’ and
‘‘Distribution payment’’;
■ i. Adding in alphabetical order
definitions for ‘‘Downstream
collaboration agent’’, ‘‘Downstream
distribution arrangement’’,
‘‘Downstream distribution payment’’,
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j. Adding in alphabetical order
definitions for ‘‘Member of the NPPGP
or NPPGP member’’, ‘‘Member of the
TGP or TGP member’’, and ‘‘NPPGP’’;
■ k. Removing the definition of
‘‘Practice collaboration agent’’;
■ l. Revising the definition of ‘‘Provider
of outpatient therapy services’’;
■ m. Adding in alphabetical order
definitions of ‘‘TGP’’; and
■ n. In the definition of ‘‘Therapist’’ by
removing the phrase ‘‘the following as
defined at § 484.4:’’ and adding in its
place the phrase ‘‘the following
individuals as defined at § 484.4 of this
chapter:’’.
The additions and revisions read as
follows:
■
§ 510.2
Definitions.
*
*
*
*
*
ACO means an accountable care
organization, as defined at § 425.20 of
this chapter, that participates in the
Shared Savings Program and is not in
Track 3.
ACO participant has the meaning set
forth in § 425.20 of this chapter.
ACO provider/supplier has the
meaning set forth in § 425.20 of this
chapter.
*
*
*
*
*
Alignment payment means a payment
from a CJR collaborator to a participant
hospital under a sharing arrangement,
for the sole purpose of sharing the
participant hospital’s responsibility for
making repayments to Medicare.
*
*
*
*
*
CJR activities means activities related
to promoting accountability for the
quality, cost, and overall care for CJR
beneficiaries, including managing and
coordinating care; encouraging
investment in infrastructure enabling
technologies and redesigned care
processes for high quality and efficient
service delivery; the provision of items
and services during a CJR episode in a
manner that reduces costs and improves
quality; or carrying out any other
obligation or duty under CJR.
*
*
*
*
*
CJR collaborator means an ACO or
one of the following Medicare-enrolled
individuals or entities that enters into a
sharing arrangement:
(1) SNF.
(2) HHA.
(3) LTCH.
(4) IRF.
(5) Physician.
(6) Nonphysician practitioner.
(7) Therapist in private practice.
(8) CORF.
(9) Provider of outpatient therapy
services.
(10) Physician Group Practice (PGP).
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611
(11) Hospital.
(12) CAH.
(13) Non-Physician Provider Group
Practice (NPPGP).
(14) Therapy Group Practice (TGP).
*
*
*
*
*
Collaboration agent means an
individual or entity that is not a CJR
collaborator and that is either of the
following:
(1) A member of a PGP, NPPGP, or
TGP that has entered into a distribution
arrangement with the same PGP,
NPPGP, or TGP in which he or she is
an owner or employee, and where the
PGP, NPPGP, or TGP is a CJR
collaborator.
(2) An ACO participant or ACO
provider/supplier that has entered into
a distribution arrangement with the
same ACO in which it is participating,
and where the ACO is a CJR
collaborator.
*
*
*
*
*
CORF stands for comprehensive
outpatient rehabilitation facility.
*
*
*
*
*
Distribution arrangement means a
financial arrangement between a CJR
collaborator that is an ACO, PGP,
NPPGP, or TGP and a collaboration
agent for the sole purpose of distributing
some or all of a gainsharing payment
received by the ACO, PGP, NPPGP, or
TGP.
Distribution payment means a
payment from a CJR collaborator that is
an ACO, PGP, NPPGP, or TGP to a
collaboration agent, under a distribution
arrangement, composed only of
gainsharing payments.
*
*
*
*
*
Downstream collaboration agent
means an individual who is not a CJR
collaborator or a collaboration agent and
who is a PGP member, an NPPGP
member, or a TGP member that has
entered into a downstream distribution
arrangement with the same PGP,
NPPGP, or TGP in which he or she is
an owner or employee, and where the
PGP, NPPGP, or TGP is a collaboration
agent.
Downstream distribution arrangement
means a financial arrangement between
a collaboration agent that is both a PGP,
NPPGP, or TGP and an ACO participant
and a downstream collaboration agent
for the sole purpose of distributing some
or all of a distribution payment received
by the PGP, NPPGP, or TGP.
Downstream distribution payment
means a payment from a collaboration
agent that is both a PGP, NPPGP, or TGP
and an ACO participant to a
downstream collaboration agent, under
a downstream distribution arrangement,
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distribution arrangements and the
documentation required under
§§ 510.500(d) and 510.525(c)) sufficient
to enable the audit, evaluation,
inspection or investigation of any of the
following:
(1) The individual’s or entity’s
compliance with CJR model
requirements.
(2) The calculation, distribution,
receipt, or recoupment of gainsharing
payments, alignment payments,
distribution payments, and downstream
distribution payments.
(3) The obligation to repay any
reconciliation payments owed to CMS.
(4) The quality of the services
furnished to a CJR beneficiary during a
CJR episode.
(5) The sufficiency of CJR beneficiary
notifications.
(6) The accuracy of the CJR
participant hospital’s submissions
under CEHRT use requirements.
(b) Maintain all such books, contracts,
records, documents, and other evidence
for a period of 10 years from the last day
of the participant hospital’s
participation in the CJR model or from
the date of completion of any audit,
evaluation, inspection, or investigation,
whichever is later, unless—
(1) CMS determines a particular
record or group of records should be
retained for a longer period and notifies
the participant hospital at least 30
calendar days before the disposition
date; or
(2) There has been a dispute or
allegation of fraud or similar fault
against the participant hospital, CJR
collaborator, collaboration agents,
downstream collaboration agent, or any
other individual or entity performing
CJR activities in which case the records
must be maintained for 6 years from the
date of any resulting final resolution of
the dispute or allegation of fraud or
similar fault.
■ 5. Section 510.120 is added to subpart
B to read as follows:
§ 510.110
asabaliauskas on DSK3SPTVN1PROD with RULES
composed only of distribution
payments.
*
*
*
*
*
Member of the NPPGP or NPPGP
member means a nonphysician
practitioner or therapist who is an
owner or employee of an NPPGP and
who has reassigned to the NPPGP his or
her right to receive Medicare payment.
Member of the TGP or TGP member
means a therapist who is an owner or
employee of a TGP and who has
reassigned to the TGP his or her right to
receive Medicare payment.
*
*
*
*
*
NPPGP means an entity that is
enrolled in Medicare as a group
practice, includes at least one owner or
employee who is a nonphysician
practitioner, does not include a
physician owner or employee, and has
a valid and active TIN.
*
*
*
*
*
Provider of outpatient therapy
services means an entity that is enrolled
in Medicare as a provider of therapy
services and furnishes one or more of
the following:
(1) Outpatient physical therapy
services as defined in § 410.60 of this
chapter.
(2) Outpatient occupational therapy
services as defined in § 410.59 of this
chapter.
(3) Outpatient speech-language
pathology services as defined in
§ 410.62 of this chapter.
*
*
*
*
*
TGP means an entity that is enrolled
in Medicare as a therapy group in
private practice, includes at least one
owner or employee who is a therapist in
private practice, does not include an
owner or employee who is a physician
or nonphysician practitioner, and has a
valid and active TIN.
*
*
*
*
*
■ 4. Section 510.110 is added to subpart
B, effective July 1, 2017, to read as
follows:
§ 510.120 CJR participant hospital CEHRT
track requirements.
Access to records and retention.
Participant hospitals, CJR
collaborators, collaboration agents,
downstream collaboration agents, and
any other individuals or entities
performing CJR activities must do all of
the following:
(a) Allow the Government, including
CMS, OIG, HHS and the Comptroller
General or their designees, scheduled
and unscheduled access to all books,
contracts, records, documents and other
evidence (including data related to
utilization and payments, quality
criteria, billings, lists of CJR
collaborators, sharing arrangements,
distribution arrangements, downstream
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(a) CJR CEHRT use. For performance
years 2 through 5, CJR participant
hospitals choose either of the following:
(1) CEHRT use. Participant hospitals
attest in a form and manner specified by
CMS to their use of CEHRT as defined
in § 414.1305 of this chapter to
document and communicate clinical
care with patients and other health
professionals.
(2) No CEHRT use. Participant
hospitals do not attest in a form and
manner specified by CMS to their use of
CEHRT as defined in § 414.1305 of this
chapter to document and communicate
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clinical care with patients and other
health professionals.
(b) Clinician financial arrangements
list. Each participant hospital that
chooses CEHRT use as provided in
paragraph (a)(1) of this section must
submit to CMS a clinician financial
arrangements list in a form and manner
specified by CMS on a no more than
quarterly basis. The list must include
the following information on
individuals and entities for the period of
the CJR performance year specified by
CMS:
(1) CJR collaborators. For each
physician, nonphysician practitioner, or
therapist in private practice who is a
CJR collaborator during the period of the
CJR performance year specified by CMS:
(i) The name, TIN, and NPI of the CJR
collaborator.
(ii) The start date and, if applicable,
end date, for the sharing arrangement
between the CJR participant hospital
and the CJR collaborator.
(2) Practice collaboration agents. For
each physician, nonphysician
practitioner, or therapist who is a
practice collaboration agent during the
period of the CJR performance year
specified by CMS:
(i) The name and TIN of the CJR
collaborator and the name, TIN, and NPI
of the practice collaboration agent.
(ii) The start date and, if applicable,
end date, for the distribution
arrangement between the CJR
collaborator and the practice
collaboration agent.
(3) [Reserved.]
(4) Attestation to no individuals. If
there are no individuals that meet the
requirements to be reported, as specified
in paragraphs (b)(1) through (3) of this
section, the CJR participant hospital
must attest in a form and manner
required by CMS that there are no
individuals to report on the clinician
financial arrangements list.
(c) Documentation requirements. (1)
Each CJR participant hospital that
chooses CEHRT use as provided in
paragraph (a)(1) of this section must
maintain documentation of their
attestation to CEHRT use and clinician
financial arrangements lists.
(2) [Reserved.]
■ 6. Section 510.120 is amended,
effective July 1, 2017, by revising
paragraph (b)(2) and by adding
paragraphs (b)(3) and (c)(2) to read as
follows:
§ 510.120 CJR participant hospital CEHRT
track requirements.
*
*
*
*
*
(b) * * *
(2) Collaboration agents. For each
physician, nonphysician practitioner, or
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therapist who is a collaboration agent
during the period of the CJR
performance year specified by CMS:
(i) The name and TIN of the CJR
collaborator and the name, TIN, and NPI
of the collaboration agent.
(ii) The start date and, if applicable,
end date, for the distribution
arrangement between the CJR
collaborator and the collaboration agent.
(3) Downstream collaboration agents.
For each physician, nonphysician
practitioner, or therapist who is a
downstream collaboration agent during
the period of the CJR performance year
specified by CMS—
(i) The name and TIN of the CJR
collaborator and the name and TIN of
the collaboration agent and the name,
TIN, and NPI of the downstream
collaboration agent.
(ii) The start date and, if applicable,
end date, for the downstream
distribution arrangement between the
collaboration agent and the downstream
collaboration agent.
*
*
*
*
*
(c) * * *
(2) The CJR participant hospital must
retain and provide access to the
required documentation in accordance
with § 510.110.
■ 7. Section 510.205 is amended by
adding paragraph (a)(6) to read as
follows:
asabaliauskas on DSK3SPTVN1PROD with RULES
§ 510.205
Beneficiary inclusion criteria.
(a) * * *
(6) For episodes beginning on or after
July 1, 2017, are not prospectively
assigned to—
(i) An ACO in the Next Generation
ACO model;
(ii) An ACO in a track of the
Comprehensive ESRD Care Model
incorporating downside risk for
financial losses; or
(iii) A Shared Savings Program ACO
in Track 3.
*
*
*
*
*
■ 8. Section 510.300 is amended by—
■ a. Revising the section heading;
■ b. Revising paragraphs (a)
introductory text and (a)(1) through (3);
■ c. Redesignating paragraph (a)(5) as
paragraph (a)(6);
■ d. Adding a new paragraph (a)(5);
■ e. Revising the paragraph (b) subject
heading and revising paragraphs (b)(1)
introductory text and (b)(3), (5), and (7);
■ f. Adding paragraph (b)(8); and
■ g. Revising paragraph (c).
The revisions and additions read as
follows:
§ 510.300 Determination of episode
quality-adjusted target prices.
(a) General. CMS establishes episode
quality-adjusted target prices for
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participant hospitals for each
performance year of the model as
specified in this section. Episode
quality-adjusted target prices are
established according to the following:
(1) MS–DRG and fracture status. MS–
DRG assigned at discharge for anchor
hospitalization and present of hip
fracture diagnosis for anchor
hospitalization—
(i) MS–DRG 469 with hip fracture;
(ii) MS–DRG 469 without hip fracture;
(iii) MS–DRG 470 with hip fracture; or
(iv) MS–DRG 470 without hip
fracture.
(2) Applicable time period for
performance year episode qualityadjusted target prices. Episode qualityadjusted target prices are updated to
account for Medicare payment updates
no less than 2 times per year, for
updated quality-adjusted target prices
effective October 1 and January 1, and
at other intervals if necessary.
(3) Episodes that straddle
performance years or payment updates.
The quality-adjusted target price that
applies to the type of episode as of the
date of admission for the anchor
hospitalization is the quality-adjusted
target price that applies to the episode.
*
*
*
*
*
(5) Quality performance. Qualityadjusted target prices reflect effective
discount factors or applicable discount
factors based on a hospital’s composite
quality score, as specified in
§§ 510.300(c) and 510.315(f).
*
*
*
*
*
(b) Episode quality-adjusted target
price. (1) CMS calculates qualityadjusted target prices based on a blend
of each participant hospital’s hospitalspecific and regional episode
expenditures. The region corresponds to
the U.S. Census Division associated
with the primary address of the CCN of
the participant hospital and the regional
component is based on all hospitals in
said region, except as follows. In cases
where an MSA selected for participation
in CJR spans more than one U.S. Census
Division, the entire MSA will be
grouped into the U.S. Census Division
where the largest city by population in
the MSA is located for quality-adjusted
target price and reconciliation
calculations. The calendar years used
for historical expenditure calculations
are as follows:
*
*
*
*
*
(3) Exception for low-volume
hospitals. Quality-adjusted target prices
for participant hospitals with fewer than
20 CJR episodes in total across the 3
historical years of data used to calculate
the quality-adjusted target price are
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613
based on 100 percent regional historical
episode payments.
*
*
*
*
*
(5) Exception for high episode
spending. Episode payments are capped
at 2 standard deviations above the mean
regional episode payment for both the
hospital-specific and regional
components of the quality-adjusted
target price.
*
*
*
*
*
(7) Communication of episode
quality-adjusted target prices. CMS
communicates episode quality-adjusted
target prices to participant hospitals
before the performance period in which
they apply.
(8) Inclusion of reconciliation
payments and repayments. For
performance years 3, 4, and 5 only,
reconciliation payments and repayment
amounts under § 510.305(f)(2) and (f)(3)
and from LEJR episodes included in the
BPCI initiative are included in historical
episode payments.
(c) Discount factor. A participant
hospital’s episode quality-adjusted
target prices incorporate discount
factors to reflect Medicare’s portion of
reduced expenditures from the CJR
model as described in this section.
(1) Discount factors affected by the
quality incentive payments and the
composite quality score. In all
performance years, the discount factor
may be affected by the quality incentive
payment and composite quality score as
provided in § 510.315 to create the
effective discount factor or applicable
discount factor used for calculating
reconciliation payments and repayment
amounts. The quality-adjusted target
prices incorporate the effective or
applicable discount factor at
reconciliation.
(2) Discount factor for reconciliation
payments. The discount factor for
reconciliation payments in all
performance years is 3.0 percent.
(3) Discount factors for repayment
amounts. The discount factor for
repayment amounts is—
(i) Not applicable in performance year
1, as the requirement for hospital
repayment under the CJR model is
waived in performance year 1;
(ii) In performance years 2 and 3, 2.0
percent; and
(iii) In performance years 4 and 5, 3.0
percent.
*
*
*
*
*
■ 9. Section 510.305 is amended by—
■ a. Revising paragraphs (e)
introductory text, (e)(1)(ii) and (v),
(f)(1)(i) and (ii), (f)(2), (g)(2), and (h)(6);
■ b. Adding paragraph (h)(7);
■ c. Revising paragraph (i); and
■ d. Adding paragraph (j).
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The revisions and additions read as
follows:
§ 510.305 Determination of the NPRA and
reconciliation process.
asabaliauskas on DSK3SPTVN1PROD with RULES
*
*
*
*
*
(e) Calculation of the NPRA. By
comparing the quality-adjusted target
prices described in § 510.300 and the
participant hospital’s actual episode
spending for the performance year and
applying the adjustments in paragraph
(e)(1)(v) of this section, CMS establishes
an NPRA for each participant hospital
for each performance year.
(1) * * *
(ii) Multiplies each episode qualityadjusted target price by the number of
episodes included in the performance
year (other than episodes that have been
canceled in accordance with
§ 510.210(b)) to which that episode
quality-adjusted target price applies.
*
*
*
*
*
(v) Applies the following prior to
determination of the reconciliation
payment or repayment amount:
(A) Limitation on loss. Except as
provided in paragraph (e)(1)(v)(C) of this
section, the total amount of the NPRA
and subsequent reconciliation
calculation for a performance year
cannot exceed the following:
(1) For performance year 2 only, 5
percent of the amount calculated in
paragraph (e)(1)(iii) of this section for
the performance year.
(2) For performance year 3, 10 percent
of the amount calculated in paragraph
(e)(1)(iii) of this section for the
performance year.
(3) For performance years 4 and 5, 20
percent of the amount calculated in
paragraph (e)(1)(iii) of this section for
the performance year.
(4) As provided in paragraph (i) of
this section, the subsequent
reconciliation calculation reassesses the
limitation on loss for a given
performance year by applying the
limitations on loss to the aggregate of
the 2 reconciliation calculations.
(5) The post-episode spending and
ACO overlap calculation amounts in
paragraphs (j)(1) and (2) of this section
are not subject to the limitation on loss.
(B) Limitation on gain. The total
amount of the NPRA and subsequent
reconciliation calculation for a
performance year cannot exceed the
following:
(1) For performance years 1 and 2, 5
percent of the amount calculated in
paragraph (e)(1)(iii) of this section for
the performance year.
(2) For performance year 3, 10 percent
of the amount calculated in paragraph
(e)(1)(iii) of this section for the
performance year.
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(3) For performance years 4 and 5, 20
percent of the amount calculated in
paragraph (e)(1)(iii) of this section for
the performance year.
(4) As provided in paragraph (i) of
this section, the subsequent
reconciliation calculation reassesses the
limitation on gain for a given
performance year by applying the
limitations on gain to the aggregate of
the 2 reconciliation calculations.
(5) The post-episode spending and
ACO overlap calculation amounts in
paragraphs (j)(1) and (j)(2) of this section
are not subject to the limitation on gain.
(C) Financial loss limits for rural
hospitals, SCHs, MDHs, and RRCs. If a
participant hospital is a rural hospital,
SCH, MDH, or RRC, then for
performance year 2, the total repayment
amount for which the participant
hospital is responsible due to the NPRA
and subsequent reconciliation
calculation cannot exceed 3 percent of
the amount calculated in paragraph
(e)(1)(iii) of this section. For
performance years 3 through 5, the
amount cannot exceed 5 percent of the
amount calculated in paragraph
(e)(1)(iii) of this section.
(f) * * *
(1) * * *
(i) Subject to paragraph (f)(1)(iii) of
this section, for performance year 1, the
reconciliation payment (if any) is equal
to the NPRA.
(ii) Subject to paragraph (f)(1)(iii) of
this section, for performance years 2
through 5, results from the subsequent
reconciliation calculation for a prior
year’s reconciliation as described in
paragraph (i) of this section and the
post-episode spending and ACO overlap
calculations as described in paragraph
(j) of this section are added to the
current year’s NPRA in order to
determine the reconciliation payment or
repayment amount.
*
*
*
*
*
(2) Reconciliation payment. If the
amount described in paragraph (f)(1) of
this section is positive and the
composite quality score described in
§ 510.315 is acceptable (defined as
greater than or equal to 5.00 and less
than 6.9), good (defined as greater than
or equal to 6.9 and less than or equal to
15.0), or excellent (defined as greater
than 15.0), Medicare pays the
participant hospital a reconciliation
payment in an amount equal to the
amount described in paragraph (f)(1) of
this section.
*
*
*
*
*
(g) * * *
(2) If the hospital’s composite quality
score described in § 510.315 is
acceptable (defined as greater than or
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equal to 5.00 and less than 6.9), good
(defined as greater than or equal to 6.9
and less than or equal to 15.0), or
excellent (defined as greater than 15.0),
and the hospital is determined to have
a positive NPRA under § 510.305(e)), the
hospital is eligible for a reconciliation
payment.
*
*
*
*
*
(h) * * *
(6) The post-episode spending amount
and ACO overlap calculation for the
previous performance year, as
applicable.
(7) The reconciliation payment or
repayment amount.
(i) Subsequent reconciliation
calculation. (1) Fourteen months after
the end of each performance year, CMS
performs an additional calculation,
using claims data available at that time,
to account for final claims run-out and
any additional episode cancelations due
to overlap between the CJR model and
other CMS models and programs, or for
other reasons as specified in
§ 510.210(b).
(2) The subsequent calculation for
performance years 1 through 4 occurs
concurrently with the first
reconciliation process for the following
performance year. If the result of the
subsequent calculation is different than
zero, CMS applies the stop-loss and
stop-gain limits in paragraph (e) of this
section to the aggregate calculation of
the amounts described in paragraphs
(e)(1)(iv) and (i)(1) of this section for
that performance year (the initial
reconciliation and the subsequent
reconciliation calculation) to ensure
such amount does not exceed the
applicable stop-loss or stop-gain limits.
Because there will be no additional
performance year after performance year
5, the subsequent reconciliation
calculation for performance year 5 will
occur independently in 2022.
(j) Additional adjustments to the
reconciliation payment or repayment
amount. (1) In order to account for
shared savings payments, CMS will
reduce the reconciliation payment or
increase the repayment amount for the
subsequent performance year (for years
1 through 4) by the amount of the
participant hospital’s discount
percentage that is paid to the ACO in
the prior performance year as shared
savings. (This amount will be assessed
independently for performance year 5 in
2022.) This adjustment is made only
when the participant hospital is a
participant or provider/supplier in the
ACO and the beneficiary in the CJR
episode is assigned to one of the
following ACO models or programs:
(i) The Pioneer ACO model.
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(ii) The Medicare Shared Savings
Program (excluding Track 3 for CJR
episodes that initiate on or after July 1,
2017).
(iii) The Comprehensive ESRD Care
Initiative (excluding a track with
downside risk for CJR episodes that
initiate after July 1, 2017).
(iv) The Next Generation ACO model
(excluding CJR episodes that initiate on
or after July 1, 2017).
(2) Increases in post-episode
spending. If the average post-episode
Medicare Parts A and B payments for a
participant hospital in the prior
performance year is greater than 3
standard deviations above the regional
average post-episode payments for the
same performance year, then the
spending amount exceeding 3 standard
deviations above the regional average
post-episode payments for the same
performance year is subtracted from the
net reconciliation or added to the
repayment amount for the subsequent
performance year for years 1 through 4,
and assessed independently for year 5.
■ 10. Section 510.310 is amended by—
■ a. Revising paragraphs (a)
introductory text and (a)(1) and (2);
■ b. Removing paragraph (a)(3);
■ c. Redesignating paragraph (a)(4) as
paragraph (a)(3);
■ d. Adding a new paragraph (a)(4);
■ e. Revising paragraph (c);
■ f. Redesignating paragraph (d) as
paragraph (e);
■ g. Adding a new paragraph (d); and
■ h. Revising newly designated
paragraph (e)(6).
The revisions and additions read as
follows:
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§ 510.310
Appeals process.
(a) Notice of calculation error (first
level of appeal). Subject to the
limitations on review in subpart D of
this part, if a participant hospital wishes
to dispute calculations involving a
matter related to payment,
reconciliation amounts, repayment
amounts, the use of quality measure
results in determining the composite
quality score, or the application of the
composite quality score during
reconciliation, the participant hospital
is required to provide written notice of
the calculation error, in a form and
manner specified by CMS.
(1) Unless the participant hospital
provides such notice, CMS deems final
the CJR reconciliation report 45
calendar days after it is issued and
proceeds with the payment or
repayment processes as applicable.
(2) If CMS receives a notice of a
calculation error within 45 calendar
days of the issuance of the
reconciliation report, CMS responds in
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writing within 30 calendar days to
either confirm that there was an error in
the calculation or verify that the
calculation is correct, although CMS
reserves the right to an extension upon
written notice to the participant
hospital.
*
*
*
*
*
(4) Only participant hospitals may use
the notice of calculation error process
described in this part.
*
*
*
*
*
(c) Exception to the process. If the
participant hospital contests a matter
that does not involve an issue contained
in, or a calculation that contributes to,
a CJR reconciliation report, a notice of
calculation error is not required. In
these instances, if CMS does not receive
a request for reconsideration from the
participant hospital within 10 calendar
days of the notice of the initial
determination, the initial determination
is deemed final and CMS proceeds with
action indicated in the initial
determination. This does not apply to
the limitations on review in paragraph
(e) of this section.
(d) Notice of a participant hospital’s
termination from the CJR model. If a
participant hospital receives notification
that it has been terminated from the CJR
model, it must provide a written notice
to CMS requesting review of the
termination within 10 calendar days of
the notice. CMS has 30 days to respond
to the participant hospital’s request for
review. If the participant hospital fails
to notify CMS, the termination is
deemed final.
(e) * * *
(6) Decisions about expansion of the
duration and scope of a model under
section 1115A(c) of the Act, including
the determination that a model is not
expected to meet criteria described in
section 1115A(c)(1) or (2) of the Act.
■ 11. Section 510.315 is amended by—
■ a. Revising paragraph (c) introductory
text;
■ b. Redesignating paragraph (c)(1)(ix)
as paragraph (c)(1)(viii);
■ c. Redesignating paragraph (c)(2)(ix)
as paragraph (c)(2)(viii); and
■ d. Revising paragraphs (d) and (f).
The revisions read as follows:
§ 510.315 Composite quality scores for
determining reconciliation payment
eligibility and quality incentive payments.
*
*
*
*
*
(c) Quality performance points. CMS
computes quality performance points
for each quality measure based on the
participant hospital’s performance
relative to the distribution of
performance of all subsection (d)
hospitals that are eligible for payment
under IPPS and meet the minimum
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615
patient case or survey count for that
measure.
*
*
*
*
*
(d) Quality improvement points. For
performance year 1, if a participant
hospital’s quality performance
percentile on an individual measure
described in § 510.400(a) increases from
the corresponding time period in the
previous year by at least 2 deciles on the
performance percentile scale, then the
hospitals is eligible to receive quality
improvement points equal to 10 percent
of the total available point for that
individual measure up to a maximum
composite quality score of 20 points.
For performance years 2 through 5, if a
participant hospital’s quality
performance percentile on an individual
measure described in § 510.400(a)
increases from the previous
performance year by at least 2 deciles on
the performance percentile scale, then
the hospitals is eligible to receive
quality improvement points equal to 10
percent of the total available point for
that individual measure up to a
maximum composite quality score of 20
points.
*
*
*
*
*
(f) Quality incentive payments. CMS
provides incentive payments to
participant hospitals that demonstrate
good or excellent quality performance
on the composite quality scores
described in paragraph (b) of this
section. These incentive payments are
implemented in the form of the
following reductions to the effective
discount factors or applicable discount
factors described in § 510.300(c):
(1) A 1.0 percentage point reduction
to the effective discount factor or
applicable discount factor for
participant hospitals with good quality
performance, defined as composite
quality scores that are greater than or
equal to 6.9 and less than or equal to
15.0.
(2) A 1.5 percentage point reduction
to the effective discount factor or
applicable discount factor for
participant hospitals with excellent
quality performance, defined as
composite quality scores that are greater
than 15.0.
■ 12. Section 510.400 is amended by
revising paragraph (c)(3) to read as
follows:
§ 510.400
Quality measures and reporting.
*
*
*
*
*
(c) * * *
(3) Does not publicly report the
voluntary patient-reported outcomes
and limited risk variable data during
this model, but indicates whether a
hospital has successfully submitted
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such data in accordance with
§ 510.400(b).
■ 13. Section 510.405 is amended by
revising paragraph (a)(1) and (b) to read
as follows:
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§ 510.405 Beneficiary choice and
beneficiary notification.
(a) * * *
(1) As part of discharge planning and
referral, participant hospitals must
provide a complete list of HHAs, SNFs,
IRFs, or LTCHs that are participating in
the Medicare program, and that serve
the geographic area (as defined by the
HHA) in which the patient resides, or in
the case of a SNF, IRF, or LTCH, in the
geographic area requested by the
patient.
(i) This list must be presented to CJR
beneficiaries for whom home health
care, SNF, IRF, or LTCH services are
medically necessary.
(ii) Participant hospitals must specify
on the list those post-acute care
providers on the list with whom they
have a sharing arrangement.
(iii) Participant hospitals may
recommend preferred providers and
suppliers, consistent with applicable
statutes and regulations.
(iv) Participant hospitals may not
limit beneficiary choice to any list of
providers or suppliers in any manner
other than that permitted under
applicable statutes and regulations.
(v) Participant hospitals must take
into account patient and family
preferences when they are expressed.
*
*
*
*
*
(b) Required beneficiary notification—
(1) Participant hospital detailed
notification. Each participant hospital
must provide written notification to any
Medicare beneficiary that meets the
criteria in § 510.205 of his or her
inclusion in the CJR model. The
notification must be provided upon
admission to the participant hospital if
the admission that initiates the CJR
episode is not scheduled with the
participant hospital in advance. If the
admission is scheduled in advance, then
the participant hospital must provide
notice as soon as the admission is
scheduled. In circumstances where, due
to the patient’s condition, it is not
feasible to provide notification at such
times, the notification must be provided
to the beneficiary or his or her
representative as soon as is reasonably
practicable but no later than discharge
from the participant hospital
accountable for the CJR episode. The
beneficiary notification must contain all
of the following:
(i) A detailed explanation of the
model and how it might be expected to
affect the beneficiary’s care.
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(ii) Notification that the beneficiary
retains freedom of choice to choose
providers and services.
(iii) Explanation of how patients can
access care records and claims data
through an available patient portal, and
how they can share access to their Blue
Button® electronic health information
with caregivers.
(iv) A statement that all existing
Medicare beneficiary protections
continue to be available to the
beneficiary. These include the ability to
report concerns of substandard care to
Quality Improvement Organizations or
the 1–800–MEDICARE helpline.
(v) A list of the providers, suppliers,
and ACOs with whom the CJR
participant hospital has a sharing
arrangement. This requirement may be
fulfilled by the participant hospital
including in the detailed notification a
Web address where beneficiaries may
access the list.
(2) CJR collaborator notice. A
participant hospital must require every
CJR collaborator to provide written
notice to applicable CJR beneficiaries of
the structure of the CJR model and the
existence of its sharing arrangement
with the participant hospital.
(i) A CJR participant hospital must
require every CJR collaborator (other
than PGPs) that furnishes an item or
service to a CJR beneficiary during a CJR
episode to provide written notice to the
beneficiary of the structure of the model
and the existence of the individual’s or
entity’s sharing arrangement. The notice
must be provided no later than the time
at which the beneficiary first receives an
item or service from the CJR collaborator
during a CJR episode. In circumstances
where, due to the patient’s condition, it
is not feasible to provide notification at
such time, the notification must be
provided to the beneficiary or his or her
representative as soon as is reasonably
practicable.
(ii) A participant hospital must
require every PGP that is a CJR
collaborator where a member of the PGP
furnishes an item or service to a CJR
beneficiary during a CJR episode to
provide written notice to the beneficiary
of the structure of the model and the
existence of the entity’s sharing
arrangement under the model. The
notice must be provided no later than
the time at which the beneficiary first
receives an item or service from any
member of the PGP, and the required
PGP notice may be provided by that
member. In circumstances where, due to
the patient’s condition, it is not feasible
to provide notice at such times, the
notice must be provided to the
beneficiary or his or her representative
as soon as is reasonably practicable.
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(3) Discharge planning notice. A
participant hospital must provide the
beneficiary with a written notice of any
potential financial liability associated
with non-covered services
recommended or presented as an option
as part of discharge planning, no later
than the time that the beneficiary
discusses a particular post-acute care
option or at the time the beneficiary is
discharged, whichever occurs earlier.
(i) If the participant hospital knows or
should have known that the beneficiary
is considering or has decided to receive
a non-covered post-acute care service or
other non-covered associated service or
supply, the participant hospital must
notify the beneficiary that the service
would not be covered by Medicare.
(ii) If the participant hospital is
discharging a beneficiary to a SNF prior
to the occurrence of a 3-day hospital
stay, and the beneficiary is being
transferred to or is considering a SNF
that would not qualify under the SNF 3day waiver in § 510.610, the participant
hospital must notify the beneficiary in
accordance with paragraph (b)(3)(i) of
this section that the beneficiary will be
responsible for payment for the services
furnished by the SNF during that stay,
except those services that would be
covered by Medicare Part B during a
non-covered inpatient SNF stay.
■ 14. Section 510.405 is further
amended, effective July 1, 2017, by
revising paragraphs (b)(1) and (2) and
adding paragraph (b)(4) to read as
follows:
§ 510.405 Beneficiary choice and
beneficiary notification.
*
*
*
*
*
(b) * * *
(1) Participant hospital detailed
notification. Each participant hospital
must provide written notification to any
Medicare beneficiary that meets the
criteria in § 510.205 of his or her
inclusion in the CJR model. The
notification must be provided upon
admission to the participant hospital if
the admission that initiates the CJR
episode is not scheduled with the
participant hospital in advance. If the
admission is scheduled in advance, then
the participant hospital must provide
notice as soon as the admission is
scheduled. In circumstances where, due
to the patient’s condition, it is not
feasible to provide notification at such
times, the notification must be provided
to the beneficiary or his or her
representative as soon as is reasonably
practicable but no later than discharge
from the participant hospital
accountable for the CJR episode. The
participant hospital must be able to
generate a list of all beneficiaries
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receiving such notification, including
the date on which the notification was
provided to the beneficiary, to CMS or
its designee upon request. The
beneficiary notification must contain all
of the following:
(i) A detailed explanation of the
model and how it might be expected to
affect the beneficiary’s care.
(ii) Notification that the beneficiary
retains freedom of choice to choose
providers and services.
(iii) Explanation of how patients can
access care records and claims data
through an available patient portal, and
how they can share access to their Blue
Button® electronic health information
with caregivers.
(iv) A statement that all existing
Medicare beneficiary protections
continue to be available to the
beneficiary. These include the ability to
report concerns of substandard care to
Quality Improvement Organizations or
the 1–800–MEDICARE helpline.
(v) A list of the providers, suppliers,
and ACOs with whom the CJR
participant hospital has a sharing
arrangement. This requirement may be
fulfilled by the participant hospital
including in the detailed notification a
Web address where beneficiaries may
access the list.
(2) CJR collaborator notice. A
participant hospital must require every
CJR collaborator to provide written
notice to applicable CJR beneficiaries of
the structure of the CJR model and the
existence of its sharing arrangement
with the participant hospital.
(i) With the exception of ACOs, PGPs,
NPPGPs, and TGPs, a CJR participant
hospital must require every CJR
collaborator that furnishes an item or
service to a CJR beneficiary during a CJR
episode to provide written notice to the
beneficiary of the structure of the model
and the existence of the individual’s or
entity’s sharing arrangement. The notice
must be provided no later than the time
at which the beneficiary first receives an
item or service from the CJR collaborator
during a CJR episode. In circumstances
where, due to the patient’s condition, it
is not feasible to provide notification at
such time, the notification must be
provided to the beneficiary or his or her
representative as soon as is reasonably
practicable. The CJR collaborator must
be able to generate a list of all
beneficiaries who received such a
notice, including the date on which the
notice was provided to the beneficiary,
to CMS upon request.
(ii) A participant hospital must
require every PGP, NPPGP, or TGP that
is a CJR collaborator where a member of
the PGP, member of the NPPGP, or
member of the TGP furnishes an item or
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service to a CJR beneficiary during a CJR
episode to provide written notice to the
beneficiary of the structure of the model
and the existence of the entity’s sharing
arrangement. The notice must be
provided no later than the time at which
the beneficiary first receives an item or
service from any member of the PGP,
member of the NPPGP, or member of the
TGP, and the required PGP, NPPGP, or
TGP notice may be provided by that
member respectively. In circumstances
where, due to the patient’s condition, it
is not feasible to provide notice at such
times, the notice must be provided to
the beneficiary or his or her
representative as soon as is reasonably
practicable. The PGP, NPPGP, or TGP
must be able to generate a list of all
beneficiaries who received such a
notice, including the date on which the
notice was provided to the beneficiary,
to CMS upon request.
(iii) A participant hospital must
require every ACO that is a CJR
collaborator where an ACO participant
or ACO provider/supplier furnishes an
item or service to a CJR beneficiary
during a CJR episode to provide written
notice to the beneficiary of the structure
of the model and the existence of the
entity’s sharing arrangement. The notice
must be provided no later than the time
at which the beneficiary first receives an
item or service from any ACO
participant or ACO provider/supplier
and the required ACO notice may be
provided by that ACO participant or
ACO provider/supplier respectively. In
circumstances where, due to the
patient’s condition, it is not feasible to
provide notice at such times, the notice
must be provided to the beneficiary or
his or her representative as soon as is
reasonably practicable. The ACO must
be able to generate a list of all
beneficiaries who received such a
notice, including the date on which the
notice was provided to the beneficiary,
to CMS upon request.
*
*
*
*
*
(4) Access to records and retention.
Lists of beneficiaries that receive
notifications or notices must be
retained, and access provided to CMS,
or its designees, in accordance with
§ 510.110.
■ 15. Section 510.410 is amended,
effective July 1, 2017, by revising
paragraphs (b)(1) introductory text,
(b)(1)(i) introductory text, (b)(1)(i)(F),
(b)(1)(ii), (b)(2)(i) through (v), and (b)(3)
to read as follows:
§ 510.410
Compliance enforcement.
*
*
*
*
*
(b) * * *
(1) CMS may take one or more of the
remedial actions set forth in paragraph
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617
(b)(2) of this section if a participant
hospital or its related CJR collaborators,
collaboration agents, or downstream
collaboration agents—
(i) Fails to comply with any
requirements of this part or is identified
as noncompliant through monitoring by
HHS (including CMS and OIG) of the
CJR model, including but not limited to
the following:
*
*
*
*
*
(F) Failing to follow the requirements
related to sharing arrangements.
(ii) Has signed a sharing arrangement,
distribution arrangement, or
downstream distribution arrangement
that is noncompliant with the
requirements of this part.
*
*
*
*
*
(2) * * *
(i) Issuing a warning letter to the
participant hospital.
(ii) Requiring the participant hospital
to develop a corrective action plan,
commonly referred to as a CAP.
(iii) Reducing or eliminating a
participant hospital’s reconciliation
payment.
(iv) Requiring a participant hospital to
terminate a sharing arrangement with a
CJR collaborator and prohibiting further
engagement in sharing arrangements
with the participant hospital by that CJR
collaborator.
(v) Terminating the participant
hospital’s participation in the CJR
model. Where a participant is
terminated from the CJR model, the
participant hospital will remain liable
for all negative NPRA generated from
episodes of care that ended prior to
termination.
(3) CMS may add a 25 percent penalty
to a repayment amount on the
participant hospital’s reconciliation
report if all of the following conditions
are met:
(i) CMS has required a corrective
action plan from a participant hospital;
(ii) The participant hospital owes a
repayment amount to CMS; and
(iii) The participant hospital fails to
timely comply with the corrective
action plan or is noncompliant with the
CJR model’s requirements.
■ 16. Section 510.500 is revised,
effective July 1, 2017, to read as follows:
§ 510.500 Sharing arrangements under the
CJR model.
(a) General. (1) A participant hospital
may enter into a sharing arrangement
with a CJR collaborator to make a
gainsharing payment, or to receive an
alignment payment, or both. A
participant hospital must not make a
gainsharing payment or receive an
alignment payment except in
accordance with a sharing arrangement.
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(2) A sharing arrangement must
comply with the provisions of this
section and all other applicable laws
and regulations, including the
applicable fraud and abuse laws and all
applicable payment and coverage
requirements.
(3) Participant hospitals must
develop, maintain, and use a set of
written policies for selecting individuals
and entities to be CJR collaborators.
These policies must contain criteria
related to, and inclusive of, the quality
of care delivered by the potential CJR
collaborator. The selection criteria
cannot be based directly or indirectly on
the volume or value of past or
anticipated referrals or business
otherwise generated by, between or
among the participant hospital, any CJR
collaborator, any collaboration agent,
any downstream collaboration agent, or
any individual or entity affiliated with
a participant hospital, CJR collaborator,
collaboration agent, or downstream
collaboration agent. A selection
criterion that considers whether a
potential CJR collaborator has
performed a reasonable minimum
number of services that would qualify as
CJR activities will be deemed not to
violate the volume or value standard if
the purpose of the criterion is to ensure
the quality of care furnished to CJR
beneficiaries.
(4) If a participant hospital enters into
a sharing arrangement, its compliance
program must include oversight of
sharing arrangements and compliance
with the applicable requirements of the
CJR model.
(b) Requirements. (1) A sharing
arrangement must be in writing and
signed by the parties, and entered into
before care is furnished to CJR
beneficiaries under the sharing
arrangement.
(2) Participation in a sharing
arrangement must be voluntary and
without penalty for nonparticipation.
(3) The sharing arrangement must
require the CJR collaborator and its
employees, contractors (including
collaboration agents), and
subcontractors (including downstream
collaboration agents) to comply with all
of the following:
(i) The applicable provisions of this
part (including requirements regarding
beneficiary notifications, access to
records, record retention, and
participation in any evaluation,
monitoring, compliance, and
enforcement activities performed by
CMS or its designees).
(ii) All applicable Medicare provider
enrollment requirements at § 424.500 of
this chapter, including having a valid
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and active TIN or NPI, during the term
of the sharing arrangement.
(iii) All other applicable laws and
regulations.
(4) The sharing arrangement must
require the CJR collaborator to have or
be covered by a compliance program
that includes oversight of the sharing
arrangement and compliance with the
requirements of the CJR model that
apply to its role as a CJR collaborator,
including any distribution
arrangements.
(5) The sharing arrangement must not
pose a risk to beneficiary access,
beneficiary freedom of choice, or quality
of care.
(6) The board or other governing body
of the participant hospital must have
responsibility for overseeing the
participant hospital’s participation in
the CJR model, its arrangements with
CJR collaborators, its payment of
gainsharing payments, its receipt of
alignment payments, and its use of
beneficiary incentives in the CJR model.
(7) The written agreement
memorializing a sharing arrangement
must specify the following:
(i) The purpose and scope of the
sharing arrangement.
(ii) The obligations of the parties,
including specified CJR activities and
other services to be performed by the
parties under the sharing arrangement.
(iii) The date of the sharing
arrangement.
(iv) The financial or economic terms
for payment, including the following:
(A) Eligibility criteria for a
gainsharing payment.
(B) Eligibility criteria for an alignment
payment.
(C) Frequency of gainsharing or
alignment payment.
(D) Methodology and accounting
formula for determining the amount of
a gainsharing payment or alignment
payment.
(8) The sharing arrangement must
not—
(i) Induce the participant hospital,
CJR collaborator, or any employees,
contractors, or subcontractors of the
participant hospital or CJR collaborator
to reduce or limit medically necessary
services to any Medicare beneficiary; or
(ii) Restrict the ability of a CJR
collaborator to make decisions in the
best interests of its patients, including
the selection of devices, supplies, and
treatments.
(c) Gainsharing payment, alignment
payment, and internal cost savings
conditions and restrictions. (1)
Gainsharing payments, if any, must—
(i) Be derived solely from
reconciliation payments, or internal cost
savings, or both;
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(ii) Be distributed on an annual basis
(not more than once per calendar year);
(iii) Not be a loan, advance payment,
or payment for referrals or other
business; and
(iv) Be clearly identified as a
gainsharing payment at the time it is
paid.
(2)(i) To be eligible to receive a
gainsharing payment, a CJR collaborator
must meet quality of care criteria for the
performance year for which the
participant hospital accrued the internal
cost savings or earned the reconciliation
payment that comprises the gainsharing
payment. The quality of care criteria
must be established by the participant
hospital and directly related to the CJR
episode.
(ii) To be eligible to receive a
gainsharing payment, or to be required
to make an alignment payment, a CJR
collaborator other than ACO, PGP,
NPPGP, or TGP must have directly
furnished a billable item or service to a
CJR beneficiary during a CJR episode
that occurred in the same performance
year for which the participant hospital
accrued the internal cost savings or
earned the reconciliation payment that
comprises the gainsharing payment or
was assessed a repayment amount.
(iii) To be eligible to receive a
gainsharing payment, or to be required
to make an alignment payment, a CJR
collaborator that is a PGP, NPPGP, or
TGP must meet the following criteria:
(A) The PGP, NPPGP, or TGP must
have billed for an item or service that
was rendered by one or more PGP
member, NPPGP member, or TGP
member respectively to a CJR
beneficiary during a CJR episode that
occurred during the same performance
year for which the participant hospital
accrued the internal cost savings or
earned the reconciliation payment that
comprises the gainsharing payment or
was assessed a repayment amount.
(B) The PGP, NPPGP, or TGP must
have contributed to CJR activities and
been clinically involved in the care of
CJR beneficiaries during the same
performance year for which the CJR
participant hospital accrued the internal
cost savings or earned the reconciliation
payment that comprises the gainsharing
payment or was assessed a repayment
amount. For example, a PGP, NPPGP, or
TGP might have been clinically
involved in the care of CJR beneficiaries
by—
(1) Providing care coordination
services to beneficiaries during and/or
after inpatient admission;
(2) Engaging with a participant
hospital in care redesign strategies, and
actually performing a role in
implementing such strategies, that are
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designed to improve the quality of care
for CJR episodes and reduce CJR episode
spending; or
(3) In coordination with other
providers and suppliers (such as PGP
members, NPPGP members, or TGP
members; the participant hospital; and
post-acute care providers),
implementing strategies designed to
address and manage the comorbidities
of CJR beneficiaries.
(iv) To be eligible to receive a
gainsharing payment, or to be required
to make an alignment payment, a CJR
collaborator that is an ACO must meet
the following criteria:
(A) The ACO must have had an ACO
provider/supplier that directly
furnished, or an ACO participant that
billed for, an item or service that was
rendered to a CJR beneficiary during a
CJR episode that occurred during the
same performance year for which the
participant hospital accrued the internal
cost savings or earned the reconciliation
payment that comprises the gainsharing
payment or was assessed a repayment
amount; and
(B) The ACO must have contributed to
CJR activities and been clinically
involved in the care of CJR beneficiaries
during the same performance year for
which the participant hospital accrued
the internal cost savings or earned the
reconciliation payment that comprises
the gainsharing payment or was
assessed the repayment amount. For
example, an ACO might be have been
clinically involved in the care of CJR
beneficiaries by—
(1) Providing care coordination
services to CJR beneficiaries during and/
or after inpatient admission;
(2) Engaging with a participant
hospital in care redesign strategies, and
actually performing a role in
implementing such strategies, that are
designed to improve the quality of care
and reduce spending for CJR episodes;
or
(3) In coordination with providers and
suppliers (such as ACO participants,
ACO providers/suppliers, the
participant hospital, and post-acute care
providers), implementing strategies
designed to address and manage the
comorbidities of CJR beneficiaries.
(3)(i) The methodology for accruing,
calculating and verifying internal cost
savings must be transparent,
measurable, and verifiable in
accordance with generally accepted
accounting principles (GAAP) and
Government Auditing Standards (The
Yellow Book).
(ii) The methodology used to calculate
internal cost savings must reflect the
actual, internal cost savings achieved by
the participant hospital through the
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documented implementation of CJR
activities identified by the participant
hospital and must exclude—
(A) Any savings realized by any
individual or entity that is not the
participant hospital; and
(B) ‘‘Paper’’ savings from accounting
conventions or past investment in fixed
costs.
(4) The total amount of a gainsharing
payment for a performance year paid to
a CJR collaborator must not exceed the
following:
(i) In the case of a CJR collaborator
who is a physician or nonphysician
practitioner, 50 percent of the Medicareapproved amounts under the PFS for
items and services furnished by that
physician or nonphysician practitioner
to the participant hospital’s CJR
beneficiaries during CJR episodes that
occurred during the same performance
year for which the participant hospital
accrued the internal cost savings or
earned the reconciliation payment that
comprises the gainsharing payment
being made.
(ii) In the case of a CJR collaborator
that is a PGP or NPPGP, 50 percent of
the Medicare-approved amounts under
the PFS for items and services billed by
that PGP or NPPGP and furnished to the
participant hospital’s CJR beneficiaries
by the PGP members or NPPGP
members respectively during CJR
episodes that occurred during the same
performance year for which the
participant hospital accrued the internal
cost savings or earned the reconciliation
payment that comprises the gainsharing
payment being made.
(5) The amount of any gainsharing
payments must be determined in
accordance with a methodology that is
substantially based on quality of care
and the provision of CJR activities. The
methodology may take into account the
amount of such CJR activities provided
by a CJR collaborator relative to other
CJR collaborators.
(6) For a performance year, the
aggregate amount of all gainsharing
payments that are derived from a
reconciliation payment the CJR
participant hospital receives from CMS
must not exceed the amount of that
reconciliation payment.
(7) No entity or individual, whether a
party to a sharing arrangement or not,
may condition the opportunity to make
or receive gainsharing payments or to
make or receive alignment payments
directly or indirectly on the volume or
value of past or anticipated referrals or
business otherwise generated by,
between or among the participant
hospital, any CJR collaborator, any
collaboration agent, any downstream
collaboration agent, or any individual or
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619
entity affiliated with a participant
hospital, CJR collaborator, collaboration
agent, or downstream collaboration
agent.
(8) A participant hospital must not
make a gainsharing payment to a CJR
collaborator if CMS has notified the
participant hospital that such
collaborator is subject to any action for
noncompliance with this part or the
fraud and abuse laws, or for the
provision of substandard care to CJR
beneficiaries or other integrity
problems.
(9) The sharing arrangement must
require the participant hospital to
recoup any gainsharing payment that
contained funds derived from a CMS
overpayment on a reconciliation report
or was based on the submission of false
or fraudulent data.
(10) Alignment payments from a CJR
collaborator to a participant hospital
may be made at any interval that is
agreed upon by both parties, and must
not be—
(i) Issued, distributed, or paid prior to
the calculation by CMS of a repayment
amount reflected in a reconciliation
report;
(ii) Loans, advance payments, or
payments for referrals or other business;
or
(iii) Assessed by a participant hospital
if it does not owe a repayment amount.
(11) The participant hospital must not
receive any amounts under a sharing
arrangement from a CJR collaborator
that are not alignment payments.
(12) For a performance year, the
aggregate amount of all alignment
payments received by the participant
hospital must not exceed 50 percent of
the participant hospital’s repayment
amount.
(13) The aggregate amount of all
alignment payments from a CJR
collaborator to the participant hospital
may not be greater than—
(i) With respect to a CJR collaborator
other than an ACO, 25 percent of the
participant hospital’s repayment
amount.
(ii) With respect to a CJR collaborator
that is an ACO, 50 percent of the
participant hospital’s repayment
amount.
(14) The amount of any alignment
payments must be determined in
accordance with a methodology that
does not directly account for the volume
or value of past or anticipated referrals
or business otherwise generated by,
between or among the participant
hospital, any CJR collaborator, any
collaboration agent, any downstream
collaboration agent, or any individual or
entity affiliated with a participant
hospital, CJR collaborator, collaboration
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agent, or downstream collaboration
agent.
(15) All gainsharing payments and
any alignment payments must be
administered by the participant hospital
in accordance with generally accepted
accounting principles (GAAP) and
Government Auditing Standards (The
Yellow Book).
(16) All gainsharing payments and
alignment payments must be made by
check, electronic funds transfer, or
another traceable cash transaction.
(d) Documentation requirements. (1)
Participant hospitals must—(i)
Document the sharing arrangement
contemporaneously with the
establishment of the arrangement;
(ii) Publicly post (and update on at
least a quarterly basis) on a Web page
on the CJR participant hospital’s Web
site—
(A) Accurate current and historical
lists of all CJR collaborators, including
CJR collaborator names and addresses.
(B) Written policies for selecting
individuals and entities to be CJR
collaborators required by
§ 510.500(a)(3).
(iii) Maintain and require each CJR
collaborator to maintain
contemporaneous documentation with
respect to the payment or receipt of any
gainsharing payment or alignment
payment that includes at a minimum:
(A) Nature of the payment
(gainsharing payment or alignment
payment);
(B) Identity of the parties making and
receiving the payment;
(C) Date of the payment;
(D) Amount of the payment;
(E) Date and amount of any
recoupment of all or a portion of a CJR
collaborator’s gainsharing payment.
(F) Explanation for each recoupment,
such as whether the CJR collaborator
received a gainsharing payment that
contained funds derived from a CMS
overpayment on a reconciliation report,
or was based on the submission of false
or fraudulent data.
(2) The participant hospital must keep
records of all of the following:
(i) Its process for determining and
verifying its potential and current CJR
collaborators’ eligibility to participate in
Medicare.
(ii) Its plan to track internal cost
savings.
(iii) Information on the accounting
systems used to track internal cost
savings.
(iv) A description of current health
information technology, including
systems to track reconciliation
payments and internal cost savings.
(v) Its plan to track gainsharing
payments and alignment payments.
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(3) The participant hospital must
retain and provide access to, and must
require each CJR collaborator to retain
and provide access to, the required
documentation in accordance with
§ 510.110.
■ 17. Section 510.505 is revised,
effective July 1, 2017, to read as follows:
§ 510.505
Distribution arrangements.
(a) General. (1) An ACO, PGP, NPPGP,
or TGP that has entered into a sharing
arrangement with a participant hospital
may distribute all or a portion of any
gainsharing payment it receives from
the participant hospital only in
accordance with a distribution
arrangement.
(2) All distribution arrangements must
comply with the provisions of this
section and all other applicable laws
and regulations, including the fraud and
abuse laws.
(b) Requirements. (1) All distribution
arrangements must be in writing and
signed by the parties, contain the date
of the agreement, and be entered into
before care is furnished to CJR
beneficiaries under the distribution
arrangement.
(2) Participation in a distribution
arrangement must be voluntary and
without penalty for nonparticipation.
(3) The distribution arrangement must
require the collaboration agent to
comply with all applicable laws and
regulations.
(4) The opportunity to make or
receive a distribution payment must not
be conditioned directly or indirectly on
the volume or value of past or
anticipated referrals or business
otherwise generated by, between or
among the participant hospital, any CJR
collaborator, any collaboration agent,
any downstream collaboration agent, or
any individual or entity affiliated with
a participant hospital, CJR collaborator,
collaboration agent, or downstream
collaboration agent.
(5) The amount of any distribution
payments from an ACO, from an NPPGP
to an NPPGP member, or from a TGP to
a TGP member must be determined in
accordance with a methodology that is
substantially based on quality of care
and the provision of CJR activities and
that may take into account the amount
of such CJR activities provided by a
collaboration agent relative to other
collaboration agents.
(6) The amount of any distribution
payments from a PGP must be
determined either in a manner that
complies with § 411.352(g) of this
chapter or in accordance with a
methodology that is substantially based
on quality of care and the provision of
CJR activities and that may take into
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account the amount of such CJR
activities provided by a collaboration
agent relative to other collaboration
agents.
(7) Except for a distribution payment
from a PGP to a PGP member that
complies with § 411.352(g) of this
chapter, a collaboration agent is eligible
to receive a distribution payment only if
the collaboration agent furnished or
billed for an item or service rendered to
a CJR beneficiary during a CJR episode
that occurred during the same
performance year for which the
participant hospital accrued the internal
cost savings or earned the reconciliation
payment that comprises the gainsharing
payment being distributed.
(8) Except for a distribution payment
from a PGP to a PGP member that
complies with § 411.352(g) of this
chapter, the total amount of distribution
payments for a performance year paid to
a collaboration agent must not exceed
the following:
(i) In the case of a collaboration agent
that is a physician or nonphysician
practitioner, 50 percent of the total
Medicare-approved amounts under the
PFS for items and services furnished by
the collaboration agent to the
participant hospital’s CJR beneficiaries
during CJR episodes that occurred
during the same performance year for
which the participant hospital accrued
the internal cost savings or earned the
reconciliation payment that comprises
the gainsharing payment being
distributed.
(ii) In the case of a collaboration agent
that is a PGP or NPPGP, 50 percent of
the total Medicare-approved amounts
under the PFS for items and services
billed by that PGP or NPPGP for items
and services furnished by PGP members
or NPPGP member respectively to the
participant hospital’s CJR beneficiaries
during CJR episodes that occurred
during the same performance year for
which the participant hospital accrued
the internal cost savings or earned the
reconciliation payment that comprises
the gainsharing payment being
distributed.
(9) With respect to the distribution of
any gainsharing payment received by an
ACO, PGP, NPPGP, or TGP, the total
amount of all distribution payments
must not exceed the amount of the
gainsharing payment received by the
CJR collaborator from the participant
hospital.
(10) All distribution payments must
be made by check, electronic funds
transfer, or another traceable cash
transaction.
(11) The collaboration agent must
retain the ability to make decisions in
the best interests of the patient,
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including the selection of devices,
supplies, and treatments.
(12) The distribution arrangement
must not—
(i) Induce the collaboration agent to
reduce or limit medically necessary
items and services to any Medicare
beneficiary; or
(ii) Reward the provision of items and
services that are medically unnecessary.
(13) The CJR collaborator must
maintain contemporaneous
documentation regarding distribution
arrangements in accordance with
§ 510.110, including the following:
(i) The relevant written agreements;
(ii) The date and amount of any
distribution payment(s);
(iii) The identity of each collaboration
agent that received a distribution
payment; and
(iv) A description of the methodology
and accounting formula for determining
the amount of any distribution payment.
(14) The CJR collaborator may not
enter into a distribution arrangement
with any individual or entity that has a
sharing arrangement with the same
participant hospital.
(15) The CJR collaborator must retain
and provide access to, and must require
collaboration agents to retain and
provide access to, the required
documentation in accordance with
§ 510.110.
■ 18. Section 510.506 is added, effective
July 1, 2017, to read as follows:
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§ 510.506 Downstream distribution
arrangements.
(a) General. (1) An ACO participant
that is a PGP, NPPGP, or TGP and that
has entered into a distribution
arrangement with a CJR collaborator that
is an ACO may distribute all or a
portion of any distribution payment it
receives from the CJR collaborator only
in accordance with downstream
distribution arrangement.
(2) All downstream distribution
arrangements must comply with the
provisions of this section and all
applicable laws and regulations,
including the fraud and abuse laws.
(b) Requirements. (1) All downstream
distribution arrangements must be in
writing and signed by the parties,
contain the date of the agreement, and
be entered into before care is furnished
to CJR beneficiaries under the
downstream distribution arrangement.
(2) Participation in a downstream
distribution arrangement must be
voluntary and without penalty for
nonparticipation.
(3) The downstream distribution
arrangement must require the
downstream collaboration agent to
comply with all applicable laws and
regulations.
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(4) The opportunity to make or
receive a downstream distribution
payment must not be conditioned
directly or indirectly on the volume or
value of past or anticipated referrals or
business otherwise generated by,
between or among the participant
hospital, any CJR collaborator, any
collaboration agent, any downstream
collaboration agent, or any individual or
entity affiliated with a participant
hospital, CJR collaborator, collaboration
agent, or downstream collaboration
agent.
(5) The amount of any downstream
distribution payments from an NPPGP
to an NPPGP member or from a TGP to
a TGP member must be determined in
accordance with a methodology that is
substantially based on quality of care
and the provision CJR activities and that
may take into account the amount of
such CJR activities provided by a
downstream collaboration agent relative
to other downstream collaboration
agents.
(6) The amount of any downstream
distribution payments from a PGP must
be determined either in a manner that
complies with § 411.352(g) of this
chapter or in accordance with a
methodology that is substantially based
on quality of care and the provision CJR
activities and that may take into account
the amount of such CJR activities
provided by a downstream collaboration
agent relative to other downstream
collaboration agents.
(7) Except for a downstream
distribution payment from a PGP to a
PGP member that complies with
§ 411.352(g) of this chapter, a
downstream collaboration agent is
eligible to receive a downstream
distribution payment only if the
downstream collaboration agent
furnished an item or service by the
downstream collaboration agent to a CJR
beneficiary during a CJR episode that
occurred during the same performance
year for which the participant hospital
accrued the internal cost savings or
earned the reconciliation payment that
comprises the gainsharing payment
from which the ACO made the
distribution payment to the PGP,
NPPGP, or TGP that is an ACO
participant.
(8) Except for a downstream
distribution payment from a PGP to a
PGP member that complies with
§ 411.352(g) of this chapter, the total
amount of downstream distribution
payments for a performance year paid to
a downstream collaboration agent who
is a physician or nonphysician
practitioner and is either a member of a
PGP or a member of an NPPGP must not
exceed 50 percent of the total Medicare-
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621
approved amounts under the PFS for
items and services furnished by the
downstream collaboration agent to the
participant hospital’s CJR beneficiaries
during a CJR episode that occurred
during the same performance year for
which the participant hospital accrued
the internal cost savings or earned the
reconciliation payment that comprises
the distribution payment being
distributed.
(9) The total amount of all
downstream distribution payments
made to downstream collaboration
agents must not exceed the amount of
the distribution payment received by
the PGP, NPPGP, or TGP from the ACO.
(10) All downstream distribution
payments must be made by check,
electronic funds transfer, or another
traceable cash transaction.
(11) The downstream collaboration
agent must retain his or her ability to
make decisions in the best interests of
the patient, including the selection of
devices, supplies, and treatments.
(12) The downstream distribution
arrangement must not—
(i) Induce the downstream
collaboration agent to reduce or limit
medically necessary services to any
Medicare beneficiary; or
(ii) Reward the provision of items and
services that are medically unnecessary.
(13) The PGP, NPPGP, or TGP must
maintain contemporaneous
documentation regarding downstream
distribution arrangements in accordance
with § 510.110, including the following:
(i) The relevant written agreements.
(ii) The date and amount of any
downstream distribution payment.
(iii) The identity of each downstream
collaboration agent that received a
downstream distribution payment.
(iv) A description of the methodology
and accounting formula for determining
the amount of any downstream
distribution payment.
(14) The PGP, NPPGP, or TGP may
not enter into a downstream distribution
arrangement with any PGP member,
NPPGP member, or TGP member who
has—
(i) A sharing arrangement with a
participant hospital.
(ii) A distribution arrangement with
the ACO that the PGP, NPPGP, or TGP
is a participant in.
(15) The PGP, NPPGP, or TGP must
retain and provide access to, and must
require downstream collaboration
agents to retain and provide access to,
the required documentation in
accordance with § 510.110.
■ 19. Section 510.515 is amended,
effective July 1, 2017, by revising
paragraphs (a)(2) and (3), (b), (c) and (d),
and removing paragraph (e).
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The revisions read as follows:
§ 510.515 Beneficiary incentives under the
CJR model.
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*
*
*
*
*
(a) * * *
(2) The item or service provided must
be reasonably connected to medical care
provided to a beneficiary during a CJR
episode of care.
(3) The item or service must be a
preventive care item or service or an
item or service that advances a clinical
goal, as listed in paragraph (c) of this
section, for a beneficiary in a CJR
episode by engaging the beneficiary in
better managing his or her own health.
*
*
*
*
*
(b) Technology provided to a CJR
beneficiary. Beneficiary engagement
incentives involving technology are
subject to the following additional
conditions:
(1) Items or services involving
technology provided to a beneficiary
may not exceed $1,000 in retail value
for any one beneficiary in any one CJR
episode.
(2) Items or services involving
technology provided to a beneficiary
must be the minimum necessary to
advance a clinical goal, as listed in
paragraph (c) of this section, for a
beneficiary in a CJR episode.
(3) Items of technology exceeding
$100 in retail value must—
(i) Remain the property of the CJR
participant; and
(ii) Be retrieved from the beneficiary
at the end of the CJR episode. The
participant hospital must document all
retrieval attempts, including the
ultimate date of retrieval. Documented,
diligent, good faith attempts to retrieve
items of technology will be deemed to
meet the retrieval requirement.
(c) Clinical goals of the CJR model.
The following are the clinical goals of
the CJR model, which may be advanced
through beneficiary incentives:
(1) Beneficiary adherence to drug
regimens.
(2) Beneficiary adherence to a care
plan.
(3) Reduction of readmissions and
complications resulting from LEJR
procedures.
(4) Management of chronic diseases
and conditions that may be affected by
the LEJR procedure.
(d) Documentation of beneficiary
incentives. (1) Participant hospitals
must maintain documentation of items
and services furnished as beneficiary
incentives that exceed $25 in retail
value.
(2) The documentation must be
established contemporaneously with the
provision of the items and services and
must include at least the following:
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(i) The date the incentive is provided.
(ii) The identity of the beneficiary to
whom the item or service was provided.
(3) The documentation regarding
items of technology exceeding $100 in
retail value must also include
contemporaneous documentation of any
attempt to retrieve technology at the end
of a CJR episode as described in
paragraph (b)(3) of this section.
(4) The CJR participant hospital must
retain and provide access to the
required documentation in accordance
with § 510.110.
■ 20. Section 510.610 is revised to read
as follows:
§ 510.610
Waiver of SNF 3-day rule.
(a) Waiver of the SNF 3-day rule. For
episodes being tested in performance
years 2 through 5 of the CJR model,
CMS waives the SNF 3-day rule for
coverage of a SNF stay for a beneficiary
who is a CJR beneficiary on the date of
discharge from the anchor
hospitalization, but only if the SNF is
identified on the applicable calendar
quarter list of qualified SNFs at the time
of the CJR beneficiary’s admission to the
SNF.
(1) CMS determines the qualified
SNFs for each calendar quarter based on
a review of the most recent rolling 12
months of overall star ratings on the
Five-Star Quality Rating System for
SNFs on the Nursing Home Compare
Web site. Qualified SNFs are rated an
overall of 3 stars or better for at least 7
of the 12 months.
(2) CMS posts to the CMS Web site
the list of qualified SNFs in advance of
the calendar quarter and the waiver only
applies for a beneficiary who has been
discharged from an anchor
hospitalization if the SNF is included
on the applicable calendar quarter list
for the date of the beneficiary’s
admission to the SNF.
(b) Financial liability for non-covered
SNF services. If CMS determines that
the waiver requirements specified in
paragraph (a) of this section were not
met, the following apply:
(1) CMS makes no payment to a SNF
for SNF services if the SNF admits a CJR
beneficiary who has not had a
qualifying inpatient stay.
(2) In the event that CMS makes no
payment for SNF services furnished by
a SNF as a result of paragraph (b)(1) of
this section, the beneficiary protections
specified in paragraph (b)(3) of this
section apply, unless the participant
hospital has provided the beneficiary
with a discharge planning notice in
accordance with § 510.405(b)(3).
(3) If the participant hospital does not
provide the beneficiary with a discharge
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planning notice in accordance with
§ 510.405(b)(3)—
(i) The SNF must not charge the
beneficiary for the expenses incurred for
such services;
(ii) The SNF must return to the
beneficiary any monies collected for
such services; and
(iii) The participant hospital is
financially liable for the expenses
incurred for such services.
(4) If the participant hospital provided
a discharge planning notice to the
beneficiary in accordance with
§ 510.405(b)(3), then normal SNF
coverage requirements apply and the
beneficiary may be financially liable for
non-covered SNF services.
(c) Other requirements. All other
Medicare rules for coverage and
payment of Part A-covered services
continue to apply except as otherwise
waived in this part.
■ 21. Section 510.620 is amended by
revising paragraph (a) to read as follows:
§ 510.620 Waiver of deductible and
coinsurance that otherwise apply to
reconciliation payments and repayments.
(a) Waiver of deductible and
coinsurance. CMS waives the
requirements of sections 1813 and
1833(a) of the Act for Medicare Part A
and Part B payment systems only to the
extent necessary to make reconciliation
payments or receive repayments based
on the NPRA that reflect the episode
payment methodology under the final
payment model for CJR participant
hospitals.
*
*
*
*
*
■ 22. Part 512 is added to subchapter H
to read as follows:
PART 512—EPISODE PAYMENT
MODEL
Sec.
Subpart A—General Provisions
512.1 Basis and scope.
512.2 Definitions.
Subpart B—Episode Payment Model
Participants
512.100 EPM episodes being tested.
512.105 Geographic areas.
512.110 Access to records and retention.
512.120 EPM participant CEHRT track
requirements.
Subpart C—Scope of Episodes
512.200 Time periods for EPM episodes.
512.210 Included and excluded services.
512.230 Beneficiary inclusion criteria.
512.240 Determination of the EPM episode.
Subpart D—Pricing and Payment
512.300 Determination of episode qualityadjusted target prices and actual episode
payments.
512.305 Determination of the NPRA and
reconciliation process.
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512.307 Subsequent calculations.
512.310 Appeals process.
512.315 Composite quality scores for
determining reconciliation payment
eligibility and effective and applicable
discount factors.
512.320 Treatment of incentive programs or
add-on payments under existing
Medicare payment systems.
512.350 Data sharing.
Subpart E—Quality Measures, Beneficiary
Protections, and Compliance Enforcement
512.400 Quality measures and reporting—
general.
512.411 Quality measures and reporting for
AMI model.
512.412 Quality measures and reporting for
CABG model.
512.413 Quality measures and reporting for
SHFFT model.
512.450 Beneficiary choice and beneficiary
notification.
512.460 Compliance enforcement.
Subpart F—Financial Arrangements and
Beneficiary Incentives
512.500 Sharing arrangements under the
EPM.
512.505 Distribution arrangements under
the EPM.
512.510 Downstream distribution
arrangements under the EPM.
512.520 Enforcement authority under the
EPM.
512.525 Beneficiary engagement incentives
under the EPM.
Subpart G—Waivers
512.600 Waiver of direct supervision
requirement for certain post-discharge
home visits.
512.605 Waiver of certain telehealth
requirements.
512.610 Waiver of SNF 3-day rule.
512.615 Waiver of certain post-operative
billing restrictions.
512.620 Waiver of deductible and
coinsurance that otherwise apply to
reconciliation payments or repayments.
512.630 Waiver of physician definition for
furnishing cardiac rehabilitation and
intensive cardiac rehabilitation services
to an EPM beneficiary.
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Subpart H—CR Incentive Payment Model
for EPM and Medicare Fee-for-Service
Participants
512.700 Basis and scope.
512.703 CR incentive payment model
participants.
512.705 CR/ICR services that count towards
CR incentive payments.
512.710 Determination of CR incentive
payments.
Provisions for FFS–CR Participants
512.715 Access to records and retention for
FFS–CR participants.
512.720 Appeals process for FFS–CR
participants.
512.725 Data sharing for FFS–CR
participants.
512.730 Compliance enforcement for FFS–
CR participants.
512.735 Enforcement authority for FFS–CR
participants.
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512.740 Beneficiary engagement incentives
for FFS–CR participant use.
512.745 Waiver of physician definition for
furnishing CR and ICR services to a FFS–
CR beneficiary.
Subparts I–J [Reserved]
Subpart K—Model Termination
512.900 Termination of an episode payment
model.
512.905 Termination of the CR incentive
payment model.
Authority: Secs. 1102, 1115A, and 1871 of
the Social Security Act (42 U.S.C. 1302,
1315(a), and 1395hh).
Subpart A—General Provisions
§ 512.1
Basis and scope.
(a) Basis. This part implements the
test of episode payment models under
section 1115A of the Act. Except as
specifically noted in this part, the
regulations under this part must not be
construed to affect the payment,
coverage, program integrity, or other
requirements (such as those in parts 412
and 482 of this chapter) that apply to
providers and suppliers under this
chapter.
(b) Scope. This part sets forth the
following:
(1) The participants in each episode
payment model.
(2) The episodes being tested in each
episode payment model.
(3) The methodology for pricing and
payment under each episode payment
model.
(4) Quality performance standards
and quality reporting requirements.
(5) Safeguards to ensure preservation
of beneficiary choice and beneficiary
notification.
§ 512.2
Definitions.
For the purposes of this part, the
following definitions are applicable
unless otherwise stated:
ACO means an accountable care
organization, as defined at § 425.20 of
this chapter, that participates in the
Shared Savings Program and is not in
Track 3.
ACO participant has the meaning set
forth in § 425.20 of this chapter.
ACO provider/supplier has the
meaning set forth in § 425.20 of this
chapter.
Actual episode payment means the
sum of Medicare claims payments and
certain non-claims-based payments for
items and services that are included in
the episode in accordance with
§ 512.210(a), excluding the items and
services described in § 512.210(b).
Alignment payment means a payment
from an EPM collaborator to an EPM
participant under a sharing
arrangement, for the sole purpose of
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623
sharing the EPM participant’s
responsibility for making repayments to
Medicare.
AMI means acute myocardial
infarction, an event caused by
diminished blood supply to the heart
leading to irreversible heart muscle cell
damage or death.
AMI care period means a period of
AMI care that would meet the
requirements to be an AMI model
episode in accordance with all
provisions in subpart B of this part if the
FFS–CR participant were an AMI model
participant.
AMI model means the EPM for AMI.
AMI model participant means an EPM
participant that is an IPPS hospital
(other than those hospitals specifically
excepted under § 512.100(b)) with a
CCN primary address in one of the
geographic areas selected for
participation in the AMI model in
accordance with § 512.105(b), as of the
date of selection or any time thereafter
during any performance year.
Anchor hospitalization means a
hospitalization that initiates an EPM
episode.
Anchor hospitalization portion means
the part of an EPM episode that occurs
during the anchor hospitalization.
Anchor MS–DRG means the MS–DRG
assigned to the hospitalization
discharge, which initiates an EPM
episode.
Applicable discount factor means the
discount percentage established by the
EPM participant’s quality category as
determined in § 512.315, that is applied
to the episode benchmark price for
purposes of determining an EPM
participant’s Medicare repayment in
performance year 2 for EPM participants
who elect early downside risk and
performance years 3 and 4 for all EPM
participants.
Area means, as defined in § 400.200
of this chapter, the geographical area
within the boundaries of a State, or a
State or other jurisdiction, designated as
constituting an area with respect to
which a Professional Standards Review
Organization or a Utilization and
Quality Control Peer Review
Organization has been or may be
designated.
BPCI stands for the Bundled Payment
for Care Improvement initiative.
CABG means coronary artery bypass
graft, a surgical procedure that diverts
the flow of blood around a section of a
blocked or partially blocked artery in
the heart, creating a new pathway that
improves blood flow to heart muscle.
CABG care period means a period of
CABG care that would meet the
requirements to be a CABG model
episode in accordance with all
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provisions in subpart B of this part if the
FFS–CR participant were a CABG model
participant.
CABG model means the EPM for
CABG.
CABG model participant means an
EPM participant that is an IPPS hospital
(other than those hospitals specifically
excepted under § 512.100(b)) with a
CCN primary address in one of the
geographic areas selected for
participation in the CABG model in
accordance with § 512.105(b), as of the
date of selection or any time thereafter
during any performance year.
CAH means a critical access hospital
designated under subpart F of part 485
of this chapter.
CCN stands for CMS certification
number.
CEC stands for Comprehensive ESRD
Care Model.
CEHRT means certified electronic
health record technology that meet the
requirements of 45 CFR 170.102.
Collaboration agent means an
individual or entity that is not an EPM
collaborator and that is either of the
following:
(1) A PGP member, an NPPGP
member, or a TGP member that has
entered into a distribution arrangement
with the same PGP, NPPGP, or TGP in
which he or she is an owner or
employee, and where the PGP, NPPGP,
or TGP is an EPM collaborator.
(2) An ACO participant or ACO
provider/supplier that has entered into
a distribution arrangement with the
same ACO in which it is participating,
and where the ACO is an EPM
collaborator.
Core-based statistical area (CBSA)
means a statistical geographic entity
consisting of the county or counties
associated with at least one core
(urbanized area or urban cluster) of at
least 10,000 population, plus adjacent
counties having a high degree of social
and economic integration with the core
as measured through commuting ties
with the counties containing the core.
CORF stands for comprehensive
outpatient rehabilitation facility.
CR means cardiac rehabilitation as
defined in § 410.49(a) of this chapter, a
physician-supervised program that
furnishes physician prescribed exercise,
cardiac risk factor modification,
psychosocial assessment, and outcomes
assessment.
CR amount means the dollar amount
determined by the number of CR/ICR
services paid by Medicare under the
OPPS or to any supplier reporting place
of service code 11 on the PFS claim for
a beneficiary in an AMI or CABG model
episode or AMI care period or CABG
care period.
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CR incentive payment means a
payment made by CMS to an EPM–CR
participant or FFS–CR participant for
CR/ICR service use that is the sum of the
CR amounts as determined in
accordance with § 512.710.
CR incentive payment model means
the model testing CR incentive
payments for CR/ICR service use made
in accordance with subpart H of this
part.
CR participant means all EPM–CR
participants and FFS–CR participants.
CR performance year means one of
the years in which the CR incentive
payment model is being tested.
Performance years for the CR incentive
payment model correlate to calendar
years with the exception of performance
year 1, which is July 1, 2017 through
December 31, 2017.
CR service count means the number of
CR/ICR services paid by Medicare under
the OPPS or to any supplier reporting
place of service code 11 on the PFS
claim for a beneficiary in an AMI or
CABG model episode or AMI care
period or CABG care period.
Distribution arrangement means a
financial arrangement between an EPM
collaborator that is an ACO, PGP,
NPPGP, or TGP and a collaboration
agent for the sole purpose of distributing
some or all of a gainsharing payment
received by the ACO, PGP, NPPGP, or
TGP.
Distribution payment means a
payment from an EPM collaborator that
is an ACO, PGP, NPPGP, or TGP to a
collaboration agent, under a distribution
arrangement, composed only of
gainsharing payments.
DME stands for durable medical
equipment.
Downstream collaboration agent
means an individual who is not an EPM
collaborator or a collaboration agent and
who is a PGP member, an NPPGP
member, or a TGP member that has
entered into a downstream distribution
arrangement with the same PGP,
NPPGP, or TGP in which he or she is
an owner or employee, and where the
PGP, NPPGP, or TGP is a collaboration
agent.
Downstream distribution arrangement
means a financial arrangement between
a collaboration agent that is both a PGP,
NPPGP, or TGP and an ACO participant
and a downstream collaboration agent
for the sole purpose of distributing some
or all of a distribution payment received
by the PGP, NPPGP, or TGP.
Downstream distribution payment
means a payment from a collaboration
agent that is both a PGP, NPPGP, or TGP
and an ACO participant to a
downstream collaboration agent, under
a downstream distribution arrangement,
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composed only of distribution
payments.
Effective discount factor means the
discount factor established by the EPM
participant’s quality category as
determined in § 512.315, that is applied
to the episode benchmark price to
calculate the quality-adjusted target
price.
Episode attribution means the process
of assigning financial responsibility for
an EPM episode to an EPM participant.
Episode benchmark price means a
dollar amount assigned to EPM episodes
based on historical episode data (3 years
of historical Medicare payment data
grouped into EPM episodes according to
the EPM episode definitions as
discussed in § 512.300(b)) prior to the
application of the effective discount
factor, as described in § 512.300(d).
Episode payment model (EPM) means
the AMI model, CABG model, SHFFT
model, or another model with payment
made on an episode basis in accordance
with this part. Each section of the
regulations applies in its entirety to
each model.
EPM activities means activities related
to promoting accountability for the
quality, cost, and overall care for EPM
beneficiaries, including managing and
coordinating care; encouraging
investment in infrastructure, enabling
technologies, and redesigned care
processes for high quality and efficient
service delivery; the provision of items
and services during an EPM episode in
a manner that reduces costs and
improves quality; or carrying out any
other obligation or duty under the EPM.
EPM beneficiary means a beneficiary
who meets the beneficiary inclusion
criteria in § 512.230 and who is in an
EPM episode.
EPM collaborator means an ACO or
one of the following Medicare-enrolled
individuals or entities that enters into a
sharing arrangement:
(1) SNF.
(2) HHA.
(3) LTCH.
(4) IRF.
(5) Physician.
(6) Nonphysician practitioner.
(7) Therapist in private practice.
(8) CORF.
(9) Provider of outpatient therapy
services.
(10) PGP.
(11) Hospital.
(12) CAH.
(13) NPPGP.
(14) TGP.
EPM composite quality score means a
score computed for each EPM
participant’s level of quality
performance and improvement and
successful reporting of voluntary data, if
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applicable, on specified EPM quality
measures as described in § 512.315.
EPM–CR participant means an AMI or
CABG model participant that is eligible
to receive CR incentive payments from
CMS in accordance with § 512.710.
EPM episode of care (or Episode)
means all Medicare Part A and Part B
items and services described in
§ 512.210(a) (and excluding the items
and services described in § 512.210(b))
that are furnished to an EPM beneficiary
described in § 512.240 that begins with
the beneficiary’s admission to an anchor
hospitalization, with the day of
discharge itself from the anchor
hospitalization being counted as the
first day of the 90-day post-discharge
period.
EPM participant means a Medicare
provider or supplier that is eligible to
receive payment from CMS on an
episode basis for services rendered to
EPM beneficiaries.
EPM volume protection hospital
means an EPM participant that meets
the requirements under
§ 512.305(c)(2)(iii)(D).
ESRD stands for end-stage renal
disease.
FFS–CR beneficiary means a
beneficiary attributed to an FFS–CR
participant and receiving care during an
AMI care period or CABG care period.
FFS–CR participant means a hospital
that is not an EPM participant and that
is eligible to receive CR incentive
payments from CMS in accordance with
§ 512.710.
Gainsharing payment means a
payment from an EPM participant to an
EPM collaborator, under a sharing
arrangement, composed of only
reconciliation payments or internal cost
savings or both.
HCAHPS stands for Hospital
Consumer Assessment of Healthcare
Providers and Systems.
HCPCS stands for CMS Common
Procedure Coding System.
Health Insurance Claim Number
(HICN) means the unique number
assigned by the Social Security
Administration to an individual for the
purpose of identifying that individual as
a Medicare beneficiary.
HHA means a Medicare-enrolled
home health agency.
Historical episode payment means the
expenditures for episodes that occurred
during the historical period used to
determine the EPM episode benchmark
price.
Hospital means a provider subject to
the prospective payment system
specified in § 412.1(a)(1) of this chapter.
ICD–CM stands for International
Classification of Diseases, Clinical
Modification.
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ICR means intensive cardiac
rehabilitation as defined in § 410.49(a)
of this chapter, a physician-supervised
program that furnishes cardiac
rehabilitation and has shown, in peerreviewed published research, that it
improves patients’ cardiovascular
disease through specific outcome
measurements described in § 410.49(c)
of this chapter.
Inpatient prospective payment
systems (IPPS) means the payment
systems for subsection (d) hospitals as
defined in section 1886(d)(1)(B) of the
Act.
Internal cost savings means the
measurable, actual, and verifiable cost
savings realized by the EPM participant
resulting from care redesign undertaken
by such participant in connection with
providing items and services to
beneficiaries within specific EPM
episodes. Internal cost savings does not
include savings realized by any
individual or entity that is not the EPM
participant.
Intracardiac procedures means
procedures performed within the heart
chambers, rather than within coronary
artery blood vessels, through
percutaneous access to blood vessels.
These procedures are indicated for the
treatment of congenital cardiac
malformations, cardiac valve disease,
and cardiac arrhythmias.
IPF stands for inpatient psychiatric
facility.
IRF stands for inpatient rehabilitation
facility.
LTCH stands for long-term care
hospital.
MDH means a Medicare-dependent,
small rural hospital that meets the
classification criteria specified under
§ 412.108 of this chapter.
Member of the PGP or PGP member
means a physician, nonphysician
practitioner, or therapist who is an
owner or employee of a PGP and who
has reassigned to the PGP his or her
right to receive Medicare payment.
Member of the NPPGP or NPPGP
member means a nonphysician
practitioner or therapist who is an
owner or employee of an NPPGP and
who has reassigned to the NPPGP his or
her right to receive Medicare payment.
Member of the TGP or TGP member
means a therapist who is an owner or
employee of a TGP and who has
reassigned to the TGP his or her right to
receive Medicare payment.
MSA stands for metropolitan
statistical area and means a CBSA
associated with at least one urbanized
area that has a population of at least
50,000.
MS–DRG stands for Medicare severity
diagnosis-related group, which is the
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625
classification of inpatient hospital
discharges updated in accordance with
§ 412.10 of this chapter.
Nonphysician practitioner means
(except for purposes of subpart G of this
part) one of the following:
(1) A physician assistant who satisfies
the qualifications set forth at
§ 410.74(a)(2)(i) and (ii) of this chapter.
(2) A nurse practitioner who satisfies
the qualifications set forth at § 410.75(b)
of this chapter.
(3) A clinical nurse specialist who
satisfies the qualifications set forth at
§ 410.76(b) of this chapter.
(4) A certified registered nurse
anesthetist (as defined at § 410.69(b) of
this chapter).
(5) A clinical social worker (as
defined at § 410.73(a) of this chapter).
(6) A registered dietician or nutrition
professional (as defined at § 410.134 of
this chapter).
NPI stands for National Provider
Identifier.
NPPGP means an entity that is
enrolled in Medicare as a group
practice, includes at least one owner or
employee who is a nonphysician
practitioner, does not include a
physician owner or employee, and has
a valid and active TIN.
NPRA means the net payment
reconciliation amount determined in
accordance with § 512.305(c).
OIG stands for the Department of
Health and Human Services Office of
Inspector General.
OPPS stands for the Medicare
Outpatient Prospective Payment
System.
PAC stands for post-acute care.
PBPM stands for per-beneficiary-permonth.
PCI means percutaneous coronary
intervention, a procedure used to open
blocked arteries in the heart through
percutaneous placement of a small wire
mesh tube that keeps the artery open
and minimizes the risk of it later
narrowing.
Performance year means one of the
years in which the EPM is being tested.
Performance years for the EPMs
correlate to calendar years with the
exception of performance year 1, which
is July 1, 2017 through December 31,
2017.
PFS means the Medicare Physician
Fee Schedule authorized under section
1848 of the Act.
PGP stands for physician group
practice.
Physician has the meaning set forth in
section 1861(r) of the Act.
Post-anchor hospitalization portion
means the part of an episode that occurs
after the anchor hospitalization.
Post-episode spending amount means
the sum of Medicare Parts A and B
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payments for items and services that are
furnished to a beneficiary within 30
days after the end of the beneficiary’s
EPM episode.
Provider of outpatient therapy
services means an entity that is enrolled
in Medicare as a provider of therapy
services and furnishes one or more of
the following:
(1) Outpatient physical therapy
services as defined in § 410.60 of this
chapter.
(2) Outpatient occupational therapy
services as defined in § 410.59 of this
chapter.
(3) Outpatient speech-language
pathology services as defined in
§ 410.62 of this chapter.
Quality-adjusted target price means
the dollar amount assigned to EPM
episodes as the result of reducing the
episode benchmark price by the EPM
participant’s effective discount factor
based on the EPM participant’s quality
category, as described in § 512.315(b)(5),
(c)(5), or (d)(5).
Quality improvement points are
points that CMS adds to an EPM
participant’s EPM composite quality
score for a measure if the EPM
participant’s performance improves
from the previous performance year
according to the relevant EPM measure
improvement methodology.
Quality performance points are points
that CMS adds to an EPM participant’s
EPM composite quality score for a
measure based on the performance
percentile scale and for successful
submission of voluntary data if
applicable to the EPM.
Reconciliation payment means a
payment made by CMS to an EPM
participant as determined in accordance
with § 512.305(d).
Repayment amount means the
amount owed by an EPM participant to
CMS, as reflected on a reconciliation
report.
RRC means a rural referral center that
satisfies the criteria set forth in § 412.96
of this chapter.
Rural hospital means an IPPS hospital
that meets one of the following
definitions:
(1) Is located in a rural area as defined
under § 412.64 of this chapter.
(2) Is located in a rural census tract
defined under § 412.103(a)(1) of this
chapter.
(3) Has reclassified as a rural hospital
under § 412.103 of this chapter.
SCH means a sole community
hospital that meets the classification
criteria specified in § 412.92 of this
chapter.
Sharing arrangement means a
financial arrangement between an EPM
participant and an EPM collaborator for
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the sole purpose of making gainsharing
payments or alignment payments under
the EPM.
SHFFT stands for surgical hip/femur
fracture treatment and means surgical
treatment for hip and femur fractures,
other than hip replacements, consisting
primarily of hip fixation procedures,
with or without reduction of the
fracture, as well as open and closed
surgical approaches.
SHFFT model means the EPM for
SHFFT.
SHFFT model participant means an
EPM participant that is an IPPS hospital
(other than those hospitals specifically
excepted under § 512.100(b)) with a
CCN primary address in one of the
geographic areas selected for
participation in a SHFFT model in
accordance with § 512.105(a), as of the
date of selection or any time thereafter
during any performance year.
SNF stands for skilled nursing
facility.
TGP means an entity that is enrolled
in Medicare as a therapy group in
private practice, includes at least one
owner or employee who is a therapist in
private practice, does not include an
owner or employee who is a physician
or nonphysician practitioner, and has a
valid and active TIN.
THA/TKA stands for total hip
arthroplasty/total knee arthroplasty.
Therapist means one of the following
individuals as defined at § 484.4 of this
chapter:
(1) Physical therapist.
(2) Occupational therapist.
(3) Speech-language pathologist.
Therapist in private practice means a
therapist that either—
(1) Complies with the special
provisions for services furnished by
physical therapists in private practice in
§ 410.60(c) of this chapter;
(2) Complies with the special
provisions for services furnished by
occupational therapists in private
practice in § 410.59(c) of this chapter; or
(3) Complies with the special
provisions for services furnished by
speech-language pathologists in private
practice in § 410.62(c) of this chapter.
TIN stands for taxpayer identification
number.
Two-sided risk arrangement means an
arrangement in which the ACO may
share savings with the Medicare
program, if it meets the requirements for
doing so, and is also liable for sharing
losses incurred under the program or
model, if it meets the criteria under
which sharing losses occurs.
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Subpart B—Episode Payment Model
Participants
§ 512.100
EPM episodes being tested.
(a) Initiation of an episode. An
episode is initiated when an EPM
participant admits a Medicare
beneficiary described in § 512.230 for an
anchor hospitalization.
(b) Hospital exclusions. (1) A hospital
is excluded from participating in EPMs
for EPM anchor MS–DRGs that are
included in BPCI episodes in which the
hospital currently participates.
(2) These exclusions cease to apply as
of the date that the hospital no longer
meets the conditions specified in this
paragraph (b) or September 30, 2018,
whichever date is sooner.
(c) Types of EPM episodes. An EPM
episode is initiated by a beneficiary’s
admission to an EPM participant for an
anchor hospitalization that is paid
under an EPM anchor MS–DRG and, in
the case of the AMI model, with an AMI
ICD–10–CM diagnosis code if the
admission is under a PCI MS–DRG. The
EPM anchor MS–DRGs and ICD–10–CM
diagnosis codes for the EPM episodes
are as follows:
(1) Acute myocardial infarction (AMI).
(i) Discharge under an AMI MS–DRG
(MS–DRGs 280 to 282); or
(ii) Discharge under a PCI MS–DRG
(MS–DRGs 246 to 251) with an ICD–10–
CM diagnosis code of AMI on the claim
for the anchor hospitalization in the
principal or secondary diagnosis code
position.
(2) Coronary artery bypass graft
(CABG). Discharge under a CABG MS–
DRG (MS–DRGs 231 to 236).
(3) Surgical hip/femur fracture
treatment (SHFFT). Discharge under a
SHFFT MS–DRG (MS–DRGs 480 to
482).
(d) Identifying AMI historical episodes
and EPM episodes with AMI ICD–CM
diagnosis codes. CMS develops a list of
AMI ICD–9–CM and ICD–10–CM
diagnosis codes that identify the
initiation of historical episodes or
initiate AMI model episodes when
reported in the principal or secondary
diagnosis code position on the inpatient
hospital claim for a historical
hospitalization or the anchor
hospitalization discharged under PCI
MS–DRGs (MS–DRGs 246 to 251). The
list of ICD–9–CM and ICD–10–CM
diagnosis codes representing AMI is
posted on the CMS Web site.
(1) On an annual basis, or more
frequently as needed, CMS updates the
list of ICD–10–CM diagnosis codes
representing AMI to reflect coding
changes or other issues brought to CMS’
attention.
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(2) CMS applies the following
standard when revising the list of ICD–
10–CM diagnosis codes representing
AMI: The ICD–10–CM diagnosis code is
sufficiently specific that it represents an
AMI.
(3) CMS posts the following to the
CMS Web site:
(i) Potential AMI ICD–10–CM
diagnosis codes for public comment;
and
(ii) A final AMI ICD–10–CM diagnosis
code list after consideration of public
comment.
(4) CMS excludes AMI historical
episodes with PCI MS–DRGs and
inpatient claims that contain
intracardiac ICD–9–CM procedure
codes. CMS excludes historical AMI
model episodes discharged under PCI
MS–DRGs with an AMI ICD–9–CM
diagnosis code in the principal or
secondary diagnosis code position on
the inpatient hospital claim from the
AMI historical episodes that set episode
benchmark prices if there is an
intracardiac ICD–9–CM procedure code
in any procedure code field on the
inpatient hospital claim. The
intracardiac ICD–9–CM procedure codes
are as follows:
(i) 35.52 (Repair of atrial septal defect
with prosthesis, closed technique).
(ii) 35.96 (Percutaneous balloon
valvuloplasty).
(iii) 35.97 (Percutaneous mitral valve
repair with implant).
(iv) 37.26 (Catheter based invasive
electrophysiologic testing).
(v) 37.27 (Cardiac mapping).
(vi) 37.34 (Excision or destruction of
other lesion or tissue of heart,
endovascular approach).
(vii) 37.36 (Excision, destruction, or
exclusion of left atrial appendage).
(viii) 37.90 (Insertion of left atrial
appendage device).
asabaliauskas on DSK3SPTVN1PROD with RULES
§ 512.105
Geographic areas.
(a) The SHFFT model must be
implemented in the same geographic
areas as the CJR model as described
under § 510.105 of the chapter.
(b) The geographic areas for inclusion
in the CABG and AMI models will be
obtained using a random sampling of
certain MSAs in the United States. All
counties within each of the selected
MSAs are selected for inclusion in the
AMI and CABG models. CMS excludes
MSAs that met the following criteria
between January 1, 2014 and December
31, 2014 from the possibility of being
selected geographic areas. MSAs are
excluded if they—
(1) Had fewer than 75 AMI episodes;
(2) Had fewer than 75 AMI episodes
that were not attributable to BPCI Model
2 or 4, AMI, CABG or PCI episodes;
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(3) Had more than 50 percent of
otherwise qualifying (BPCI or non BPCI)
episodes attributable to a BPCI Model 2
or 4 AMI, CABG or PCI episodes; or
(4) Are in Maryland, Vermont, or
another state where CMS is
implementing a state-wide all-payer
model. In such situations all MSAs in
the state may be excluded even if
hospitals are otherwise being paid in
accordance with the IPPS and would
otherwise qualify as an eligible EPM
participant.
(c) In all geographic areas where the
AMI, CABG, or SHFFT models are being
implemented, the accountable financial
entity must be an acute care IPPS
hospital.
investigation, whichever is later,
unless—
(1) CMS determines a particular
record or group of records should be
retained for a longer period and notifies
the EPM participant at least 30 calendar
days before the disposition date; or
(2) There has been a dispute or
allegation of fraud or similar fault
against the EPM participant, EPM
collaborator, collaboration agent,
downstream collaboration agent, or any
other individual or entity performing
EPM activities in which case the records
must be maintained for 6 years from the
date of any resulting final resolution of
the dispute or allegation of fraud or
similar fault.
§ 512.110
§ 512.120 EPM participant CEHRT track
requirements.
Access to records and retention.
EPM participants, EPM collaborators,
collaboration agents, downstream
collaboration agents, and any other
individuals or entities performing EPM
activities must:
(a) Allow the Government, including
CMS, OIG, HHS, and the Comptroller
General or their designees, scheduled
and unscheduled access to all books,
contracts, records, documents, and other
evidence (including data related to
utilization and payments, quality of care
criteria, billings, lists of EPM
collaborators, sharing arrangements,
distribution arrangements, downstream
distribution arrangements, and the
documentation required under
§§ 512.500(d) and 512.525(d)) sufficient
to enable the audit, evaluation,
inspection, or investigation of the
following:
(1) The individual’s or entity’s
compliance with EPM requirements
and, if applicable, the individual’s or
entity’s compliance with CR incentive
payment model requirements.
(2) The calculation, distribution,
receipt, or recoupment of gainsharing
payments, alignment payments,
distribution payments, and downstream
distribution payments.
(3) The obligation to repay any
reconciliation payments or CR incentive
payments, if applicable, owed to CMS.
(4) The quality of the services
furnished to an EPM beneficiary during
an EPM episode.
(5) The sufficiency of EPM beneficiary
notifications.
(6) The accuracy of the EPM
participant’s submissions under CEHRT
use requirements.
(b) Maintain all such books, contracts,
records, documents, and other evidence
for a period of 10 years from the last day
of the EPM participant’s participation in
the EPM or from the date of completion
of any audit, evaluation, inspection, or
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(a) EPM CEHRT use. For performance
year 2 if the EPM participant elects
downside risk and for performance
years 3 through 5, EPM participants
choose either of the following:
(1) CEHRT use. EPM participants
attest in a form and manner specified by
CMS to their use of CEHRT as defined
in § 414.1305 of this chapter to
document and communicate clinical
care with patients and other health
professionals.
(2) No CEHRT use. EPM participants
do not attest in a form and manner
specified by CMS to their use of CEHRT
as defined in § 414.1305 of this chapter
to document and communicate clinical
care with patients and other health
professionals.
(b) Clinician financial arrangements
list. Each EPM participant that chooses
CEHRT use as provided in paragraph
(a)(1) of this section must submit to
CMS a clinician financial arrangements
list in a form and manner specified by
CMS on a no more than quarterly basis.
The list must include the following
information on individuals and entities
for the period of the EPM performance
year specified by CMS:
(1) EPM collaborators. For each
physician, nonphysician practitioner, or
therapist in private practice who is an
EPM collaborator during the period of
the EPM performance year specified by
CMS:
(i) The name, TIN, and NPI of the
EPM collaborator.
(ii) The start date and, if applicable,
end date, for the sharing arrangement
between the EPM participant and the
EPM collaborator.
(2) Collaboration agents. For each
physician, nonphysician practitioner, or
therapist who is a collaboration agent
during the period of the EPM
performance year specified by CMS:
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(i) The name and TIN of the EPM
collaborator and the name, TIN, and NPI
of the collaboration agent.
(ii) The start date and, if applicable,
end date, for the distribution
arrangement between the EPM
collaborator and the collaboration agent.
(3) Downstream collaboration agents.
For each physician, nonphysician
practitioner, or therapist who is a
downstream collaboration agent during
the period of the EPM performance year
specified by CMS:
(i) The name and TIN of the EPM
collaborator, the name and TIN of the
collaboration agent and the name, TIN,
and NPI of the downstream
collaboration agent.
(ii) The start date and, if applicable,
end date, for the downstream
distribution arrangement between the
collaboration agent and the downstream
collaboration agent.
(4) Attestation to no individuals. If
there are no individuals that meet the
requirements to be reported, as specified
in paragraphs (b)(1) through (3) of this
section, the EPM participant must attest
in a form and manner required by CMS
that there are no individuals to report
on the clinician financial arrangements
list.
(c) Documentation requirements. (1)
Each EPM participant that chooses
CEHRT use as provided in paragraph
(a)(1) of this section must maintain
documentation of their attestation to
CEHRT use and clinician financial
arrangements lists.
(2) The EPM participant must retain
and provide access to the required
documentation in accordance with
§ 512.110.
Subpart C—Scope of Episodes
§ 512.200
Time periods for EPM episodes.
All AMI, CABG, and SHFFT episodes
begin on or after July 1, 2017 and end
on or before December 31, 2021.
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§ 512.210
Included and excluded services.
(a) Included services for an EPM. All
Medicare Parts A and B items and
services are included in the EPM
episode, except as specified in
paragraph (b) of this section. These
services include, but are not limited to,
the following:
(1) Physicians’ services.
(2) Inpatient hospital services.
(3) IPF services.
(4) LTCH services.
(5) IRF services.
(6) SNF services.
(7) HHA services.
(8) Hospital outpatient services.
(9) Independent outpatient therapy
services.
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(10) Clinical laboratory services.
(11) DME.
(12) Part B drugs and biologicals.
(13) Hospice.
(14) PBPM payments under models
tested under section 1115A of the Act.
(b) Excluded services. The following
items, services, and payments are
excluded from the EPM episode:
(1) Hemophilia clotting factors
provided in accordance with § 412.115
of this chapter.
(2) New technology add-on payments
for medical devices as defined in part
412, subpart F, of this chapter.
(3) Transitional pass-through
payments for medical devices as defined
in § 419.66 of this chapter.
(4) Items and services unrelated to the
anchor MS–DRG that initiates the EPM
episode, as determined by CMS.
Excluded services include, but are not
limited, to the following:
(i) Inpatient hospital admissions for
MS–DRGs that group to the following
categories of diagnoses:
(A) Oncology.
(B) Trauma medical.
(C) Chronic disease surgical unrelated
to a condition likely to have been
affected by care during the EPM
episode, such as prostatectomy.
(D) Acute disease surgical unrelated
to a condition resulting from or likely to
have been affected by care during the
EPM episode, such as appendectomy.
(ii) Medicare Part B services during
the 90-day post-discharge period and
additionally DME during the anchor
hospitalization, as identified by the
principal ICD–CM diagnosis code on the
claim that groups to the following
categories of diagnoses:
(A) Acute disease diagnoses unrelated
to a condition resulting from or likely to
have been affected care during the EPM
episode, such as severe head injury.
(B) Certain chronic disease diagnoses,
as specified by CMS on a diagnosis-bydiagnosis basis depending on whether
the condition was likely to have been
affected by care during the EPM episode
or whether substantial services were
likely to be provided for the chronic
condition during the EPM episode.
(iii) Certain PBPM payments under
models tested under section 1115A of
the Act that CMS determines to be
primarily used for care coordination or
care management services for clinical
conditions in excluded categories of
diagnoses for an EPM, as described in
paragraphs (b)(4)(i) and (ii) of this
section.
(iv) All PBPM model payments
funded from the Innovation Center
appropriation.
(c) Updating the exclusion lists for
EPMs. (1) The EPM exclusion list that
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applies to each anchor MS–DRG for an
EPM episode and that displays excluded
MS–DRGs, ICD–9–CM and ICD–10–CM
diagnosis codes, and CMS model PBPM
payments is posted on the CMS Web
site.
(2) On an annual basis, or more
frequently as needed, CMS updates the
EPM exclusion lists to reflect annual
coding changes or other issues brought
to CMS’ attention.
(3) CMS applies the following
standards when revising the EPM
exclusion lists for reasons other than to
reflect annual coding changes:
(i) Items or services that are directly
related to the EPM episode or the
quality or safety of the EPM episode
care are included in the EPM episode.
(ii) Items or services for chronic
conditions that may be affected by the
EPM episode care are related and
included in the EPM episode.
(iii) Items and services for chronic
conditions that are generally not
affected by the EPM episode care are
excluded from the EPM episode.
(iv) Items and services for acute
clinical conditions not arising from
existing EPM episode-related chronic
clinical conditions or complications of
EPM episode care are excluded from the
EPM episode.
(v) PBPM payments under CMS
models determined to be primarily used
for care coordination or care
management services for clinical
conditions in excluded categories of
diagnoses for an EPM, as described in
paragraph (b)(4)(iii) of this section, are
excluded from the EPM episode.
(4) CMS posts the following on the
CMS Web site:
(i) Potential revisions to the EPM
exclusion lists to allow for public
comment; and
(ii) Updated EPM exclusion lists after
consideration of public comment.
§ 512.230
Beneficiary inclusion criteria.
EPM episode care is furnished to
beneficiaries who meet all of the
following criteria upon admission to the
anchor hospitalization:
(a) Enrolled in Medicare Part A and
Part B.
(b) Eligibility for Medicare is not
based on end-stage renal disease, as
described in § 406.13 of this chapter.
(c) Not enrolled in any managed care
plan (for example, Medicare Advantage,
health care prepayment plans, or costbased health maintenance
organizations).
(d) Not covered under a United Mine
Workers of America health care plan.
(e) Have Medicare as their primary
payer pursuant to the requirements in
§ 411.20 of this chapter.
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(f) Not prospectively assigned to one
of the following:—
(1) An ACO in the Next Generation
ACO model;
(2) An ACO in a track of the
Comprehensive ESRD Care Model
incorporating downside risk for
financial losses; or
(3) A Shared Savings Program ACO in
Track 3.
(g) Not under the care of an attending
or operating physician, as designated on
the inpatient hospital claim, who is a
member of a physician group practice
that initiates BPCI Model 2 episodes at
the EPM participant for the MS–DRG
that would be the anchor MS–DRG
under the EPM.
(h) Not already in any BPCI model
episode.
(i) Not already in an AMI; SHFFT;
CABG; or CJR model episode with an
episode definition that does not exclude
the MS–DRG that would be the anchor
MS–DRG under the EPM.
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§ 512.240
episode.
Determination of the EPM
(a) AMI Model—(1) General. The AMI
episode begins with the admission of a
Medicare beneficiary as described in
§ 512.230 to an AMI model participant
for an anchor hospitalization and ends
on the 90th day after the date of
discharge, with the day of discharge
itself being counted as the first day in
the 90-day post-discharge period.
(2) Cancellation of an AMI model
episode. The AMI episode is canceled
and is not included in the determination
of NPRA as specified in § 512.305 if the
beneficiary does any of the following
during the episode:
(i) Ceases to meet any criterion listed
in § 512.230(a) through (f).
(ii) Dies.
(iii) Is transferred during the anchor
hospitalization for inpatient
hospitalization at another hospital.
(iv) Initiates any BPCI model episode.
(b) CABG Model—(1) General. The
CABG episode begins with the
admission of a Medicare beneficiary as
described in § 512.230 to a CABG model
participant for an anchor hospitalization
and ends on the 90th day after the date
of discharge, with the day of discharge
itself being counted as the first day in
the 90-day post-discharge period.
(2) Cancellation of a CABG model
episode. The CABG episode is canceled
and is not included in the determination
of NPRA as specified in § 512.305 if the
beneficiary does any of the following
during the episode:
(i) Ceases to meet any criterion listed
in § 512.230(a) through (f).
(ii) Dies.
(iii) Initiates any BPCI model episode.
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(c) SHFFT Model—(1) General. The
SHFFT episode begins with the
admission of a Medicare beneficiary as
described in § 512.230 to a SHFFT
model participant for an anchor
hospitalization and ends on the 90th
day after the date of discharge, with the
day of discharge itself being counted as
the first day in the 90-day postdischarge period.
(2) Cancellation of a SHFFT model
episode. The SHFFT episode is canceled
and is not included in the determination
of NPRA as specified in § 512.305 if the
beneficiary does any of the following
during the episode:
(i) Ceases to meet any criterion listed
in § 512.230 (a) through (f).
(ii) Dies.
(iii) Initiates any BPCI model episode.
Subpart D—Pricing and Payment
§ 512.300 Determination of episode
quality-adjusted target prices and actual
episode payments.
(a) General. CMS establishes episode
quality-adjusted target prices and
calculates actual episode payments for
EPM participants for each performance
year of the EPMs as specified in this
section.
(b) Calculating episode qualityadjusted target prices. Episode qualityadjusted target prices and actual episode
payments are calculated for episodes
according to the following:
(1) For episodes involving AMI, MS–
DRGs.
(i) 280 (Acute myocardial infarction,
discharged alive with MCC).
(ii) 281 (Acute myocardial infarction,
discharged alive with CC).
(iii) 282 (Acute myocardial infarction,
discharged alive without CC/MCC).
(iv) 246 (Perc cardiovasc proc with
drug-eluting stent with MCC or 4+
vessels/stents).
(v) 247 (Perc cardiovasc proc with
drug-eluting stent without MCC).
(vi) 248 (Perc cardiovasc proc with
non-drug-eluting stent with MCC or 4+
vessels/stents).
(vii) 249 (Perc cardiovasc proc with
non-drug-eluting stent without MCC).
(viii) 250 (Perc cardiovasc proc
without coronary artery stent with
MCC).
(ix) 251 (Perc cardiovasc proc without
coronary artery stent without MCC).
(2) For episodes involving CABG,
MS–DRGs.
(i) 231 (Coronary bypass with PTCA
with MCC).
(ii) 232 (Coronary bypass with PTCA
without MCC).
(iii) 233 (Coronary bypass with
cardiac cath with MCC).
(iv) 234 (Coronary bypass with
cardiac cath without MCC).
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629
(v) 235 (Coronary bypass without
cardiac cath with MCC).
(vi) 236 (Coronary bypass without
cardiac cath without MCC).
(3) For episodes involving SHFFT,
MS–DRGs.
(i) 480 (Hip and femur procedures
except major joint with MCC).
(ii) 481 (Hip and femur procedures
except major joint with CC).
(iii) 482 (Hip and femur procedures
except major joint without CC or MCC).
(c) Calculating quality-adjusted target
prices. CMS calculates quality adjusted
target prices as specified in
§ 512.300(c)(1) through (13).
(1) Calculation of the historical
expenditures. CMS calculates historical
expenditure calculations based on the
following calendar years:
(i) Episodes beginning in 2013
through 2015 for performance years 1
and 2.
(ii) Episodes beginning in 2015
through 2017 for performance years 3
and 4.
(iii) Episodes beginning in 2017
through 2019 for performance year 5.
(2) Calculation of the quality-adjusted
target prices. CMS calculates qualityadjusted target prices based on a blend
of each EPM-participant hospitalspecific and regional historical episode
expenditures.
(i) The region corresponds to the U.S.
Census Division associated with the
primary address of the CCN of the EPM
participant and the regional component
is based on episodes occurring at all
acute care hospitals in said region,
except as follows.
(ii) In cases where an MSA selected
for participation in an EPM spans more
than one U.S. Census Division, the
entire MSA is grouped into the U.S.
Census Division where the largest city
by population in the MSA is located for
quality-adjusted target price and
episode payment calculations.
(3) Calculation of the quality-adjusted
target price blend. The quality-adjusted
target price blend consists of the
following:
(i) Two-thirds of the EPM
participant’s own historical episode
payments and one-third of the regional
historical episode payments for
performance years 1 and 2.
(ii) One-third of the EPM participant’s
own historical episode payments and
two-thirds of the regional historical
episode payments for performance year
3.
(iii) Regional historical episode
payments for performance years 4 and 5.
(4) Exception for low-volume
hospitals. (i) For the SHFFT model,
quality-adjusted target prices for
participants with fewer than 50 SHFFT
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model episodes in total across the 3
historical years of data used to calculate
the quality-adjusted target price are
based on 100 percent regional historical
episode payments.
(ii) For the AMI model, qualityadjusted target prices for anchor MS–
DRGs 280–282 for participants with
fewer than 75 AMI model episodes with
anchor MS–DRGs 280–282 in total
across the 3 historical years of data used
to calculate the quality-adjusted target
price are based on 100 percent regional
historical episode payments.
(iii) For the AMI model, qualityadjusted target prices for anchor MS–
DRGs 246–251 for participants with
fewer than 125 AMI model episodes
with anchor MS–DRGs 246–251 in total
across the 3 historical years of data used
to calculate the quality-adjusted target
price are based on 100 percent regional
historical episode payments.
(iv) For the CABG model, qualityadjusted target prices for participants
with fewer than 50 CABG model
episodes in total across the 3 historical
years of data used to calculate the
quality-adjusted target price are based
on 100 percent regional historical
episode payments.
(5) Exception for recently merged or
split hospitals. EPM-participant
hospital-specific historical episode
payments for EPM participants that
have undergone a merger, consolidation,
spin off or other reorganization that
results in a new hospital entity without
3 full years of historical claims data are
determined using the historical episode
payments attributed to their
predecessor(s).
(6) Episodes that straddle
performance years or payment updates.
Where an episode straddles
performance years or payment updates,
the quality-adjusted target price is based
on the quality-adjusted target price for
the type of episode as of the date of
admission for the anchor
hospitalization.
(7) Adjustments for certain
hospitalizations under the AMI and
CABG models—(i) Adjustments for
CABG model episodes with anchor MS–
DRGs 231–236. The episode benchmark
price for an episode with CABG anchor
MS–DRG 231–236 is set based on the
sum of expenditures during the anchor
hospitalization portion and post-anchor
hospitalization portion of the episode as
follows:
(A) The anchor hospitalization
portion of the episode benchmark price
is set based on the CABG anchor MS–
DRG at discharge.
(B) The post-anchor hospitalization
portion of the episode benchmark price
is set separately for episodes:
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(1) With AMI ICD–CM diagnosis code
on the anchor inpatient claim and
CABG anchor MS–DRG with major
complication or comorbidity (231, 233,
or 235).
(2) With AMI ICD–CM diagnosis code
on the anchor inpatient claim and
CABG anchor MS–DRG without major
complication or comorbidity (232, 234,
or 236).
(3) Without AMI ICD–CM diagnosis
code on the anchor inpatient claim and
CABG anchor MS–DRG with major
complication or comorbidity (231, 233,
or 235).
(4) Without AMI ICD–CM diagnosis
code on the anchor inpatient claim and
CABG anchor MS–DRG without major
complication or comorbidity (232, 234,
or 236).
(ii) Adjustments for Certain AMI
Model Episodes with CABG
Readmissions. The episode benchmark
price for an AMI model episode with
AMI anchor MS–DRG 280–282 or PCI
anchor MS–DRG 246–251 with a
readmission to any of CABG anchor
MS–DRGs 231–236 is the sum of the
anchor hospitalization portion of the
CABG episode benchmark price
corresponding to the MS–DRG of the
CABG readmission and the episode
benchmark price for the corresponding
anchor MS–DRG that would be applied
to the episode if it did not include a
CABG readmission.
(8) Inclusion of reconciliation
payments and Medicare repayments.
CMS will include certain reconciliation
payments and Medicare repayments
when updating quality adjusted target
prices.
(i) Inclusion of reconciliation
payments and Medicare repayments in
BPCI initiative. Reconciliation payments
and Medicare repayments under
§ 512.305(d)(2) and (3) and those from
episodes in the BPCI initiative are
included when updating qualityadjusted target prices for performance
years 3 through 5, subject to the
adjustment for CABG model episodes in
paragraph (c)(8)(ii) of this section.
(ii) Inclusion of reconciliation
payments and Medicare repayments in
CABG model episodes. When updating
prices for CABG episodes, reconciliation
payments and Medicare repayments
under § 512.305(d)(2) and (d)(3) and
from episodes included in the BPCI
initiative will be apportioned
proportionally to the anchor
hospitalization and post-anchor
hospitalization portions of historical
CABG episodes. The proportions will be
based on based on regional average
historical episode payments that
occurred during the anchor
hospitalization portion of CABG model
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episodes and regional average historical
episode payments that occurred during
the post-anchor anchor hospitalization
portion of CABG model episodes that
were initiated during the 3 historical
years.
(9) Communication of qualityadjusted target prices. CMS
communicates quality—adjusted target
prices to EPM participants prior to the
beginning of the performance period in
which they apply.
(10) Applicable time period for
updating quality-adjusted target prices.
In general quality-adjusted target prices
are updated to account for Medicare
payment updates no less than 2 times
per year, for updated quality-adjusted
target prices effective October 1 and
January 1, and at other intervals if
necessary as determined by CMS.
(i) For CABG model episodes, qualityadjusted target prices are updated by
separately updating the anchor
hospitalization portion of the episode
benchmark price and the post-anchor
hospitalization portion of the episode
benchmark price and then applying the
effective discount factor.
(ii) [Reserved].
(11) Trending of historical
expenditure data. CMS trends historical
expenditure data by applying separate
national trend factors to episode
payments. A trend factor is calculated
for each of the first 2 years in the
historical period based on the ratio of
national average episode payments in
the third year of the historical period to
national average episode payments in
each of the first 2 years in the historical
period, for the following scenarios:
(i) Separately for each SHFFT anchor
MS–DRGs 480 through 482.
(ii) Separately for each AMI anchor
MS–DRGs 280 through 282 and PCI
anchor MS–DRGs 246 through 251 for
AMI model episodes without CABG
readmissions.
(iii) For CABG model episodes,
separately for the anchor hospitalization
portion and post-anchor hospitalization
portion as follows:
(A) For the anchor hospitalization
portion of CABG model episodes,
separately for each CABG anchor MS–
DRGs 231 through 236.
(B) For the post-anchor
hospitalization portion of CABG model
episodes, separately for episodes:
(1) With AMI ICD–CM diagnosis code
on the anchor inpatient claim and
CABG anchor MS–DRG with major
complication or comorbidity (231, 233,
or 235).
(2) With AMI ICD–CM diagnosis code
on the anchor inpatient claim and
CABG anchor MS–DRG without major
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complication or comorbidity (232, 234,
or 236).
(3) Without AMI ICD–CM diagnosis
code on the anchor inpatient claim and
CABG anchor MS–DRG with major
complication or comorbidity (231, 233,
or 235).
(4) Without AMI ICD–CM diagnosis
code on the anchor inpatient claim and
CABG anchor MS–DRG without major
complication or comorbidity (232, 234,
or 236).
(12) Normalizing for wage variation.
CMS applies the CMS Price (Payment)
Standardization Detailed Methodology
to remove wage level differences in
calculating EPM-episode benchmark
prices and actual EPM-episode
payments. CMS reintroduces wage
index variations by multiplying the
blended and updated historical
payments by a wage normalization
factor of 0.7 * IPPS wage index + 0.3.
(13) Combining episodes to set stable
benchmark and quality-adjusted target
prices. For purposes of having sufficient
episode volume to set stable EPM
episode benchmark and quality-adjusted
target prices, where applicable, CMS
aggregates EPM episodes and portions of
EPM episodes across dimensions that
include anchor MS–DRGs, the presence
of an AMI ICD–CM diagnosis code on
the anchor inpatient claim, and the
presence of a major complication or
comorbidity for anchor CABG MS–
DRGs.
(i) For each EPM, CMS combines
episodes for anchor MS–DRGs adjusted
for severity and hospital-specific and
region-specific weights both for EPM
participants and IPPS hospitals within
each region for the purposes of blending
EPM-participant hospital-specific
components of the episode benchmark
price and region-specific components of
the episode benchmark price as follows:
(A) For SHFFT model episodes, CMS
combines episodes with anchor MS–
DRGs 480 through 482.
(B) For AMI model episodes with AMI
anchor MS–DRGs in 280 through 282 or
PCI anchor MS–DRGs 246 through 251
and without readmissions for CABG
MS–DRGs, episodes with AMI anchor
MS–DRGs 280 through 282 are grouped
separately from episodes with PCI
anchor MS–DRGs 246 through 251.
(C) For CABG model episodes with
CABG anchor MS–DRGs in 231 through
236, CMS separately groups the anchor
hospitalization portion and the postanchor hospitalization portion.
(1) For the anchor hospitalization
portion of CABG model episodes, the
anchor hospitalization portion is
grouped by the CABG anchor MS–DRG.
(2) For the post-anchor hospitalization
portion of CABG model episodes, the
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post-anchor hospitalization portion is
grouped by episodes:
(i) With AMI ICD–CM diagnosis code
on the anchor inpatient claim and
anchor MS–DRG with major
complication or comorbidity (231, 233,
or 235).
(ii) With AMI ICD–CM diagnosis code
on the anchor inpatient claim and
anchor MS–DRG without major
complication or comorbidity (232, 234,
or 236).
(iii) Without AMI ICD–CM diagnosis
code on the anchor inpatient claim and
anchor MS–DRG with major
complication or comorbidity (231, 233,
or 235).
(iv) Without AMI ICD–CM diagnosis
code on the anchor inpatient claim and
anchor MS–DRG without major
complication or comorbidity (232, 234,
or 236).
(ii) After blending EPM-participant
hospital-specific and regional-specific
components of the combined episodes,
CMS separates episodes to calculate
episode benchmark prices according to
the episode anchor MS–DRG, subject to
adjustments described in
§ 512.300(c)(7).
(d) Effective discount factor. An EPM
participant’s quality-adjusted target
prices incorporate an effective discount
factor to reflect Medicare’s portion of
reduced expenditures from the EPM as
described in this section.
(1) Effective discount factor for
reconciliation payments. The effective
discount factor for reconciliation
payment in all performance years is
determined by the EPM participant’s
quality category as provided in
§ 512.315(b)(5), (c)(5), and (d)(5).
(2) Applicable discount factor for
repayment amounts. The applicable
discount factor for repayment amounts
is—
(i) Not applicable in performance year
1, as the requirement for EPM
participant repayment is waived.
(ii) Not applicable in performance
year 2 as the requirement for EPM
participant repayment is waived except
for an EPM participant that has elected
downside risk for that performance year.
(iii) In performance year 2 for an EPM
participant that has elected downside
risk and performance years 3 and 4
when partial EPM participant
repayment applies, as determined by the
EPM participant’s quality category as
provided in § 512.315(b)(5), (c)(5), and
(d)(5).
(iv) Not applicable in performance
year 5 when full EPM participant
repayment applies, as determined by the
effective discount factor that applies to
repayment amounts as specified in
paragraph (d)(1) of this section.
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631
(e) Exceptions that apply to both
quality-adjusted target prices and actual
episode payments—(1) Exception for
high episode payment. For each EPM,
actual episode payments and historical
episode payments are capped at 2
standard deviations above the mean
regional episode payment for the EPMparticipant hospital-specific and
regional components of the qualityadjusted target price under the EPM, as
well as for calculating actual episode
payments under the EPM during a
performance year, subject to the
exceptions noted in paragraphs (e)(1)(i)
through (iii) of this section.
(i) For AMI model episodes with
anchor MS–DRGs 280–282 or PCI
anchor MS–DRGs 246 through 251
without readmission for CABG MS–
DRGs 231 through 236, payments are
capped separately based on the anchor
MS–DRG.
(ii) For CABG model episodes with
CABG MS–DRGs 231 through 236,
episode payments during the anchor
hospitalization portion are capped
separately from episode payments
during the post-anchor hospitalization
portion as follows.
(A) Payments during the anchor
hospitalization portion are capped
based on the CABG anchor MS–DRGs
231 through 236.
(B) Payments during the post-anchor
hospitalization portion are capped
separately for episodes:
(1) With an AMI ICD–CM diagnosis
code on the anchor inpatient claim and
CABG anchor MS–DRG with major
complication or comorbidity (231, 233,
or 235).
(2) With an AMI ICD–CM diagnosis
code on the anchor inpatient claim and
CABG anchor MS–DRG without major
complication or comorbidity (232, 234,
or 236).
(3) Without an AMI ICD–CM
diagnosis code on the anchor inpatient
claim and CABG anchor MS–DRG with
major complication or comorbidity (231,
233, or 235).
(4) Without an AMI ICD–CM
diagnosis code on the anchor inpatient
claim and CABG anchor MS–DRG
without major complication or
comorbidity (232, 234, or 236).
(iii) For AMI episodes with either
AMI anchor MS–DRGs 280 through 282
or PCI anchor MS–DRGs 246 through
251 and with readmission for a CABG
MS–DRG 231–236, the cap is applied
separately to the payments during the
CABG readmission and all other
payments during the episode.
(A) For payments during the CABG
readmission portion of the episode, the
cap is applied for the anchor
hospitalization portion of a CABG
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episode for the corresponding CABG
readmission MS–DRG.
(B) For all other payments during the
episode, the cap is applied to the AMI
model episodes with AMI anchor MS–
DRGs 280 through 282 or PCI anchor
MS–DRGs 246 through 251 and without
readmission for CABG MS–DRGs
corresponding to the AMI anchor MS–
DRG.
(2) Exclusion of incentive programs
and add-on payments under existing
Medicare payment systems. Certain
incentive programs and add-on
payments are excluded by CMS’
application of the CMS Price (Payment)
Standardization Detailed Methodology
used for the Medicare spending per
beneficiary measure in the Hospital
Value-Based Purchasing Program and
Physician Value-Based Payment
Modifier Program as specified in
§ 414.1235(a)(6) and (c)(1) of this
chapter.
(f) Allocation of payments for services
that straddle the episode—(1) General.
Services included in the episode that
begin before the start of or continue
beyond the end of an EPM episode are
prorated so that only the portion
attributable to care furnished during the
episode are included in the calculation
of actual episode payments.
(2) Proration of services. Payments for
services that straddle the episode are
prorated using the following
methodology:
(i) Non-IPPS inpatient services and
other inpatient services. Non-IPPS
inpatient services, and services
furnished by other inpatient providers
that extend beyond the end of the
episode are prorated according to the
percentage of the actual length of stay
(in days) that falls within the episode.
(ii) Home health agency services.
Home health services paid under the
prospective payment system in part 484,
subpart E of this chapter are prorated
according to the percentage of days,
starting with the first billable service
date (start of care date) and through and
including the last billable service date,
that occur during the episode. This
methodology is applied in the same way
if the home health services begin (the
start of care date) prior to the start of the
episode.
(3) IPPS services. IPPS claim amounts
that extend beyond the end of the
episode are prorated according to the
geometric mean length of stay, using the
following methodology:
(i) The first day of the IPPS stay is
counted as 2 days.
(ii) If the actual length of stay that
occurred during the episode is equal to
or greater than the MS–DRG geometric
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mean, the normal MS–DRG payment is
fully allocated to the episode.
(iii) If the actual length of stay that
occurred during the episode is less than
the geometric mean, the normal MS–
DRG payment amount is allocated to the
episode based on the number of
inpatient days that fall within the
episode.
(iv) If the full amount is not allocated
to the episode, any remainder amount is
allocated to the post-episode spending
calculation (determined in § 512.307(c)).
§ 512.305 Determination of the NPRA and
reconciliation process.
(a) General. Providers and suppliers
furnishing items and services included
in the EPM episode bill for such items
and services in accordance with existing
rules and as if this part were not in
effect.
(b) Annual reconciliation. CMS
annually performs the processes
described in paragraphs (c) and (d) of
this section to determine actual episode
payments for each EPM episode for the
performance year (except for episodes
that have been canceled in accordance
with § 512.240(a)(2), (b)(2), and (c)(2))
and determines the amount of a
reconciliation payment to or Medicare
repayment amount from EPM
participants, if any, for that performance
year.
(c) Annual reconciliation to establish
NPRA. (1) Beginning 2 months after the
end of each performance year and using
the most recent claims data and nonclaims-based payment data available,
CMS performs a reconciliation
calculation to establish an NPRA for
each EPM participant based on the
following process.
(2) CMS—
(i) Assesses whether EPM participants
are in an acceptable or better quality
category under § 512.315; and
(ii) Calculates the NPRA for each EPM
participant for each performance year by
comparing the quality-adjusted target
prices and the EPM participant’s actual
episode payments for the performance
year or portion of that performance year
as described in § 512.300 as follows:
(A) Determines actual EPM episode
payments for each EPM episode
included in the performance year or
portion of that performance year.
(B) Multiplies the quality-adjusted
target price by the number of noncanceled EPM episodes included in the
performance year or portion of that
performance year to which that episode
quality-adjusted price applies and
aggregates these amounts.
(C) Subtracts the amount determined
under paragraph (c)(2)(ii)(A) of this
section from the amount determined
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under paragraph (c)(2)(ii)(B) of this
section.
(iii) Applies the following:
(A) Limitation on loss. Except as
provided in paragraphs (c)(2)(iii)(C) and
(D) of this section, the total amount of
the NPRA and subsequent reconciliation
calculation for a performance year or
portion of that performance year cannot
exceed the following:
(1) For performance year 2—
(i) Five percent of the amount
calculated in paragraph (c)(2)(ii)(B) of
this section for the performance year if
the EPM participant elected downside
risk for that year.
(ii) Zero percent of the amount
calculated in paragraph (c)(2)(ii)(B) of
this section for the performance year for
all other EPM participants.
(2) For performance year 3, 5 percent
of the amount calculated in paragraph
(c)(2)(ii)(B) of this section for the
performance year.
(3) For performance year 4, 10 percent
of the amount calculated in paragraph
(c)(2)(ii)(B) of this section for the
performance year.
(4) For performance year 5, 20 percent
of the amount calculated in paragraph
(c)(2)(ii)(B) of this section for the
performance year.
(B) Limitation on gain. The total
amount of the NPRA and subsequent
reconciliation calculation for a
performance year cannot exceed the
following:
(1) For performance years 1, 2, and 3,
5 percent of the amount calculated in
paragraph (c)(2)(ii)(B) of this section for
the performance year.
(2) For performance year 4, 10 percent
of the amount calculated in paragraph
(c)(2)(ii)(B) of this section for the
performance year.
(3) For performance year 5, 20 percent
of the amount calculated in paragraph
(c)(2)(ii)(B) of this section for the
performance year.
(C) Financial loss limits for rural
hospitals, SCHs, MDHs, and RRCs. The
total amount of the NPRA and
subsequent reconciliation calculation
for a performance year cannot exceed
the following:
(1) For performance year 2—
(i) Three percent of the amount
calculated in paragraph (c)(2)(ii)(B) of
this section for the performance year if
the EPM participant elected downside
risk for that year.
(ii) Zero percent of the amount
calculated in paragraph (c)(2)(ii)(B) of
this section for the performance year for
all other EPM participants.
(2) For performance year 3, 3 percent
of the amount calculated in paragraph
(c)(2)(ii)(B) of this section for the
performance year.
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(3) For performance years 4 and 5, 5
percent of the amount calculated in
paragraph (c)(2)(ii)(B) of this section for
the performance year.
(D) Financial loss limits for EPM
volume protection hospitals. EPM
participants may be determined to be an
EPM volume protection hospital under
an EPM.
(1) An EPM participant is determined
to be an EPM volume protection
hospital under a model if their total
volume of EPM historical episodes is at
or below the 10th percentile of hospitalspecific historical EPM episodes for
hospitals with one or more episodes
located in the MSAs eligible for
selection into that specific EPM.
(2) CMS establishes thresholds as
specified in paragraph (c)(2)(iii)(D)(1) of
this section based on episodes
beginning in the time period specified
in § 512.300(c)(1)(i).
(3) For an EPM participant
determined to have a low volume of
episodes within a model as specified in
paragraph (c)(2)(iii)(D)(1) but not
paragraph (c)(2)(iii)(C) of this section,
then the financial loss limits specified
under paragraph (c)(2)(iii)(C) of this
section are applied.
(iv) CMS posts to the CMS Web site
the threshold established in this section
and a list of CCNs of EPM participants
that are classified as EPM volume
protection hospitals.
(v) CMS communicates to each EPM
participant whether it is classified as an
EPM volume protection hospital at the
same time that CMS communicates
quality-adjusted target prices as
described in § 512.300(c)(9).
(E) Application of limitations on
losses and gains. CMS establishes limits
on losses and gains specifically with
respect to and separately for each EPM.
(d) Determination of reconciliation or
repayment amount—(1) General. (i)
Subject to paragraphs (c)(2)(iii)(B) and
(d)(1)(iii) of this section, for
performance year 1, the reconciliation
payment (if any) is equal to the NPRA.
(ii) Subject to paragraphs (c)(2)(iii)(A)
through (D) and (d)(1)(iii) of this
section, for performance years 2 through
5, results from the subsequent
reconciliation calculation for a prior
year’s reconciliation, as described in
§ 512.307, and the post-episode
spending and ACO overlap calculations,
as described in § 512.307(b) and (c), are
added to the current year’s NPRA in
order to determine the reconciliation or
repayment amount.
(iii) The reconciliation or repayment
amount may be adjusted as described in
§ 512.460(b).
(2) Reconciliation payment. If the
amount described in paragraph (d)(1) of
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this section is positive and the EPM
participant quality category as described
in § 512.315 is acceptable, good, or
excellent, Medicare pays the EPM
participant a reconciliation payment in
an amount equal to the amount
described in paragraph (d)(1) of this
section. If the EPM participant’s quality
category as described in § 512.315 is
unacceptable, the EPM participant is not
eligible to be paid a reconciliation
payment.
(3) Repayment amount. If the amount
described in paragraph (d)(1) of this
section is negative, the EPM participant
pays to Medicare an amount equal to the
amount described in paragraph (d)(1) of
this section, in accordance with
§ 405.371 of this chapter. CMS waives
this requirement for performance year 1.
(e) EPM participants found to be
engaged in inappropriate and systemic
under delivery of care. If the EPM
participant is found to be engaged in an
inappropriate and systemic under
delivery of care as specified in
§ 512.460(b)(1)(i)(C), the quality of the
care provided must be considered to be
seriously compromised and the EPM
participant must be ineligible to receive
or retain a reconciliation payment for
any period in which such under
delivery of care was found to occur.
(f) Reconciliation report. (1) CMS
issues each EPM participant a
reconciliation report for the
performance year. Each reconciliation
report contains the following:
(i) Information on the EPM
participant’s composite quality score
described in § 512.315.
(ii) The total actual episode payments
for the EPM participant.
(iii) The NPRA.
(iv) Whether the EPM participant is
eligible for a reconciliation payment or
must make a repayment to Medicare.
(v) The NPRA and subsequent
reconciliation calculation amount for
the previous performance year, as
applicable.
(vi) The post-episode spending
amount and ACO overlap calculation for
the previous performance year, as
applicable.
(vii) The reconciliation payment or
repayment amount.
(2) For performance year 2, the
reconciliation report would also include
information separately for the
performance year 2 (DR) and
performance year 2 (NDR) portions of
that year.
§ 512.307
Subsequent calculations.
(a) Subsequent reconciliation
calculation. (1) Fourteen months after
the end of each performance year, CMS
performs an additional calculation,
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which accounts for changes since the
calculation of the initial NPRA, using
claims data and non-claims-based
payment data available at that time, to
account for final claims run-out, final
changes in non-claims-based payment
data, and any additional episode
cancellations due to overlap or other
reasons as specified in § 512.240(a)(2),
(b)(2), and (c)(2).
(2) The additional calculation occurs
concurrently with the reconciliation
process for the most recent performance
year and determines the subsequent
calculation amount as follows:
(i) If the result of the subsequent
reconciliation calculation is different
than zero, CMS applies the stop-loss
and stop-gain limits in
§ 512.305(c)(2)(iii)(A) through (D) to the
calculations in aggregate for that
performance year (the initial
reconciliation from
§ 512.305(c)(2)(ii)(C), before application
of the stop-loss and stop-gain limits, and
the subsequent reconciliation
calculation) to ensure the calculations
in aggregate do not exceed the stop-loss
or stop-gain limits. CMS then takes the
difference between that amount and the
initial NPRA after application of the
stop-loss and stop-gain limits in
§ 512.305(c)(2)(iii)(A) through (D) to
determine the subsequent calculation
amount.
(ii) CMS then applies the subsequent
calculation amount to the NPRA for the
most recent performance year in order
to determine the reconciliation amount
or repayment amount for the most
recent performance year.
(iii) Because EPM participants that
elected downside risk in performance
year do not have financial repayment
responsibility for performance year 1,
for the performance year 2
reconciliation report only, the
subsequent calculation amount (for
performance year 1) is applied to the
performance year 1 NPRA to ensure that
the combined amount is not less than
zero.
(iv) Because EPM participants that
have not elected downside risk in
performance year 2 do not have
financial repayment responsibility for
performance years 1 or 2, for the
performance year 2 and performance
year 3 reconciliation reports only, the
subsequent calculation amount (for
performance year 1 or performance year
2) is applied to the performance year 1
NPRA or performance year 2 NPRA to
ensure that the combined amount is not
less than zero.
(b) Additional calculations to
determine the reconciliation payment or
repayment amount. CMS reduces the
reconciliation payment or increase the
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repayment amount for the subsequent
performance year to account for shared
savings paid to the ACO in the prior
performance year by the amount of the
EPM discount factor paid out to the
ACO as shared savings in the prior
performance year. This adjustment is
only made when the EPM participant is
a participant or provider/supplier in the
ACO and the EPM beneficiary is not
prospectively assigned to one of the
following:
(1) An ACO in the Next Generation
ACO model.
(2) An ACO in Track 3 of the
Medicare Shared Savings Program.
(3) An ACO in the Comprehensive
ESRD Care Model that includes
downside risk.
(c) Increases in post-episode
spending. If the average post-episode
Medicare Parts A and B payments for an
EPM participant in the prior
performance year is greater than 3
standard deviations above the regional
average post-episode payments for the
same performance year, then the
spending amount exceeding 3 standard
deviations above the regional average
post-episode payments for the same
performance year is added to the
calculation of the reconciliation or
repayment amount for the subsequent
performance year.
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§ 512.310
Appeals process.
(a) Notice of calculation error (first
level of appeal). Subject to the
limitations on review in subpart D of
this part, if an EPM participant wishes
to dispute calculations involving a
matter related to payment, a CR
incentive payment, reconciliation
amounts, repayment amounts, the use of
quality measure results in determining
the composite quality score, or the
application of the composite quality
score during reconciliation, the EPM
participant is required to provide
written notice of the calculation error,
in a form and manner specified by CMS.
(1) Unless the EPM participant
provides such notice, CMS deems final
the reconciliation report and CR
incentive payment report 45 calendar
days after the reconciliation report or
CR incentive payment report is issued
and proceeds with the payment or
repayment processes as applicable.
(2) If CMS receives a notice of a
calculation error within 45 calendar
days of the issuance of the
reconciliation report or CR incentive
payment report, CMS responds in
writing within 30 calendar days to
either confirm that there was an error in
the calculation or verify that the
calculation is correct, although CMS
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reserves the right to an extension upon
written notice to the EPM participant.
(3) Only EPM participants may use
the notice of calculation error process
described in this part.
(b) Dispute resolution process (second
level of appeal). (1) If the EPM
participant is dissatisfied with CMS’
response to the notice of a calculation
error, the EPM participant may request
a reconsideration review in a form and
manner as specified by CMS.
(2) The reconsideration request must
provide a detailed explanation of the
basis for the dispute and include
supporting documentation for the EPM
participant’s assertion that CMS or its
representatives did not accurately
calculate the NPRA, the reconciliation
payment, the CR incentive payment, or
the repayment amount in accordance
with subpart D of this part.
(3) If CMS does not receive a request
for reconsideration from the EPM
participant within 10 calendar days of
the issue date of CMS’ response to the
EPM participant’s notice of calculation
error, then CMS’ response to the
calculation error is deemed final and
CMS proceeds with the applicable
processes, as described in subpart D of
this part.
(4) The CMS reconsideration official
notifies the EPM participant in writing
within 15 calendar days of receiving the
EPM participant’s review request of the
following:
(i) The date, time, and location of the
review.
(ii) The issues in dispute.
(iii) The review procedures.
(iv) The procedures (including format
and deadlines) for submission of
evidence.
(5) The CMS reconsideration official
takes all reasonable efforts to schedule
the review to occur no later than 30
days after the date of receipt of the
notification.
(6) The provisions at § 425.804(b), (c),
and (e) of this chapter are applicable to
reviews conducted in accordance with
the reconsideration review process for
the EPM.
(7) The CMS reconsideration official
issues a written determination within 30
days of the review. The determination is
final and binding.
(8) Only EPM participants may use
the dispute resolution process described
in this part.
(c) Exception to the notice of
calculation error process. If the EPM
participant contests a matter that does
not involve an issue contained in, or a
calculation which contributes to, a
reconciliation report or CR incentive
payment report a notice of calculation
error is not required. In these instances,
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if CMS does not receive a request for
reconsideration from the EPM
participant within 10 calendar days of
the notice of the initial determination,
the initial determination is deemed final
and CMS proceeds with the action
indicated in the initial determination.
This does not apply to the limitations
on review in paragraph (e) of this
section.
(d) Notice of an EPM participant’s
termination from the EPM. If an EPM
participant receives notification that it
has been terminated from the EPM and
wishes to appeal such termination, it
must provide a written request for
reconsideration to CMS requesting
review of the termination within 10
calendar days of the notice. CMS has 30
days to respond to the EPM participant’s
request for review. If the EPM
participant fails to notify CMS, the
termination is deemed final.
(e) Limitations on review. In
accordance with section 1115A (d)(2) of
the Act, there is no administrative or
judicial review under sections 1869 or
1878 of the Act or otherwise for the
following:
(1) The selection of models for testing
or expansion under section 1115A of the
Act.
(2) The selection of organizations,
sites, or participants to test those
models selected.
(3) The elements, parameters, scope,
and duration of such models for testing
or dissemination.
(4) Determinations regarding budget
neutrality under section 1115A(b)(3) of
the Act.
(5) The termination or modification of
the design and implementation of a
model under section 1115A(b)(3)(B) of
Act.
(6) Decisions to expand the duration
and scope of a model under section
1115A(c) of the Act, including the
determination that a model is not
expected to meet criteria described in
paragraph (e)(1) or (2) of this section.
§ 512.315 Composite quality scores for
determining reconciliation payment
eligibility and effective and applicable
discount factors.
(a) General. An EPM participant’s
eligibility for a reconciliation payment
under § 512.305, and the determination
of effective discount factors and
applicable discount factors for
reconciliation and repayment,
respectively, under paragraphs (b)(5),
(c)(5), and (d)(5) of this section, for a
performance year depend on the EPM
participant’s EPM composite quality
score (including any quality
performance points and quality
improvement points earned) for that
performance year.
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(b) AMI model—(1) AMI model
composite quality score. CMS calculates
an AMI model composite quality score
for each AMI model participant for each
performance year, which equals the sum
of the following:
(i) The AMI model participant’s
quality performance points for the
Hospital 30-Day, All-Cause, RiskStandardized Mortality Rate (RSMR)
Following Acute Myocardial Infarction
(NQF #0230) measure described in
§ 512.411(a)(1). This measure is
weighted at 50 percent of the AMI
model composite quality score.
(ii) The AMI model participant’s
quality performance points for the
Excess Days in Acute Care after
Hospitalization for AMI measure
described in § 512.411(a)(2). This
measure is weighted at 20 percent of the
AMI model composite quality score.
(iii) The AMI model participant’s
quality performance points for the
Hospital Consumer Assessment of
Healthcare Providers and Systems
Survey (NQF #0166) measure described
in § 512.411(a)(3). This measure is
weighted at 20 percent of the AMI
model composite quality score.
(iv) Any additional quality
improvement points the AMI model
participant may earn as a result of
demonstrating improvement on the
quality measures in § 512.411(a), as
described in paragraph (b)(3) of this
section.
(v) If applicable, 2 additional points
for successful Hybrid Hospital 30-Day,
All-Cause, Risk-Standardized Mortality
Rate Following Acute Myocardial
Infarction (AMI) Hospitalization (NQF
#2473) measure voluntary data
submission as described in
§ 512.411(b)(2). Successful submission
is weighted at 10 percent of the AMI
model composite quality score.
(2) AMI model quality performance
points. CMS computes quality
performance points for each quality
measure based on the AMI model
participant’s performance percentile
relative to the national distribution of
all subsection (d) hospitals that are
eligible for payment under the IPPS and
meet the minimum measure patient case
or survey count.
(i) For the Hospital 30-Day, All-Cause,
Risk-Standardized Mortality Rate
(RSMR) Following Acute Myocardial
Infarction (NQF #0230) measure
described in § 512.411(a)(1), CMS
assigns the AMI model participant
measure value to a performance
percentile and then quality performance
points are assigned based on the
following performance percentile scale:
(A) 10.00 points for ≥ 90th.
(B) 9.25 points for ≥ 80th and < 90th.
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(C) 8.50 points for ≥ 70th and < 80th.
(D) 7.75 points for ≥ 60th and < 70th.
(E) 7.00 points for ≥ 50th and < 60th.
(F) 6.25 points for ≥ 40th and < 50th.
(G) 5.50 points for ≥ 30th and < 40th.
(H) 0.00 points for < 30th.
(ii) For the Excess Days in Acute Care
after Hospitalization for AMI measure
described in § 512.411(a)(2), CMS
assigns the AMI model participant
measure value to a performance
percentile and then quality performance
points are assigned based on the
following performance percentile scale:
(A) 4.00 points for ≥ 90th.
(B) 3.70 points for ≥ 80th and < 90th.
(C) 3.40 points for ≥ 70th and < 80th.
(D) 3.10 points for ≥ 60th and < 70th.
(E) 2.80 points for ≥ 50th and < 60th.
(F) 2.50 points for ≥ 40th and < 50th.
(G) 2.20 points for ≥ 30th and < 40th.
(H) 0.00 points for < 30th.
(iii) For the Hospital Consumer
Assessment of Healthcare Providers and
Systems Survey (NQF #0166) measure
described in § 512.411(a)(3), CMS
assigns the AMI model participant
measure value to a performance
percentile and then quality performance
points are assigned based on the
following performance percentile scale:
(A) 4.00 points for ≥ 90th.
(B) 3.70 points for ≥ 80th and < 90th.
(C) 3.40 points for ≥ 70th and < 80th.
(D) 3.10 points for ≥ 60th and < 70th.
(E) 2.80 points for ≥ 50th and < 60th.
(F) 2.50 points for ≥ 40th and < 50th.
(G) 2.20 points for ≥ 30th and < 40th.
(H) 0.00 points for < 30th.
(3) AMI model quality improvement
points. If an AMI model participant’s
own improvement in the participant’s
measure point estimate from the
previous year on an individual measure
described in § 512.411(a), regardless of
the participant’s measure point estimate
starting and ending values, falls into the
top 10 percent of all subsection (d)
hospitals that are eligible for payment
under the IPPS based on the national
distribution of measure improvement
over the most recent 2 years, then the
AMI model participant is eligible to
receive quality improvement points up
to 10 percent of the total available
points for that measure. The AMI model
composite quality score is capped at 20
points.
(4) Exception for AMI model
participants without a measure value. In
the case of an AMI model participant
without a measure value that would
allow CMS to assign quality
performance points for that quality
measure, CMS assigns the 50th
percentile quality performance points to
the AMI model participant for the
individual measure.
(i) An AMI model participant does not
have a measure value for the—
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635
(A) Hospital 30-Day, All-Cause, RiskStandardized Mortality Rate (RSMR)
Following Acute Myocardial Infarction
(NQF #0230) measure described in
§ 512.411(a)(1) if the participant does
not meet the minimum 25 case count.
(B) Excess Days in Acute Care after
Hospitalization for AMI measure
described in § 512.411(a)(2) if the
participant does not meet the minimum
25 case count.
(C) Hospital Consumer Assessment of
Healthcare Providers and Systems
Survey (NQF #0166) measure described
in § 512.411(a)(3) if the participant does
not meet the minimum of 100
completed surveys and does not have 4
consecutive quarters of HCAHPS data.
(D) Measures described in paragraphs
(4)(i)(A) through (C) of this section, if
CMS identifies an error in the data used
to calculate the measure and suppresses
the measure value.
(5) Establishing AMI model
reconciliation payment eligibility and
effective and applicable discount
factors. CMS determines reconciliation
payment eligibility and the effective
discount factor for reconciliation
payments in all performance years and
repayment amounts in performance year
5, as well as the applicable discount
factor for repayment amounts in
performance year 2 for AMI model
participants who elect early downside
risk, and performance years 3 and 4 for
all AMI model participants based on the
AMI model composite quality score
described in paragraph (b)(1) of this
section.
(i) Reconciliation payment eligibility
requires an acceptable or better quality
category, defined as an AMI model
composite quality score of greater than
or equal to 3.8.
(ii) Effective discount factor for
reconciliation payments.
(A) A 3.0 percentage point effective
discount factor for AMI model
participants in the unacceptable or
acceptable category, defined as an AMI
model composite quality score that is
less than 6.3.
(B) A 2.0 percentage point effective
discount factor for AMI model
participants in the good quality
category, defined as an AMI model
composite quality score that is greater
than or equal to 6.3 and less than or
equal to 15.0.
(C) A 1.5 percentage point effective
discount factor for AMI model
participants in the excellent quality
category, defined as an AMI model
composite quality score that is greater
than 15.0.
(iii) Applicable discount factor for
repayment amount in performance year
2 for AMI model participants who elect
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early downside risk, and years 3 and 4
for all AMI model participants.
(A) A 2.0 percentage point applicable
discount factor for AMI model
participants in the unacceptable or
acceptable quality category, defined as
an AMI model composite quality score
of less than 6.3.
(B) A 1.0 percentage point applicable
discount factor for AMI model
participants in the good quality
category, defined as an AMI model
composite quality score that is greater
than or equal to 6.3 and less than or
equal to 15.0.
(C) A 0.5 percentage point applicable
discount factor for AMI model
participants in the excellent quality
category, defined as an AMI model
composite quality scores that is greater
than 15.0.
(iv) Effective discount factor for
repayment amount in performance year
5 for all AMI model participants.
(A) A 3.0 percentage point applicable
discount factor for AMI model
participants in the unacceptable or
acceptable quality category, defined as
an AMI model composite quality score
of less than 6.3.
(B) A 2.0 percentage point applicable
discount factor for AMI model
participants in the good quality
category, defined as an AMI model
composite quality score that is greater
than or equal to 6.3 and less than or
equal to 15.0.
(C) A 1.5 percentage point applicable
discount factor for AMI model
participants in the excellent quality
category, defined as an AMI model
composite quality scores that is greater
than 15.0.
(c) CABG model—(1) CABG model
composite quality score. CMS calculates
a CABG model composite quality score
for each CABG model participant for
each performance year, which equals
the sum of the following:
(i) The CABG model participant’s
quality performance points for the
Hospital 30-Day, All-Cause, RiskStandardized Mortality Rate (RSMR)
Following Coronary Artery Bypass Graft
(CABG) Surgery (NQF #2558) measure
described in § 512.412(a)(1). This
measure is weighted at 70 percent of the
CABG model composite quality score.
(ii) The CABG model participant’s
quality performance points for the
Hospital Consumer Assessment of
Healthcare Providers and Systems
Survey (NQF #0166) measure described
in § 512.412(a)(2). This measure is
weighted at 20 percent of the CABG
model composite quality score.
(iii) If applicable, 2 additional points
for successful submission of the STS
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CABG data that supports the following
7 measures:
(A) NQF #0134—CABG: Use of
Internal Mammary Artery in Patients
with Isolated CABG Surgery.
(B) NQF #0236—CABG: Preoperative
Beta Blocker in Patients with Isolated
CABG Surgery.
(C) NQF #0129—CABG: Prolonged
Intubation (defined as >24hrs post
surgery).
(D) NQF #0130—CABG: Deep Sternal
Wound Infection Rate.
(E) NQF #0131—CABG: Stroke.
(F) NQF #0114—CABG: Postoperative
Renal Failure.
(G) NQF #0115—CABG: Surgical ReExploration. The submission of this
measure data is weighted at 10 percent
of the CABG model composite quality
score.
(iv) Any additional quality
improvement points the CABG model
participant may earn as a result of
demonstrating improvement on the
quality measures in paragraphs (b)(1)(i)
and (ii) of this section, as described in
paragraph (c)(3) of this section.
(2) CABG model quality performance
points. CMS computes quality
performance points for each quality
measure based on the CABG model
participant’s performance percentile
relative to the national distribution of
all subsection (d) hospitals that are
eligible for payment under the IPPS and
meet the minimum measure patient case
or survey count.
(i) For the Hospital 30-Day, All-Cause,
Risk-Standardized Mortality Rate
(RSMR) Following Coronary Artery
Bypass Graft (CABG) Surgery (NQF
#2558) measure described in
§ 512.412(a)(1), CMS assigns the CABG
model participant measure value to a
performance percentile and then quality
performance points are assigned based
on the following performance percentile
scale:
(A) 14.00 points for ≥ 90th.
(B) 12.95 points for ≥ 80th and < 90th.
(C) 11.90 points for ≥ 70th and < 80th.
(D) 10.85 points for ≥ 60th and < 70th.
(E) 9.80 points for ≥ 50th and < 60th.
(F) 8.75 points for ≥ 40th and < 50th.
(G) 7.70 points for ≥ 30th and < 40th.
(H) 0.00 points for < 30th.
(ii) For the Hospital Consumer
Assessment of Healthcare Providers and
Systems Survey (NQF #0166) measure
described in § 512.412(a)(2), CMS
assigns the CABG model participant
measure value to a performance
percentile and then quality performance
points are assigned based on the
following performance percentile scale:
(A) 4.00 points for ≥ 90th.
(B) 3.70 points for ≥ 80th and < 90th.
(C) 3.40 points for ≥ 70th and < 80th.
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(D) 3.10 points for ≥ 60th and < 70th.
(E) 2.80 points for ≥ 50th and < 60th.
(F) 2.50 points for ≥ 40th and < 50th.
(G) 2.20 points for ≥ 30th and < 40th.
(H) 0.00 points for < 30th.
(3) CABG model quality improvement
points. If a CABG model participant’s
own improvement in the participant’s
measure point estimate from the
previous year on an individual measure
described in § 512.412(a), regardless of
the participant’s measure point estimate
starting and ending values, falls into the
top 10 percent of all subsection (d)
hospitals that are eligible for payment
under the IPPS based on the national
distribution of measure improvement
over the most recent 2 years, then the
CABG model participant is eligible to
receive quality improvement points up
to 10 percent of the total available
points for that measure. The total CABG
model composite quality score is
capped at 20 points.
(4) Exception for CABG model
participants without a measure value. In
the case of a CABG model participant
without a measure value that would
allow CMS to assign quality
performance points for that quality
measure, CMS assigns the 50th
percentile quality performance points to
the hospital for the individual measure.
(i) A CABG model participant does
not have a measure value for the—
(A) Hospital 30-Day, All-Cause, RiskStandardized Mortality Rate (RSMR)
Following Coronary Artery Bypass Graft
(CABG) Surgery (NQF #2558) measure
described in § 512.412(a)(1) if the CABG
model participant does not meet the
minimum 25 case count.
(B) Hospital Consumer Assessment of
Healthcare Providers and Systems
Survey (NQF #0166) measure described
in § 512.412(a)(2) if the CABG model
participant does not meet the minimum
of 100 completed surveys and does not
have 4 consecutive quarters of HCAHPS
data.
(C) Measures described in paragraphs
(c)(4)(i)(A) and (c)(4)(i)(B) of this
section, if CMS identifies an error in the
data used to calculate the measure and
suppresses the measure value.
(5) Establishing CABG model
reconciliation payment eligibility and
effective and applicable discount
factors. CMS determines reconciliation
payment eligibility and the effective
discount factor for reconciliation
payments in all performance years and
repayment amounts in performance year
5, as well as applicable discount factor
for repayment amounts in performance
years 2 for CABG model participants
who elect early downside risk, and for
performance years 3 and 4 for all CABG
model participants, based on the CABG
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model composite quality score
described in paragraph (c)(1) of this
section.
(i) Reconciliation payment eligibility
requires an acceptable or better quality
category, defined as a CABG model
composite quality score of greater than
2.2.
(ii) Effective discount factor for
reconciliation payments.
(A) A 3.0 percentage point effective
discount factor for CABG model
participants in the unacceptable or
acceptable quality category, defined as a
CABG model composite quality score
that is less than or equal to 3.4.
(B) A 2.0 percentage point effective
discount factor for CABG model
participants in the good quality
category, defined as a CABG model
composite quality score that is greater
than 3.4 and less than or equal to 16.2.
(C) A 1.5 percentage point effective
discount factor for CABG model
participants in the excellent quality
category, defined as a CABG model
composite quality score that are greater
than 16.2.
(iii) Applicable discount factor for
repayment amount in performance year
2 for CABG model participants who
elect early downside risk, and years 3
and 4 for all EPM participants.
(A) A 2.0 percentage point applicable
discount factor for CABG model
participants in the unacceptable or
acceptable quality category, defined as a
CABG model composite quality score of
less than or equal to 3.4.
(B) A 1.0 percentage point applicable
discount factor for CABG model
participants in the good quality
category, defined as a CABG model
composite quality score that is greater
than 3.4 and less than or equal to 16.2.
(C) A 0.5 percentage point applicable
discount factor for CABG model
participants in the excellent quality
category, defined as a CABG model
composite quality scores that is greater
than 16.2.
(iv) Effective discount factor for
repayment amount in performance year
5 for all CABG model participants.
(A) A 3.0 percentage point applicable
discount factor for CABG model
participants in the unacceptable or
acceptable quality category, defined as a
CABG model composite quality score of
less than or equal to 3.4.
(B) A 2.0 percentage point applicable
discount factor for CABG model
participants in the good quality
category, defined as a CABG model
composite quality score that is greater
than 3.4 and less than or or equal to
16.2.
(C) A 1.5 percentage point applicable
discount factor for CABG model
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participants in the excellent quality
category, defined as a CABG model
composite quality scores that is greater
than 16.2.
(d) SHFFT model—(1) SHFFT model
composite quality score. CMS calculates
a SHFFT model composite quality score
for each SHFFT model participant for
each performance year, which equals
the sum of the following:
(i) The SHFFT model participant’s
quality performance points for the
Hospital-Level Risk-Standardized
Complication Rate following Elective
Primary Total Hip Arthroplasty and/or
Total Knee Arthroplasty (NQF #1550)
measure described in § 512.413(a)(1).
This measure is weighted at 50 percent
of the SHFFT model composite quality
score.
(ii) The SHFFT model participant’s
quality performance points for the
Hospital Consumer Assessment of
Healthcare Providers and Systems
Survey (NQF #0166) measure described
in § 512.413(a)(2). This measure is
weighted at 40 percent of the SHFFT
model composite quality score.
(iii) Any additional quality
improvement points the SHFFT model
participant may earn as a result of
demonstrating improvement on either or
both of the quality measures in
paragraphs (d)(1)(i) and (ii) of this
section, as described in paragraph (d)(3)
of this section.
(iv) If applicable, 2 additional points
for successful THA/TKA voluntary data
submission of patient-reported
outcomes and limited risk variable data,
as described in § 512.413(b)(2).
Successful submission is weighted at 10
percent of the SHFFT model composite
quality score.
(2) SHFFT model quality performance
points. CMS computes quality
performance points for each quality
measure based on the SHFFT model
participant’s performance percentile on
that measure relative to the national
distribution of all subsection (d)
hospitals that are eligible for payment
under the IPPS and meet the minimum
measure patient case or survey count.
(i) For the Hospital-Level RiskStandardized Complication Rate
Following Elective Primary Total Hip
Arthroplasty and/or Total Knee
Arthroplasty (NQF #1550) measure
described in § 512.413(a)(1), CMS
assigns the SHFFT model participant
measure value to a performance
percentile and then quality performance
points are assigned based on the
following performance percentile scale:
(A) 10.00 points for ≥ 90th.
(B) 9.25 points for ≥ 80th and < 90th.
(C) 8.50 points for ≥ 70th and < 80th.
(D) 7.75 points for ≥ 60th and < 70th.
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(E) 7.00 points for ≥ 50th and < 60th.
(F) 6.25 points for ≥ 40th and < 50th.
(G) 5.50 points for ≥ 30th and < 40th.
(H) 0.00 points for < 30th.
(ii) For the Hospital Consumer
Assessment of Healthcare Providers and
Systems Survey (NQF #0166) measure
described in § 512.413(a)(2), CMS
assigns the SHFFT model participant
measure value to a performance
percentile and then quality performance
points are assigned based on the
following performance percentile scale:
(A) 8.00 points for ≥ 90th.
(B) 7.40 points for ≥ 80th and < 90th.
(C) 6.80 points for ≥ 70th and < 80th.
(D) 6.20 points for ≥ 60th and < 70th.
(E) 5.60 points for ≥ 50th and < 60th.
(F) 5.00 points for ≥ 40th and < 50th.
(G) 4.40 points for ≥ 30th and < 40th.
(H) 0.00 points for < 30th.
(3) SHFFT quality improvement
points. If a SHFFT model participant’s
quality performance percentile on an
individual measure described in
§ 512.413(a) increases from the previous
performance year by at least 2 deciles on
the performance percentile scale, then
the SHFFT model participant is eligible
to receive quality improvement points
up to 10 percent of the total available
points for that individual measure. The
total SHFFT model composite quality
score is capped at 20 points.
(4) Exception for SHFFT model
participants without a measure value. In
the case of a SHFFT model participant
without a measure value that would
allow CMS to assign quality
performance points for that quality
measure, CMS assigns the 50th
percentile quality performance points to
the participant for the individual
measure.
(i) A SHFFT model participant does
not have a measure value for the—
(A) Hospital-Level Risk-Standardized
Complication Fate Following Elective
Primary Total Hip Arthroplasty and/or
Total Knee Arthroplasty (NQF #1550)
measure described in § 510.413(a)(1) if
the participant does not meet the
minimum 25 case count; or
(B) Hospital Consumer Assessment of
Healthcare Providers and Systems
Survey measure (NQF #0166) described
in § 510.413(a)(2) if the participant does
not meet the minimum of 100
completed surveys and does not have 4
consecutive quarters of HCAHPS data.
(C) Measures described in paragraphs
(d)(4)(i)(A) and (d)(4)(i)(B) of this
section, if CMS identifies an error in the
data used to calculate the measure and
suppresses the measure value.
(5) Establishing SHFFT model
reconciliation payment eligibility and
effective and applicable discount
factors. CMS determines reconciliation
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payment eligibility and the effective
discount factor for reconciliation
payments in all performance years and
repayment amounts in performance year
5, as well as applicable discount factor
for repayment amounts in performance
year 2 for SHFFT model participants
who elect early downside risk and for
performance years 3 and 4 for all SHFFT
model participants, based on the SHFFT
model composite quality score
described in paragraph (d)(1) of this
section.
(i) Reconciliation payment eligibility
requires an acceptable or better quality
category, defined as a SHFFT model
composite quality score of greater than
or equal to 5.0.
(ii) Effective discount factor for
reconciliation payments.
(A) A 3.0 percentage point effective
discount factor for SHFFT model
participants in the unacceptable or
acceptable quality category, defined as a
SHFFT model composite quality score
that is less than 6.9.
(B) A 2.0 percentage point effective
discount factor for SHFFT model
participants in the good quality
category, defined as a SHFFT model
composite quality score that is greater
than or equal to 6.9 and less than or
equal to 15.0.
(C) A 1.5 percentage point effective
discount factor for SHFFT model
participants in the excellent quality
category, defined as a SHFFT model
composite quality score that are greater
than 15.0.
(iii) Applicable discount factor for
repayment amount in performance year
2 for SHFFT model participants who
elect early downside risk, and years 3
and 4 for all EPM participants.
(A) A 2.0 percentage point applicable
discount factor for SHFFT model
participants in the unacceptable or
acceptable quality category, defined as a
SHFFT model composite quality score
of less than 6.9.
(B) A 1.0 percentage point applicable
discount factor for SHFFT model
participants in the good quality
category, defined as a SHFFT model
composite quality score that is greater
than or equal to 6.9 and less than or
equal to 15.0.
(C) A 0.5 percentage point applicable
discount factor for SHFFT model
participants in the excellent quality
category, defined as a SHFFT model
composite quality scores that is greater
than 15.0.
(iv) Effective discount factor for
repayment amount in performance year
5 for all SHFFT model participants.
(A) A 3.0 percentage point applicable
discount factor for SHFFT model
participants in the unacceptable or
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acceptable quality category, defined as a
SHFFT model composite quality score
of less than 6.9.
(B) A 2.0 percentage point applicable
discount factor for SHFFT model
participants in the good quality
category, defined as a SHFFT model
composite quality score that is greater
than or equal to 6.9 and less than or
equal to 15.0.
(C) A 1.5 percentage point applicable
discount factor for SHFFT model
participants in the excellent quality
category, defined as a SHFFT model
composite quality score that is greater
than 15.0.
§ 512.320 Treatment of incentive programs
or add-on payments under existing
Medicare payment systems.
No EPM replaces any existing
Medicare incentive programs or add-on
payments. The quality-adjusted target
prices and NPRAs for an EPM
participant under such models are
independent of, and do not affect, any
incentive programs or add-on payments
under existing Medicare payment
systems.
§ 512.350
Data sharing.
(a) General. CMS makes available to
EPM participants, through the most
appropriate means, data that CMS
determines may be useful to EPM
participants to do the following:
(1) Determine appropriate ways to
increase the coordination of care.
(2) Improve quality.
(3) Enhance efficiencies in the
delivery of care.
(4) Otherwise achieve the goals of the
models described in this section.
(b) Beneficiary-identifiable data. (1)
CMS makes beneficiary-identifiable data
available to an EPM participant in
accordance with applicable privacy and
security laws and only in response to
the EPM participant’s request for such
data for a beneficiary who has been
furnished a billable service by the EPM
participant corresponding to the episode
definitions for the EPM.
(2) The minimum data necessary to
achieve the goals of the EPM, as
determined by CMS, may be provided
under this section for an EPM
participant’s baseline period and no less
frequently than on a quarterly basis
throughout the EPM participant’s
participation in an EPM.
Subpart E—Quality Measures,
Beneficiary Protections, and
Compliance Enforcement
§ 512.400 Quality measures and
reporting—general.
(a) Reporting of quality measures.
Quality measures are used for public
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reporting, for determining whether an
EPM participant is eligible for
reconciliation payments under
§ 512.305(d)(1)(iii), and for assigning the
effective and applicable discount factors
for the performance year to an EPM
participant as described in
§ 512.315(b)(5), (c)(5), and (d)(5).
(b) Quality measures. Quality
measures differ by EPM.
(c) Public reporting. CMS—
(1) Makes the required quality
measurement results for each EPM
participant in each performance year
publicly available on the CMS Web site
in a form and manner as determined by
CMS;
(2) Shares each EPM participant’s
quality metrics with the participant
prior to display on the CMS Web site;
and
(3) Does not publicly report the
voluntary measure data submitted under
an EPM in § 512.411(b) or § 512.413(b)
but does indicate whether an EPM
participant has voluntarily submitted
such data.
§ 512.411 Quality measures and reporting
for AMI model.
(a) Required measures. (1) Hospital
30-Day, All-Cause, Risk-Standardized
Mortality Rate (RSMR) Following Acute
Myocardial Infarction (NQF #0230)
(MORT–30–AMI).
(2) Excess Days in Acute Care after
Hospitalization for AMI (AMI Excess
Days).
(3) HCAHPS Survey (NQF #0166).
(b) Voluntary measure. (1) Voluntary
Hybrid Hospital 30-Day, All-Cause,
Risk-Standardized Mortality Rate
Following Acute Myocardial Infarction
(AMI) Hospitalization (NQF #2473)
(Hybrid AMI Mortality).
(2) To be eligible to receive the
additional points added to the AMI
composite quality score for successful
voluntary data submission of clinical
electronic health record data, as
described in § 512.411(b)(1), AMI model
participants must submit the clinical
electronic health record data requested
by CMS related to each eligible AMI
anchor hospitalization during the
performance period. The data must be
submitted within 60 days of the end of
the most recent performance period and
be accompanied by the limited risk
variable data (five elements finalized) as
outlined in § 512.315(b)(1)(iv).
(i) For each eligible AMI anchor
hospitalization, all five risk variable
data elements are required to be
submitted. The five risk variables are as
follows:
(A) Age.
(B) First-captured heart rate measured
within 2 hours of a patient presenting to
the hospital.
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(C) First-captured systolic blood
pressure measured within 2 hours of a
patient presenting to the hospital.
(D) First-captured troponin values
measured within 24 hours of a patient
presenting to the hospitals.
(E) First-captured creatinine values
measured within 24 hours of a patient
presenting to the hospitals.
(ii) For each eligible AMI anchor
hospitalization, six linking variables are
required to merge the electronic health
record data with the CMS claims data:
(A) AMI model participant CCN.
(B) Medicare Health Insurance Claim
Number.
(C) Sex.
(D) Date of birth.
(E) Admission date.
(F) Discharge date.
(iii) For years 1 through 5 of the AMI
model an increasing amount of data are
requested by CMS for each performance
period as follows:
(A) Year 1. Submit electronic health
record data on > 50 percent of eligible
AMI anchor hospitalizations between
July 1, 2017 and August 31, 2017.
(B) Year 2. Submit electronic health
record data on over 90 percent of
eligible AMI anchor hospitalizations
between September 1, 2017 and June 30,
2018.
(C) Year 3. Submit electronic health
record data on over 90 percent of
eligible AMI anchor hospitalizations
between July 1, 2018 and June 30, 2019.
(D) Year 4. Submit electronic health
record data on over 90 percent of
eligible AMI anchor hospitalizations
between July 1, 2019 and June 30, 2020.
(E) Year 5. Submit electronic health
record data on over 90 percent of
eligible AMI anchor hospitalizations
between July 1, 2020 and June 30, 2021.
§ 512.412 Quality measures and reporting
for CABG model.
(a) Required measures. (1) Hospital
30-Day, All-Cause, Risk-Standardized
Mortality Rate (RSMR) Following
Coronary Artery Bypass Graft (CABG)
Surgery (NQF #2558) (MORT–30–
CABG).
(2) HCAHPS Survey (NQF #0166).
(b) [Reserved]
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§ 512.413 Quality measures and reporting
for SHFFT model.
(a) Required measures. (1) HospitalLevel Risk-Standardized Complication
Rate Following Elective Primary Total
Hip Arthroplasty and/or Total Knee
Arthroplasty (NQF #1550) (Hip/Knee
Complications).
(2) HCAHPS Survey (NQF #0166).
(b) Voluntary measure. (1) Patientreported outcomes and limited risk
variable data following elective primary
THA/TKA.
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(2) To be eligible to receive the
additional points added to the SHFFT
model composite quality score for
successful voluntary data submission of
patient-reported outcomes and limited
risk variable data, as described in
§ 512.315(d)(1)(iv), SHFFT model
participants must submit the THA/TKA
patient-reported outcome and limited
risk variable data requested by CMS
related to the pre- and post-operative
periods for elective primary total hip
and/or total knee arthroplasty
procedures. The data must be submitted
within 60 days of the end of the most
recent performance period and be
accompanied by the patient-reported
outcomes and limited risk variable data
(eleven elements finalized) as outlined
in § 512.315(d)(1)(iv).
(i) For each eligible procedure all
eleven risk variable data elements are
required to be submitted. The eleven
risk variables are as follows:
(A) Date of birth.
(B) Race.
(C) Ethnicity.
(D) Date of admission to anchor
hospitalization.
(E) Date of eligible THA/TKA
procedure.
(F) Medicare Health Insurance Claim
Number.
(G) Body mass index.
(H) Use of chronic (≥ 90 days)
narcotics.
(I) Total painful joint count.
(J) Quantified spinal pain.
(K) Single Item Health Literacy
Screening (SILS2) questionnaire.
(ii) Participants must also submit the
amount of requested THA/TKA patientreported outcomes data required for
each year of the SHFFT model in order
to be considered successful in
submitting voluntary data.
(A) The amount of requested THA/
TKA patient-reported outcomes data to
submit, in order to be considered
successful increases each subsequent
year of the SHFFT model over the 5
years of the model.
(B) A phase-in approach that
determines the amount of requested
THA/TKA patient-reported outcomes
data to submit over the 5 years of the
SHFFT model is applied so that in year
1 successful submission of data would
mean CMS received all requested THA/
TKA patient-reported outcomes and
limited risk variable data on both of the
following:
(1) Greater than or equal to 60 percent
of eligible procedures or greater than or
equal to 75 percent eligible patients
during the data collection period.
(2) Submission of requested THA/
TKA PRO and limited risk variable data
is completed within 60 days of the most
recent performance period.
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639
(iii) For years 1 through 5 of the
model an increasing amount of data is
requested by CMS for each performance
period as follows:
(A) Year 1 (2017). Submit preoperative data on primary elective THA/
TKA procedures for ≥ 60 percent or ≥ 75
procedures performed between
September 1, 2016 through June 30,
2017, unless CMS requests a more
limited data set, in which case, submit
all requested data elements.
(B) Year 2 (2018). Submit—
(1) Post-operative data on primary
elective THA/TKA procedures for ≥ 60
percent or ≥ 75 procedures performed
between September 1, 2016 and June 30,
2017; and
(2) Pre-operative data on primary
elective THA/TKA procedures for ≥ 70
percent or ≥ 100 procedures performed
between July 1, 2017 and June 30, 2018,
unless CMS requests a more limited
data set, in which case, submit all
requested data elements.
(C) Year 3 (2019). Submit—
(1) Post-operative data on primary
elective THA/TKA procedures for ≥ 70
percent or ≥ 100 procedures performed
between July 1, 2017 and June 30, 2018;
and
(2) Pre-operative data on primary
elective THA/TKA procedures for ≥ 80
percent or ≥ 200 procedures performed
between July 1, 2018 and June 30, 2019,
unless CMS requests a more limited
data set, in which case, submit all
requested data elements.
(D) Year 4 (2020). Submit—
(1) Post-operative data on primary
elective THA/TKA procedures for ≥ 80
percent or ≥ 200 procedures performed
between July 1, 2018 and June 30, 2019;
and
(2) Pre-operative data on primary
elective THA/TKA procedures for ≥ 80
percent or ≥ 200 procedures performed
between July 1, 2019 and June 30, 2020,
unless CMS requests a more limited
data set, in which case, submit all
requested data elements.
(E) Year 5 (2021). Submit—
(1) Post-operative data on primary
elective THA/TKA procedures for ≥ 80
percent or ≥ 200 procedures performed
between July 1, 2019 and June 30, 2020;
and
(2) Pre-operative data on primary
elective THA/TKA procedures for ≥ 80
percent or ≥ 200 procedures performed
between July 1, 2020 and June 30, 2021,
unless CMS requests a more limited
data set, in which case, submit all
requested data elements.
§ 512.450 Beneficiary choice and
beneficiary notification.
(a) Beneficiary choice. The EPMs do
not restrict Medicare beneficiaries’
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ability to choose any Medicare enrolled
provider or supplier, or any physician
or practitioner who has opted out of
Medicare.
(1) As part of discharge planning and
referral, EPM participants must provide
a complete list of HHAs, SNFs, IRFs, or
LTCHs that are participating in the
Medicare program, and that serve the
geographic area (as defined by the HHA)
in which the patient resides, or in the
case of a SNF, IRF, or LTCH, in the
geographic area requested by the
patient.
(i) This list must be presented to EPM
beneficiaries for whom home health
care, SNF, IRF, or LTCH services are
medically necessary.
(ii) EPM participants must specify on
the list those post-acute care providers
on the list with whom they have a
sharing arrangement.
(iii) EPM participants may
recommend preferred providers and
suppliers, consistent with applicable
statutes and regulations.
(iv) EPM participants may not limit
beneficiary choice to any list of
providers or suppliers in any manner
other than that permitted under
applicable statutes and regulations.
(v) EPM participants must take into
account patient and family preferences
when they are expressed.
(2) EPM participants may not charge
any EPM collaborator a fee to be
included on any list of preferred
providers or suppliers, nor may the EPM
participant accept such payments.
(b) Required beneficiary notification—
(1) EPM participant detailed
notification. Each EPM participant must
provide written notification to any
Medicare beneficiary that meets the
criteria in § 512.240 of his or her
inclusion in the EPM. The notification
must be provided upon admission to the
EPM participant if the admission that
initiates the EPM episode is not
scheduled with the EPM participant in
advance. If the admission is scheduled
in advance, then the EPM participant
must provide notice as soon as the
admission is scheduled. In
circumstances where, due to the
patient’s condition, it is not feasible to
provide notification at such times, the
notification must be provided to the
beneficiary or his or her representative
as soon as is reasonably practicable but
no later than discharge from the EPM
participant accountable for the EPM
episode. The EPM participant must be
able to generate a list of all beneficiaries
receiving such notification, including
the date on which the notification was
provided to the beneficiary, to CMS
upon request. The beneficiary
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notification must contain all of the
following:
(i) A detailed explanation of the EPM
and how it might be expected to affect
the beneficiary’s care.
(ii) Notification that the beneficiary
retains freedom of choice to choose
providers and services.
(iii) Explanation of how patients can
access care records and claims data
through an available patient portal, and
how they can share access to their Blue
Button® electronic health information
with caregivers.
(iv) A statement that all existing
Medicare beneficiary protections
continue to be available to the
beneficiary. These include the ability to
report concerns of substandard care to
Quality Improvement Organizations or
the 1–800–MEDICARE helpline.
(v) A list of the providers, suppliers,
and ACOs with whom the EPM
participant has a sharing arrangement.
This requirement may be fulfilled by the
EPM participant including in the
detailed notification a web address
where beneficiaries may access the list.
(2) EPM collaborator notice. An EPM
participant must require every EPM
collaborator to provide written notice to
applicable EPM beneficiaries of the
structure of the EPM and the existence
of its sharing arrangement with the EPM
participant.
(i) An EPM participant must require
every EPM collaborator that furnishes
an item or service to an EPM beneficiary
during an EPM episode to provide
written notice to the beneficiary of the
structure of the EPM and the existence
of the individual’s or entity’s sharing
arrangement. The notice must be
provided no later than the time at which
the beneficiary first receives an item or
service from the EPM collaborator
during an EPM episode. In
circumstances where, due to the
patient’s condition, it is not feasible to
provide notice at such times, the notice
must be provided to the beneficiary or
his or her representative as soon as is
reasonably practicable. The EPM
collaborator must be able to generate a
list of all beneficiaries who received
such a notice, including the date on
which the notice was provided to the
beneficiary, to CMS upon request.
(ii) An EPM participant must require
every EPM collaborator that is a PGP,
NPPGP, or TGP where a member of the
PGP, member of the NPPGP, or member
of the TGP furnishes an item or service
to an EPM beneficiary during an EPM
episode to provide written notice to the
beneficiary of the structure of the EPM
and the existence of the entity’s sharing
arrangement. The notice must be
provided no later than the time at which
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the beneficiary first receives an item or
service from any member of the PGP,
member of the NPPGP, or member of the
TGP, and the required notice may be
provided by that member. In
circumstances where, due to the
patient’s condition, it is not feasible to
provide notice at such times, the notice
must be provided to the beneficiary or
his or her representative as soon as is
reasonably practicable. The PGP,
NPPGP, or TGP must be able to generate
a list of all beneficiaries who received
such a notice, including the date on
which the notice was provided to the
beneficiary, to CMS upon request.
(iii) An EPM participant must require
every EPM collaborator that is an ACO
where an ACO participant bills for or
ACO provider/supplier furnishes an
item or service to an EPM beneficiary
during an EPM episode to provide
written notice to the beneficiary of the
structure of the EPM and the existence
of the entity’s sharing arrangement. The
notice must be provided no later than
the time at which the beneficiary first
receives an item or service from any
ACO participant or ACO provider/
supplier and the required notice may be
provided by that ACO participant or
ACO provider/supplier. In
circumstances where, due to the
patient’s condition, it is not feasible to
provide notice at such times, the notice
must be provided to the beneficiary or
his or her representative as soon as is
reasonably practicable. The ACO must
be able to generate a list of all
beneficiaries who received such a
notice, including the date on which the
notice was provided to the beneficiary,
to CMS or its designee upon request.
(3) Discharge planning notice. An
EPM participant must provide the
beneficiary with a written notice of any
potential financial liability associated
with non-covered services
recommended or presented as an option
as part of discharge planning, no later
than at the time that the beneficiary
discusses a particular post-acute care
option or at the time the beneficiary is
discharged, whichever occurs earlier.
(i) If the EPM participant knows or
should have known that the beneficiary
is considering or has decided to receive
a non-covered post-acute care service or
other non-covered associated service or
supply, the EPM participant must notify
the beneficiary that the service would
not be covered by Medicare.
(ii) If the EPM participant is
discharging a beneficiary to a SNF prior
to the occurrence of a 3-day hospital
stay, and the beneficiary is being
transferred to or is considering a SNF
that would not qualify under the SNF 3day waiver in § 512.610, the EPM
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participant must notify the beneficiary
in accordance with paragraph (b)(3)(i) of
this section that the beneficiary will be
responsible for payment for the services
furnished by the SNF during that stay,
except those services that would be
covered by Medicare Part B during a
non-covered inpatient SNF stay.
(4) Access to records and retention.
Lists of beneficiaries that receive
notifications or notices must be retained
and access provided to CMS, or its
designees, in accordance with § 512.110.
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§ 512.460
Compliance enforcement.
(a) General. EPM participants must
comply with all of the requirements
outlined in this part. Except as
specifically noted in this part, the
regulations under this part must not be
construed to affect the applicable
payment, coverage, program integrity, or
other requirements under this chapter
(such as those in parts 412 and 482 of
this chapter).
(b) Failure to comply. (1) CMS may
take one or more of the remedial actions
set forth in paragraph (b)(2) of this
section if an EPM participant or its
related EPM collaborator, collaboration
agent, or downstream collaboration
agent does any of the following:
(i) Fails to comply with any
requirements of this part or is identified
as noncompliant through monitoring by
HHS (including CMS and OIG) of the
EPM, including, but not limited to, any
of the following:
(A) Avoiding potentially high-cost or
high-severity patients.
(B) Targeting potentially low-cost or
low-severity patients.
(C) Failing to provide medically
appropriate services or systematically
engaging in the over- or under-delivery
of appropriate care.
(D) Failing to provide beneficiaries
with complete and accurate
information, including required notices.
(E) Failing to allow beneficiary choice
of medically necessary options,
including non-surgical options.
(F) Failing to follow the requirements
related to sharing arrangements.
(ii) Has signed a sharing arrangement,
distribution arrangement, or
downstream distribution arrangement
that is noncompliant with the
requirements of this part.
(iii) Takes any action that threatens
the health or safety of patients.
(iv) Avoids at-risk Medicare
beneficiaries, as this term is defined in
§ 425.20 of this chapter.
(v) Avoids patients on the basis of
payer status.
(vi) Is subject to sanctions or final
actions of an accrediting organization or
Federal, state, or local government
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agency that could lead to the inability
to comply with the requirements and
provisions of this part.
(vii) Takes any action that CMS
determines for program integrity reasons
is not in the best interests of the EPM,
or fails to take any action that CMS
determines for program integrity reasons
should have been taken to further the
best interests of the EPM.
(viii) Is subject to action by HHS
(including OIG and CMS) or the
Department of Justice to redress an
allegation of fraud or significant
misconduct, including intervening in a
False Claims Act qui tam matter, issuing
a pre-demand or demand letter under a
civil sanction authority, or similar
actions.
(ix) Is subject to action involving
violations of the physician self-referral
law, civil monetary penalties law,
Federal anti-kickback statute, antitrust
laws, or any other applicable Medicare
laws, rules, or regulations that are
relevant to the EPM.
(2) Remedial actions include the
following:
(i) Issuing a warning letter to the EPM
participant.
(ii) Requiring the EPM participant to
develop a corrective action plan,
commonly referred to as a CAP.
(iii) Reducing or eliminating the EPM
participant’s reconciliation payment.
(iv) Reducing or eliminating the EPM
participant’s CR incentive payment.
(v) Requiring the EPM participant to
terminate a sharing arrangement with an
EPM collaborator and prohibit further
engagement by the EPM participant in
sharing arrangements with the EPM
collaborator.
(vi) Terminating the EPM
participant’s participation in the EPM.
Where a participant is terminated from
an EPM, the EPM participant will
remain liable for all negative NPRA
generated from EPM episodes that
ended prior to termination.
(3) CMS may add a 25-percent penalty
to a repayment amount on the EPM
participant’s reconciliation report if all
of the following conditions are met:
(i) CMS has required a corrective
action plan from the EPM participant.
(ii) The EPM participant owes a
repayment amount to CMS.
(iii) The EPM participant fails to
timely comply with the corrective
action plan or is noncompliant with the
EPM’s requirements.
Subpart F—Financial Arrangements
and Beneficiary Incentives
§ 512.500
EPM.
Sharing arrangements under the
(a) General. (1) An EPM participant
may enter into a sharing arrangement
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641
with an EPM collaborator to make a
gainsharing payment, or to receive an
alignment payment, or both. An EPM
participant must not make a gainsharing
payment or receive an alignment
payment except in accordance with a
sharing arrangement.
(2) A sharing arrangement must
comply with the provisions of this
section and all other applicable laws
and regulations, including the
applicable fraud and abuse laws and all
applicable payment and coverage
requirements.
(3) The EPM participant must
develop, maintain, and use a set of
written policies for selecting individuals
and entities to be EPM collaborators.
These policies must contain criteria
related to, and inclusive of, the quality
of care delivered by the potential EPM
collaborator. The selection criteria
cannot be based directly or indirectly on
the volume or value of past or
anticipated referrals or business
otherwise generated by, between or
among the EPM participant, any EPM
collaborator, any collaboration agent,
any downstream collaboration agent, or
any individual or entity affiliated with
an EPM participant, EPM collaborator,
collaboration agent, or downstream
collaboration agent. A selection
criterion that considers whether a
potential EPM collaborator has
performed a reasonable minimum
number of services that would qualify as
EPM activities will be deemed not to
violate the volume or value standard if
the purpose of the criterion is to ensure
the quality of care furnished to EPM
beneficiaries.
(4) If an EPM participant enters into
a sharing arrangement, its compliance
program must include oversight of
sharing arrangements and compliance
with the applicable requirements of the
EPM.
(b) Requirements. (1) A sharing
arrangement must be in writing and
signed by the parties, and entered into
before care is furnished to EPM
beneficiaries under the sharing
arrangement.
(2) Participation in a sharing
arrangement must be voluntary and
without penalty for nonparticipation.
(3) The sharing arrangement must
require the EPM collaborator and its
employees, contractors (including
collaboration agents), and
subcontractors (including downstream
collaboration agents) to comply with all
of the following:
(i) The applicable provisions of this
part (including requirements regarding
beneficiary notifications, access to
records, record retention, and
participation in any evaluation,
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monitoring, compliance, and
enforcement activities performed by
CMS or its designees).
(ii) All applicable Medicare provider
enrollment requirements at § 424.500 of
this chapter, including having a valid
and active TIN or NPI, during the term
of the sharing arrangement.
(iii) All other applicable laws and
regulations.
(4) The sharing arrangement must
require the EPM collaborator to have or
be covered by a compliance program
that includes oversight of the sharing
arrangement and compliance with the
requirements of the EPM that apply to
its role as an EPM collaborator,
including any distribution
arrangements.
(5) The sharing arrangement must not
pose a risk to beneficiary access,
beneficiary freedom of choice, or quality
of care.
(6) The board or other governing body
of the EPM participant must have
responsibility for overseeing the EPM
participant’s participation in the EPM,
its arrangements with EPM
collaborators, its payment of gainsharing
payments, its receipt of alignment
payments, and its use of beneficiary
incentives in the EPM.
(7) The written agreement
memorializing a sharing arrangement
must specify the following:
(i) The purpose and scope of the
sharing arrangement;
(ii) The identities and obligations of
the parties, including specified EPM
activities and other services to be
performed by the parties under the
sharing arrangement;
(iii) The date of the sharing
arrangement.
(iv) The financial or economic terms
for payment, including the following:
(A) Eligibility criteria for a
gainsharing payment.
(B) Eligibility criteria for an alignment
payment.
(C) Frequency of gainsharing or
alignment payment.
(D) Methodology and accounting
formula for determining the amount of
a gainsharing payment that is
substantially based on quality of care
and the provision of EPM activities.
(E) Methodology and accounting
formula for determining the amount of
an alignment payment.
(8) The sharing arrangement must
not—
(i) Induce the EPM participant, EPM
collaborator, or any employees,
contractors, or subcontractors of the
EPM participant or EPM collaborator to
reduce or limit medically necessary
services to any Medicare beneficiary; or
(ii) Restrict the ability of an EPM
collaborator to make decisions in the
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best interests of its patients, including
the selection of devices, supplies, and
treatments.
(c) Gainsharing payment, alignment
payment, and internal cost savings
conditions and restrictions. (1)
Gainsharing payments, if any, must—
(i) Be derived solely from
reconciliation payments, or internal cost
savings, or both;
(ii) Be distributed on an annual basis
(not more than once per calendar year);
(iii) Not be a loan, advance payment,
or payment for referrals or other
business; and
(iv) Be clearly identified as a
gainsharing payment at the time it is
paid.
(2)(i) To be eligible to receive a
gainsharing payment, an EPM
collaborator must meet quality of care
criteria for the performance year for
which the EPM participant accrued the
internal cost savings or earned the
reconciliation payment that comprises
the gainsharing payment. The quality of
care criteria must be established by the
EPM participant and directly related to
EPM episodes.
(ii) To be eligible to receive a
gainsharing payment, or to be required
to make an alignment payment, an EPM
collaborator other than an ACO, PGP,
NPPGP, or TGP must have directly
furnished a billable item or service to an
EPM beneficiary during an EPM episode
that occurred in the same performance
year for which the EPM participant
accrued the internal cost savings or
earned the reconciliation payment that
comprises the gainsharing payment or
was assessed a repayment amount.
(iii) To be eligible to receive a
gainsharing payment, or to be required
to make an alignment payment, an EPM
collaborator that is a PGP, NPPGP, or
TGP must meet the following criteria:
(A) The PGP, NPPGP, or TGP must
have billed for an item or service that
was rendered by one or more PGP
member, NPPGP member, or TGP
member respectively to an EPM
beneficiary during an EPM episode that
occurred during the same performance
year for which the EPM participant
accrued the internal cost savings or
earned the reconciliation payment that
comprises the gainsharing payment or
was assessed a repayment amount.
(B) The PGP, NPPGP, or TGP must
have contributed to EPM activities and
been clinically involved in the care of
EPM beneficiaries during the same
performance year for which the EPM
participant accrued the internal cost
savings or earned the reconciliation
payment that comprises the gainsharing
payment or was assessed a repayment
amount. For example, a PGP, NPPGP, or
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TGP might have been clinically
involved in the care of EPM
beneficiaries by—
(1) Providing care coordination
services to EPM beneficiaries during
and/or after inpatient admission;
(2) Engaging with an EPM participant
in care redesign strategies, and actually
performing a role in implementing such
strategies, that are designed to improve
the quality of care for EPM episodes and
reduce EPM episode spending; or
(3) In coordination with other
providers and suppliers (such as PGP
members, NPPGP members, or TGP
members; the EPM participant; and
post-acute care providers),
implementing strategies designed to
address and manage the comorbidities
of EPM beneficiaries.
(iv) To be eligible to receive a
gainsharing payment, or to be required
to make an alignment payment, an EPM
collaborator that is an ACO must meet
the following criteria:
(A) The ACO must have had an ACO
provider/supplier that directly
furnished, or an ACO participant that
billed for, an item or service that was
rendered to an EPM beneficiary during
an EPM episode that occurred during
the same performance year for which
the EPM participant accrued the
internal cost savings or earned the
reconciliation payment that comprises
the gainsharing payment or was
assessed a repayment amount; and
(B) The ACO must have contributed to
EPM activities and been clinically
involved in the care of EPM
beneficiaries during the same
performance year for which the EPM
participant accrued the internal cost
savings or earned the reconciliation
payment that comprises the gainsharing
payment or was assessed a repayment
amount. For example, an ACO might be
have been clinically involved in the care
of EPM beneficiaries by—
(1) Providing care coordination
services to EPM beneficiaries during
and/or after inpatient admission;
(2) Engaging with an EPM participant
in care redesign strategies, and actually
performing a role in implementing such
strategies, that are designed to improve
the quality of care and reduce spending
for EPM episodes; or
(3) In coordination with providers and
suppliers (such as ACO participants,
ACO providers/suppliers, the EPM
participant, and post-acute care
providers), implementing strategies
designed to address and manage the
comorbidities of EPM beneficiaries.
(3)(i) The methodology for accruing,
calculating and verifying internal cost
savings must be transparent,
measurable, and verifiable in
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accordance with generally accepted
accounting principles (GAAP) and
Government Auditing Standards (The
Yellow Book).
(ii) The methodology used to calculate
internal cost savings must reflect the
actual, internal cost savings achieved by
the EPM participant through the
documented implementation of EPM
activities identified by the EPM
participant and must exclude:
(A) Any savings realized by any
individual or entity that is not the EPM
participant; and
(B) ‘‘Paper’’ savings from accounting
conventions or past investment in fixed
costs.
(4) The total amount of a gainsharing
payment for a performance year paid to
certain individuals and entities that are
EPM collaborators must not exceed the
following:
(i) In the case of an EPM collaborator
who is a physician or nonphysician
practitioner, 50 percent of the Medicareapproved amounts under the PFS for
items and services furnished by that
physician or nonphysician practitioner
to the EPM participant’s EPM
beneficiaries during EPM episodes that
occurred during the same performance
year for which the EPM participant
accrued the internal cost savings or
earned the reconciliation payment that
comprises the gainsharing payment
being made.
(ii) In the case of an EPM collaborator
that is a PGP or NPPGP, 50 percent of
the Medicare-approved amounts under
the PFS for items and services billed by
that PGP or NPPGP and furnished to the
EPM participant’s EPM beneficiaries by
the PGP members or NPPGP members
respectively during EPM episodes that
occurred during the same performance
year for which the EPM participant
accrued the internal cost savings or
earned the reconciliation payment that
comprises the gainsharing payment
being made.
(5) The amount of any gainsharing
payments must be determined in
accordance with a methodology that is
substantially based on quality of care
and the provision of EPM activities. The
methodology may take into account the
amount of such EPM activities provided
by an EPM collaborator relative to other
EPM collaborators.
(6) For a performance year, the
aggregate amount of all gainsharing
payments that are derived from a
reconciliation payment the EPM
participant receives from CMS must not
exceed the amount of that reconciliation
payment.
(7) No entity or individual, whether a
party to a sharing arrangement or not,
may condition the opportunity to make
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or receive gainsharing payments or to
make or receive alignment payments
directly or indirectly on the volume or
value of past or anticipated referrals or
business otherwise generated by,
between or among the EPM participant,
any EPM collaborator, any collaboration
agent, any downstream collaboration
agent, or any individual or entity
affiliated with an EPM participant, EPM
collaborator, collaboration agent, or
downstream collaboration agent.
(8) An EPM participant must not
make a gainsharing payment to an EPM
collaborator if CMS has notified the
EPM participant that such collaborator
is subject to any action for
noncompliance with this part or the
fraud and abuse laws, or for the
provision of substandard care to EPM
beneficiaries or other integrity
problems.
(9) The sharing arrangement must
require the EPM participant to recoup
any gainsharing payment that contained
funds derived from a CMS overpayment
on a reconciliation report or was based
on the submission of false or fraudulent
data.
(10) Alignment payments from an
EPM collaborator to an EPM participant
may be made at any interval that is
agreed upon by both parties, and must
not be—
(i) Issued, distributed, or paid prior to
the calculation by CMS of a repayment
amount reflected in a reconciliation
report;
(ii) Loans, advance payments, or
payments for referrals or other business;
or
(iii) Assessed by an EPM participant
if it does not owe a repayment amount.
(11) The EPM participant must not
receive any amounts under a sharing
arrangement from an EPM collaborator
that are not alignment payments.
(12) For a performance year, the
aggregate amount of all alignment
payments received by the EPM
participant must not exceed 50 percent
of the EPM participant’s repayment
amount.
(13) The aggregate amount of all
alignment payments from an EPM
collaborator to the EPM participant may
not be greater than—
(i) With respect to an EPM
collaborator other than an ACO, 25
percent of the EPM participant’s
repayment amount; or
(ii) With respect to an EPM
collaborator that is an ACO, 50 percent
of the EPM participant’s repayment
amount.
(14) The amount of any alignment
payments must be determined in
accordance with a methodology that
does not directly account for the volume
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643
or value of past or anticipated referrals
or business otherwise generated by,
between or among the EPM participant,
any EPM collaborator, any collaboration
agent, any downstream collaboration
agent, or any individual or entity
affiliated with an EPM participant, EPM
collaborator, collaboration agent, or
downstream collaboration agent.
(15) All gainsharing payments and
any alignment payments must be
administered by the EPM participant in
accordance with generally accepted
accounting principles (GAAP) and
Government Auditing Standards (The
Yellow Book).
(16) All gainsharing payments and
alignment payments must be made by
check, electronic funds transfer, or
another traceable cash transaction.
(d) Documentation requirements. (1)
The EPM participant must do all of the
following:
(i) Document the sharing arrangement
contemporaneously with the
establishment of the arrangement.
(ii) Publicly post (and update on at
least a quarterly basis) on a Web page
on the EPM participant’s Web site:
(A) Accurate current and historical
lists of all EPM collaborators, including
EPM collaborator names and addresses.
(B) Written policies for selecting
individuals and entities to be EPM
collaborators required by
§ 512.500(a)(3).
(iii) Maintain and require each EPM
collaborator to maintain
contemporaneous documentation with
respect to the payment or receipt of any
gainsharing payment or alignment
payment that includes at a minimum all
of the following:
(A) Nature of the payment
(gainsharing payment or alignment
payment).
(B) Identity of the parties making and
receiving the payment.
(C) Date of the payment.
(D) Amount of the payment.
(E) Date and amount of any
recoupment of all or a portion of an
EPM collaborator’s gainsharing
payment.
(F) Explanation for each recoupment,
such as whether the EPM collaborator
received a gainsharing payment that
contained funds derived from a CMS
overpayment on a reconciliation report,
or was based on the submission of false
or fraudulent data.
(2) The EPM participant must keep
records of the following:
(i) Its process for determining and
verifying its potential and current EPM
collaborators’ eligibility to participate in
Medicare.
(ii) Its plan to track internal cost
savings.
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(iii) Information on the accounting
systems used to track internal cost
savings.
(iv) A description of current health
information technology, including
systems to track reconciliation
payments and internal cost savings.
(v) Its plan to track gainsharing
payments and alignment payments.
(3) The EPM participant must retain
and provide access to, and must require
each EPM collaborator to retain and
provide access to, the required
documentation in accordance with
§ 512.110.
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§ 512.505
the EPM.
Distribution arrangements under
(a) General. (1) An ACO, PGP, NPPGP,
or TGP that has entered into a sharing
arrangement with an EPM participant
may distribute all or a portion of any
gainsharing payment it receives from
the EPM participant only in accordance
with a distribution arrangement.
(2) All distribution arrangements must
comply with the provisions of this
section and all other applicable laws
and regulations, including the fraud and
abuse laws.
(b) Requirements. (1) All distribution
arrangements must be in writing and
signed by the parties, contain the date
of the agreement, and be entered into
before care is furnished to EPM
beneficiaries under the distribution
arrangement.
(2) Participation in a distribution
arrangement must be voluntary and
without penalty for nonparticipation.
(3) The distribution arrangement must
require the collaboration agent to
comply with all applicable laws and
regulations.
(4) The opportunity to make or
receive a distribution payment must not
be conditioned directly or indirectly on
the volume or value of past or
anticipated referrals or business
otherwise generated by, between or
among the EPM participant, any EPM
collaborator, any collaboration agent,
any downstream collaboration agent, or
any individual or entity affiliated with
an EPM participant, EPM collaborator,
collaboration agent, or downstream
collaboration agent.
(5) The amount of any distribution
payments from an ACO, from an NPPGP
to an NPPGP member, or from a TGP to
a TGP member must be determined in
accordance with a methodology that is
substantially based on quality of care
and the provision EPM activities and
that may take into account the amount
of such EPM activities provided by a
collaboration agent relative to other
collaboration agents.
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(6) The amount of any distribution
payments from a PGP must be
determined either in a manner that
complies with § 411.352(g) of this
chapter or in accordance with a
methodology that is substantially based
on quality of care and the provision
EPM activities and that may take into
account the amount of such EPM
activities provided by a collaboration
agent relative to other collaboration
agents.
(7) Except for a distribution payment
from a PGP to a PGP member that
complies with § 411.352(g) of this
chapter, a collaboration agent is eligible
to receive a distribution payment only if
the collaboration agent furnished or
billed for an item or service rendered to
an EPM beneficiary during an EPM
episode that occurred during the same
performance year for which the EPM
participant accrued the internal cost
savings or earned the reconciliation
payment that comprises the gainsharing
payment being distributed.
(8) Except for a distribution payment
from a PGP to a PGP member that
complies with § 411.352(g) of this
chapter, the total amount of distribution
payments for a performance year paid to
a collaboration agent must not exceed
the following:
(i) In the case of a collaboration agent
that is a physician or nonphysician
practitioner, 50 percent of the total
Medicare-approved amounts under the
PFS for items and services furnished by
the collaboration agent to the EPM
participant’s EPM beneficiaries during
EPM episodes that occurred during the
same performance year for which the
EPM participant accrued the internal
cost savings or earned the reconciliation
payment that comprises the gainsharing
payment being distributed.
(ii) In the case of a collaboration agent
that is a PGP or NPPGP, 50 percent of
the total Medicare-approved amounts
under the PFS for items and services
billed by that PGP or NPPGP for items
and services furnished by PGP members
or NPPGP members respectively to the
EPM participant’s EPM beneficiaries
during EPM episodes that occurred
during the same performance year for
which the EPM participant accrued the
internal cost savings or earned the
reconciliation payment that comprises
the gainsharing payment being
distributed.
(9) With respect to the distribution of
any gainsharing payment received by an
ACO, PGP, NPPGP, or TGP, the total
amount of all distribution payments
must not exceed the amount of the
gainsharing payment received by the
EPM collaborator from the EPM
participant.
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(10) All distribution payments must
be made by check, electronic funds
transfer, or another traceable cash
transaction.
(11) The collaboration agent must
retain the ability to make decisions in
the best interests of the patient,
including the selection of devices,
supplies, and treatments.
(12) The distribution arrangement
must not—
(i) Induce the collaboration agent to
reduce or limit medically necessary
items and services to any Medicare
beneficiary; or
(ii) Reward the provision of items and
services that are medically unnecessary.
(13) The EPM collaborator must
maintain contemporaneous
documentation regarding distribution
arrangements in accordance with
§ 512.110, including the following:
(i) The relevant written agreements.
(ii) The date and amount of any
distribution payment(s).
(iii) The identity of each collaboration
agent that received a distribution
payment.
(iv) A description of the methodology
and accounting formula for determining
the amount of any distribution payment.
(14) The EPM collaborator may not
enter into a distribution arrangement
with any individual or entity that has a
sharing arrangement with the same EPM
participant.
(15) The EPM collaborator must retain
and provide access to, and must require
collaboration agents to retain and
provide access to, the required
documentation in accordance with
§ 512.110.
§ 512.510 Downstream distribution
arrangements under the EPM.
(a) General. (1) An ACO participant
that is a PGP, NPPGP, or TGP and that
has entered into a distribution
arrangement with an EPM collaborator
that is an ACO may distribute all or a
portion of any distribution payment it
receives from the EPM collaborator only
in accordance with a downstream
distribution arrangement.
(2) All downstream distribution
arrangements must comply with the
provisions of this section and all
applicable laws and regulations,
including the fraud and abuse laws.
(b) Requirements. (1) All downstream
distribution arrangements must be in
writing and signed by the parties,
contain the date of the agreement, and
be entered into before care is furnished
to EPM beneficiaries under the
downstream distribution arrangement.
(2) Participation in a downstream
distribution arrangement must be
voluntary and without penalty for
nonparticipation.
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(3) The downstream distribution
arrangement must require the
downstream collaboration agent to
comply with all applicable laws and
regulations.
(4) The opportunity to make or
receive a downstream distribution
payment must not be conditioned
directly or indirectly on the volume or
value of past or anticipated referrals or
business otherwise generated by,
between or among the EPM participant,
any EPM collaborator, any collaboration
agent, any downstream collaboration
agent, or any individual or entity
affiliated with an EPM participant, EPM
collaborator, collaboration agent, or
downstream collaboration agent.
(5) The amount of any downstream
distribution payments from an NPPGP
to an NPPGP member or from a TGP to
a TGP member must be determined in
accordance with a methodology that is
substantially based on quality of care
and the provision EPM activities and
that may take into account the amount
of such EPM activities provided by a
downstream collaboration agent relative
to other downstream collaboration
agents.
(6) The amount of any downstream
distribution payments from a PGP must
be determined either in a manner that
complies with § 411.352(g) of this
chapter or in accordance with a
methodology that is substantially based
on quality of care and the provision
EPM activities and that may take into
account the amount of such EPM
activities provided by a downstream
collaboration agent relative to other
downstream collaboration agents.
(7) Except for a downstream
distribution payment from a PGP to a
PGP member that complies with
§ 411.352(g) of this chapter, a
downstream collaboration agent is
eligible to receive a downstream
distribution payment only if the
downstream collaboration agent
furnished an item or service to an EPM
beneficiary during an EPM episode that
occurred during the same performance
year for which the EPM participant
accrued the internal cost savings or
earned the reconciliation payment that
comprises the gainsharing payment
from which the ACO made the
distribution payment to the PGP,
NPPGP, or TGP that is an ACO
participant.
(8) Except for a downstream
distribution payment from a PGP to a
PGP member that complies with
§ 411.352(g) of this chapter, the total
amount of downstream distribution
payments for a performance year paid to
a downstream collaboration agent who
is a physician or nonphysician
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practitioner and is either a PGP member
or NPPGP member must not exceed 50
percent of the total Medicare-approved
amounts under the PFS for items and
services furnished by the downstream
collaboration agent to the EPM
participant’s EPM beneficiaries during
EPM episodes that occurred during the
same performance year for which the
EPM participant accrued the internal
cost savings or earned the reconciliation
payment that comprises the distribution
payment being distributed.
(9) The total amount of all
downstream distribution payments
made to downstream collaboration
agents must not exceed the amount of
the distribution payment received by
the PGP, NPPGP, or TGP from the ACO.
(10) All downstream distribution
payments must be made by check,
electronic funds transfer, or another
traceable cash transaction.
(11) The downstream collaboration
agent must retain his or her ability to
make decisions in the best interests of
the patient, including the selection of
devices, supplies, and treatments.
(12) The downstream distribution
arrangement must not—
(i) Induce the downstream
collaboration agent to reduce or limit
medically necessary services to any
Medicare beneficiary; or
(ii) Reward the provision of items and
services that are medically unnecessary.
(13) The PGP, NPPGP, or TGP must
maintain contemporaneous
documentation regarding downstream
distribution arrangements in accordance
with § 512.110, including the following:
(i) The relevant written agreements.
(ii) The date and amount of any
downstream distribution payment.
(iii) The identity of each downstream
collaboration agent that received a
downstream distribution payment.
(iv) A description of the methodology
and accounting formula for determining
the amount of any downstream
distribution payment.
(14) The PGP, NPPGP, or TGP may
not enter into a downstream distribution
arrangement with any PGP member,
NPPGP member, or TGP member who
has—
(i) A sharing arrangement with an
EPM participant; or
(ii) A distribution arrangement with
the ACO that the PGP, NPPGP, or TGP
is a participant in.
(15) The PGP, NPPGP, or TGP must
retain and provide access to, and must
require downstream collaboration
agents to retain and provide access to,
the required documentation in
accordance with § 512.110.
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§ 512.520
EPM.
645
Enforcement authority under the
(a) OIG authority. OIG authority is not
limited or restricted by the provisions of
the EPM, including the authority to
audit, evaluate, investigate, or inspect
the EPM participant, EPM collaborators,
or any other person or entity or their
records, data, or information, without
limitation.
(b) Other authorities. None of the
provisions of the EPM limits or restricts
the authority of any other government
agency permitted by law to audit,
evaluate, investigate, or inspect the EPM
participant, EPM collaborators, or any
other person or entity or their records,
data, or information, without limitation.
§ 512.525 Beneficiary engagement
incentives under the EPM.
(a) General. EPM participants may
choose to provide in-kind patient
engagement incentives to beneficiaries
in an EPM episode, subject to the
following conditions:
(1) The incentive must be provided
directly by the EPM participant or by an
agent of the EPM participant under the
EPM participant’s direction and control
to the EPM beneficiary during an EPM
episode.
(2) The item or service provided must
be reasonably connected to medical care
provided to an EPM beneficiary during
an EPM episode.
(3) The item or service must be a
preventive care item or service or an
item or service that advances a clinical
goal, as listed in paragraph (c) of this
section, for a beneficiary in an EPM
episode by engaging the beneficiary in
better managing his or her own health.
(4) The item or service must not be
tied to the receipt of items or services
outside the EPM episode.
(5) The item or service must not be
tied to the receipt of items or services
from a particular provider or supplier.
(6) The availability of the items or
services must not be advertised or
promoted except that a beneficiary may
be made aware of the availability of the
items or services at the time the
beneficiary could reasonably benefit
from them.
(7) The cost of the items or services
must not be shifted to another federal
health care program, as defined at
section 1128B(f) of the Act.
(b) Technology provided to an EPM
beneficiary. Beneficiary engagement
incentives involving technology are
subject to the following additional
conditions:
(1) Items or services involving
technology provided to a beneficiary
may not exceed $1,000 in retail value
for any one beneficiary in any one EPM
episode.
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(2) Items or services involving
technology provided to a beneficiary
must be the minimum necessary to
advance a clinical goal, as listed in
paragraph (c) of this section, for a
beneficiary in an EPM episode.
(3) Items of technology exceeding
$100 in retail value must—
(i) Remain the property of the EPM
participant; and
(ii) Be retrieved from the beneficiary
at the end of the EPM episode. The EPM
participant must document all retrieval
attempts, including the ultimate date of
retrieval. Documented, diligent, good
faith attempts to retrieve items of
technology will be deemed to meet the
retrieval requirement.
(c) Clinical goals of the EPM. The
following are the clinical goals of the
EPM, which may be advanced through
beneficiary incentives:
(1) Beneficiary adherence to drug
regimens.
(2) Beneficiary adherence to a care
plan.
(3) Reduction of readmissions and
complications resulting from treatment
for the EPM clinical condition.
(4) Management of chronic diseases
and conditions that may be affected by
treatment for the EPM clinical
condition.
(d) Documentation of beneficiary
engagement incentives. (1) EPM
participants must maintain
documentation of items and services
furnished as beneficiary engagement
incentives that exceed $25 in retail
value.
(2) The documentation established
contemporaneously with the provision
of the items and services must include
at least the following:
(i) The date the incentive is provided.
(ii) The identity of the beneficiary to
whom the item or service was provided.
(3) The documentation regarding
items of technology exceeding $100 in
retail value must also include
contemporaneous documentation of any
attempt to retrieve technology at the end
of an EPM episode as described in
paragraph (b)(3) of this section.
(4) The EPM participant must retain
and provide access to the required
documentation in accordance with
§ 512.110.
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Subpart G—Waivers
§ 512.600 Waiver of direct supervision
requirement for certain post-discharge
home visits.
(a) General. CMS waives the
requirement in § 410.26(b)(5) of this
chapter that services and supplies
furnished incident to a physician’s
service must be furnished under the
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direct supervision of the physician (or
other practitioner) to permit home visits
as specified in this section. The services
furnished under this waiver are not
considered to be ‘‘hospital services,’’
even when furnished by the clinical
staff of the hospital.
(b) General supervision of qualified
personnel. The waiver of the direct
supervision requirement in
§ 410.26(b)(5) of this chapter applies
only in the following circumstances:
(1) The home visit is furnished during
the episode to a beneficiary who has
been discharged from an anchor
hospitalization.
(2) The home visit is furnished at the
beneficiary’s home or place of
residence.
(3) The beneficiary does not qualify
for home health services under sections
1835(a) and 1814(a) of the Act at the
time of any such home visit.
(4) The visit is furnished by clinical
staff under the general supervision of a
physician or non-physician practitioner.
Clinical staff are individuals who work
under the supervision of a physician or
other qualified health care professional,
and who are allowed by law, regulation,
and facility policy to perform or assist
in the performance of a specific
professional service, but do not
individually report that professional
service.
(5) The number of visits that are
furnished to the beneficiary during—
(i) An AMI episode, is up to 13 postdischarge home visits;
(ii) A CABG episode, is up to 9 postdischarge home visits; and
(iii) A SHFFT episode, is up to 9 postdischarge home visits.
(c) Payment. Up to the maximum
post-discharge home visits for a specific
EPM episode, as described in paragraph
(b)(5) of this section, may be billed
under Part B by the physician or nonphysician practitioner or by the
participant hospital to which the
supervising physician has reassigned
his or her billing rights.
(d) Other requirements. All other
Medicare rules for coverage and
payment of services incident to a
physician’s service continue to apply.
§ 512.605 Waiver of certain telehealth
requirements.
(a) Waiver of the geographic site
requirements. Except for the geographic
site requirements for a face-to-face
encounter for home health certification,
CMS waives the geographic site
requirements of section
1834(m)(4)(C)(i)(I) through (III) of the
Act for episodes being tested in an EPM,
but only for services that—
(1) May be furnished via telehealth
under existing requirements; and
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(2) Are included in the episode in
accordance with § 512.210.
(b) Waiver of the originating site
requirements. Except for the originating
site requirements for a face-to-face
encounter for home health certification,
CMS waives the originating site
requirements under section
1834(m)(4)(C)(ii)(I) through (VIII) of the
Act for episodes being tested in an EPM
to permit a telehealth visit to originate
in the beneficiary’s home or place of
residence, but only for services that—
(1) May be furnished via telehealth
under existing requirements; and
(2) Are included in an EPM episode
in accordance with § 512.210.
(c) Waiver of selected payment
provisions. (1) CMS waives the payment
requirements under section
1834(m)(2)(A) so that the facility fee
normally paid by Medicare to an
originating site for a telehealth service is
not paid if the service is originated in
the beneficiary’s home or place of
residence.
(2) CMS waives the payment
requirements under section
1834(m)(2)(B) to allow the distant site
payment for telehealth home visit
HCPCS codes unique to this model to
more accurately reflect the resources
involved in furnishing these services in
the home by basing payment upon the
comparable office visit relative value
units for work and malpractice under
the Physician Fee Schedule.
(d) Other requirements. All other
requirements for Medicare coverage and
payment of telehealth services continue
to apply, including the list of specific
services approved to be furnished by
telehealth.
§ 512.610
Waiver of SNF 3-day rule.
(a) Applicability of the SNF 3-day rule
waiver. CMS determines that the SNF 3day rule is—
(1) Waived for the AMI model;
(2) Not waived for the CABG model;
and
(3) Not waived for the SHFFT model.
(b) Waiver of the SNF 3-day rule. For
episodes being tested in those EPMs
where the SNF 3-day rule is waived
under paragraph (a) of this section, CMS
waives the SNF 3-day rule for coverage
of a SNF stay for a beneficiary who is
an EPM beneficiary on the date of
discharge from the anchor
hospitalization on or after October 4,
2018, but only if the SNF is identified
on the applicable calendar quarter list of
qualified SNFs at the time of EPM
beneficiary admission to the SNF.
(1) CMS determines the qualified
SNFs for each calendar quarter based on
a review of the most recent rolling 12
months of overall star ratings on the
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Five-Star Quality Rating System for
SNFs on the Nursing Home Compare
Web site. Qualified SNFs are rated an
overall of 3 stars or better for at least 7
of the 12 months.
(2) CMS posts to the CMS Web site
the list of qualified SNFs in advance of
the calendar quarter and the waiver only
applies for a beneficiary who has been
discharged from an anchor
hospitalization if the SNF is included
on the applicable calendar quarter list
for the date of the beneficiary’s
admission to the SNF.
(c) Financial liability for uncovered
SNF services. CMS will determine the
financial liability for uncovered SNF
services if, subsequent to an EPM
hospital applying the SNF 3-day rule
waiver under this section, an EPM
hospital incorrectly applies the SNF 3day rule waiver.
(1) If the EPM hospital discharges a
beneficiary to a SNF that is not a
qualified SNF under paragraph (b) of
this section and provides the beneficiary
with a discharge planning notice, as
described at § 512.450(b)(3), to the
beneficiary at the time of discharge to a
SNF then the SNF coverage
requirements apply and the beneficiary
may be financially liable for uncovered
SNF services.
(2) The EPM hospital will be
financially liable for the SNF stay and
the SNF must not bill the beneficiary for
the costs of the uncovered SNF services
furnished during the SNF stay if,
subsequent to an EPM hospital applying
the SNF 3-day rule waiver under this
section, CMS determines the EPM
hospital discharges a beneficiary—
(i) To a SNF that is not a qualified
SNF under paragraph (b) of this section
and the EPM hospital does not provide
the beneficiary with a discharge
planning notice, as described at
§ 512.450(b)(3)
(ii) That is in an EPM where the SNF
3-day rule waiver is not applicable
under paragraph (a) of this section; or
(iii) Prior to October 4, 2018, where
the SNF 3-day rule waiver is not
applicable under paragraph (b) of this
section.
(d) Other requirements. All other
Medicare rules for coverage and
payment of Part A-covered SNF services
continue to apply.
§ 512.615 Waiver of certain post-operative
billing restrictions.
(a) Waiver to permit certain services to
be billed separately during the 90-day
post-operative global surgical period.
CMS waives the billing requirements for
global surgeries to allow the separate
billing of certain post-discharge home
visits described under § 512.600,
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including those related to recovery from
the surgery, as described in paragraph
(b) of this section, for episodes being
tested in an EPM.
(b) Services to which the waiver
applies. Up to the maximum postdischarge home visits for a specific EPM
episode, as described in § 512.600(b)(5),
including those related to recovery from
the surgery, per EPM episode may be
billed separately under Medicare Part B
by the physician or non-physician
practitioner, or by the participant
hospital to which the physician or nonphysician practitioner has reassigned
his or her billing rights.
(c) Other requirements. All other
Medicare rules for global surgery billing
during the 90-day post-operative period
continue to apply.
§ 512.620 Waiver of deductible and
coinsurance that otherwise apply to
reconciliation payments or repayments.
(a) Waiver of deductible and
coinsurance. CMS waives the
requirements of sections 1813 and
1833(a) of the Act for Medicare Part A
and Part B payment systems only to the
extent necessary to make reconciliation
payments or receive repayments based
on the NPRA that reflect the episode
payment methodology under the final
payment model for EPM participant
hospitals.
(b) Reconciliation payments or
repayments. Reconciliation payments or
repayments do not affect the beneficiary
cost-sharing amounts for the Medicare
Part A and Part B services provided
under an EPM.
§ 512.630 Waiver of physician definition
for furnishing cardiac rehabilitation and
intensive cardiac rehabilitation services to
an EPM beneficiary.
(a) General. Section 410.49 of this
chapter requires cardiac rehabilitation
(CR) and intensive cardiac rehabilitation
(ICR) services to be furnished under the
direction of a physician as defined in
§ 410.49(a) of this chapter.
(b) Waiver of the physician definition.
For a provider or supplier of CR and ICR
services to an EPM beneficiary during
an AMI and CABG episode, as defined
in § 512.2, CMS waives the physician
definition to allow the functions of
supervising physician, prescribing
exercise, and establishing, reviewing,
and signing an individualized treatment
plan for CR and ICR services to be
furnished under the direction of—
(1) A physician, as defined in section
1861(r)(1) of the Act; or
(2) A qualified nonphysician
practitioner, as defined by CMS.
(c) Other definitions and
requirements. All other definitions and
requirements in § 410.49 of this chapter
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647
related to a physician or supervising
physician continue to apply.
Subpart H—CR Incentive Payment
Model for EPM and Medicare Fee-forService Participants
§ 512.700
Basis and scope.
(a) Basis. This subpart implements the
cardiac rehabilitation (CR) and intensive
cardiac rehabilitation (ICR) incentive
payment model under section 1115A of
the Act.
(b) Scope. This subpart sets forth the
following:
(1) The participants in the CR
incentive payment model.
(2) The CR/ICR services that count
toward CR incentive payments.
(3) The methodology for determining
CR incentive payments.
(4) Provisions for FFS–CR participants
that are not EPM participants.
§ 512.703 CR incentive payment model
participants.
(a) Selection of CR MSAs. The MSAs
eligible for selection for AMI and CABG
models were classified into one of seven
groups based on their historic
utilization of CR/ICR services. Within
each group, EPM–CR and FFS–CR
MSAs were randomly selected. The
number of EPM–CRs selected within
each group are distributed
proportionately between the groups
based on the assignment of the 98 EPM
MSAs. The same number of FFS–MSAs
were then drawn from each group.
(b) Hospitals eligible for CR incentive
payments. (1) Hospitals that are AMI
and CABG model participants located in
the EPM–CR MSAs.
(2) FFS–CR participants. Hospitals
located in the FFS–CR MSAs that would
meet all requirements in § 512.100(b) to
be an AMI or CABG model participant
if the hospital were located in an MSA
selected for the AMI and CABG models.
§ 512.705 CR/ICR services that count
towards CR incentive payments.
(a) Identification of CR/ICR services.
CR/ICR services are identified by the
HCPCS codes for CR/ICR services
included in the CMS change request
that implements the National Coverage
Determination in the CR performance
year.
(b) CR participant eligibility for CR
incentive payment. (1) For EPM–CR
participants, CR/ICR services paid by
Medicare under the OPPS or to any
supplier reporting place of service code
11 on the PFS claim for AMI and CABG
model beneficiaries during AMI and
CABG model episodes result in
eligibility for CR incentive payments.
(2) For FFS–CR participants, CR/ICR
services paid by Medicare under the
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OPPS or to any supplier reporting place
of service code 11 on the PFS claim for
beneficiaries during AMI care periods
and CABG care periods that would meet
the requirements to be AMI and CABG
model episodes in accordance with all
provisions in subpart B if the FFS–CR
participant were an EPM participant
result in eligibility for CR incentive
payments.
(c) Overlap between AMI care periods
and CABG care periods with AMI and
CABG model episodes. (1) An AMI care
period or CABG care period does not
begin if the beneficiary is in an AMI or
CABG model episode when the AMI
care period or CABG care period would
otherwise begin.
(2) An AMI care period or CABG care
period is canceled if at any time during
the AMI care period or CABG care
period the beneficiary initiates an AMI
or CABG model episode.
(d) CR incentive payment time period.
All AMI and CABG model episodes and
AMI care periods and CABG care
periods begin on or after July 1, 2017
and end on or before December 31,
2021.
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§ 512.710 Determination of CR incentive
payments.
(a) General. CMS provides a CR
incentive payment for each CR
performance year to each EPM–CR
participant and FFS–CR participant
based on CR/ICR services paid by
Medicare under the OPPS or to any
supplier reporting place of service code
11 on the PFS claim for beneficiaries in
AMI and CABG model episodes or AMI
and CABG care periods, respectively.
CMS makes CR incentive payments
from the Medicare Part B Trust Fund to
CR participants, and also submits
beneficiary-specific CR amounts to the
CMS Master Database Management
System. The initial level of the perservice CR incentive amount is $25 per
CR/ICR service for each of up to 11 CR/
ICR services paid for by Medicare. For
those CR/ICR services in an AMI or
CABG model episode or AMI care
period or CABG care period that exceed
11, the per-service CR incentive amount
increases to $175 per CR/ICR service for
each additional CR/ICR service paid for
by Medicare.
(b) Determination of CR incentive
payment. At the same time that CMS
carries out the determination of NPRA
and reconciliation process for an EPM
performance year as specified in
§ 512.305 for EPM participants, CMS
also determines each CR participant’s
CR incentive payment for the CR
performance year according to the
following:
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(1) CR amount when the CR service
count is less than 12. CMS determines
the CR amount for a beneficiary in an
AMI or CABG model episode or AMI
care period or CABG care period with a
CR service count less than 12 by
multiplying the CR service count by
$25.
(2) CR amount when the CR service
count is 12 or more. CMS determines
the CR amount for a beneficiary in an
AMI or CABG model episode or AMI
care period or CABG care period with a
CR service count of 12 or more as the
sum of $275 ($25 multiplied by 11 for
the first 11 CR/ICR services paid for by
Medicare) and $175 multiplied by the
difference between the CR service count
and 11.
(3) CR incentive payment. CMS sums
the CR amounts determined in
paragraphs (b)(1) and (2) of this section
across the CR participant’s beneficiaries
in AMI and CABG model episodes or
AMI care periods and CABG care
periods for a given CR performance year
to determine the CR incentive payment
for the CR performance year.
(c) Relation of CR incentive payments
to reconciliation and Medicare
repayments under EPMs. CR incentive
payments to EPM–CR participants
determined under § 512.710(b) are
exclusive of reconciliation payments
and Medicare repayment amounts
determined under § 512.305(d).
(d) Relation of CR incentive payments
to sharing arrangements for EPM–CR
participants. CR incentive payments
under § 512.710(b) are not eligible for
and may not be distributed under
sharing arrangements specified in
§ 512.500.
(e) Exclusion of CR incentive
payments when updating qualityadjusted target prices for EPM–CR
participants. CR incentive payments
under § 512.710(b) are excluded when
updating quality-adjusted target prices
for EPM performance years 3 through 5.
(f) CR incentive payment report. At
the same time CMS issues the
reconciliation report as specified in
§ 512.305(f) to EPM participants, CMS
issues each EPM–CR participant and
each FFS–CR participant a CR incentive
payment report for the CR performance
year. Each report contains the following:
(1) The number of AMI and CABG
model episodes or AMI care periods and
CABG care periods attributed to the CR
participant in which Medicare paid for
11 or fewer CR/ICR services for a
beneficiary during the CR performance
year, if any.
(2) The total number of CR/ICR
services Medicare paid for during AMI
and CABG model episodes or AMI care
periods and CABG care periods
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identified in paragraph (f)(1) of this
section.
(3) The amount of the CR incentive
payment attributable to the AMI and
CABG model episodes or AMI care
periods and CABG care periods
identified in paragraph (f)(1) of this
section.
(4) The number of AMI and CABG
model episodes or AMI care periods and
CABG care periods attributed to the CR
participant in which Medicare paid for
12 or more CR/ICR services for a
beneficiary during the CR performance
year, if any.
(5) The total number of CR/ICR
services Medicare paid for during AMI
and CABG model episodes or AMI care
periods and CABG care periods
identified in paragraph (f)(4) of this
section.
(6) The amount of the CR incentive
payment attributable to the AMI and
CABG model episodes or AMI care
periods and CABG care periods
identified in paragraph (f)(4) of this
section.
(7) The total amount of the CR
incentive payment.
(g) Timing of CR incentive payments.
CMS makes CR incentive payments on
a retrospective basis subject to the
following:
(1) For EPM–CR participants, CMS
makes the CR incentive payment, if any,
concurrently with EPM reconciliation
payments or repayment amounts
assessed for a specific EPM and CR
performance year, subject to the appeals
process for EPM participants in
§ 512.310.
(2) For FFS–CR participants, CMS
makes the CR incentive payments, if
any, at the same time as for EPM–CR
participants, subject to the provisions in
§ 512.720.
Provisions for FFS–CR Participants
§ 512.715 Access to records and retention
for FFS–CR participants.
FFS–CR participants and any other
individuals or entities providing items
or services to a FFS–CR beneficiary
must do all of the following:
(a) Allow the Government, including
CMS, OIG, HHS and the Comptroller
General or their designees, scheduled
and unscheduled access to all books,
contracts, records, documents, and other
evidence (including data related to CR/
ICR service utilization and payments,
billings, and the documentation
required under § 512.740(d)) sufficient
to enable the audit, evaluation,
inspection, or investigation of the
following:
(1) The individual’s or entity’s
compliance with CR incentive payment
model requirements.
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(2) The obligation to repay any CR
incentive payments owed to CMS.
(b) Maintain all such books, contracts,
records, documents, and other evidence
for a period of 10 years from the last day
of the FFS–CR participant’s
participation in the CR incentive
payment model or from the date of
completion of any audit, evaluation,
inspection, or investigation, whichever
is later, unless—
(1) CMS determines a particular
record or group of records should be
retained for a longer period and notifies
the FFS–CR participant at least 30
calendar days before the disposition
date; or
(2) There has been a dispute or
allegation of fraud or similar fault
against the FFS–CR participant or any
other individual or entity providing
items or services to a FFS–CR
beneficiary, in which case the records
must be maintained for 6 years from the
date of any resulting final resolution of
the dispute or allegation of fraud or
similar fault.
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§ 512.720 Appeals process for FFS–CR
participants.
(a) Notice of calculation error (first
level of appeal). Subject to the
limitations on review in subpart H of
this part, if a FFS–CR participant wishes
to dispute calculations involving a
matter related to a CR incentive
payment, the FFS–CR participant is
required to provide written notice of the
calculation error, in a form and manner
specified by CMS.
(1) Unless the FFS–CR participant
provides such notice, CMS deems final
the applicable CR incentive payment
report 45 calendar days after the
applicable CR incentive payment report
is issued and proceeds with the
payment as applicable.
(2) If CMS receives a notice of a
calculation error within 45 calendar
days of the issuance of the applicable
CR incentive payment report, CMS
responds in writing within 30 calendar
days to either confirm that there was an
error in the calculation or verify that the
calculation is correct, although CMS
reserves the right to an extension upon
written notice to the FFS–CR
participant.
(3) Only FFS–CR participants may use
notice of calculation error process
described in this part.
(b) Dispute resolution process (second
level of appeal). (1) If the FFS–CR
participant is dissatisfied with CMS’
response to the notice of a calculation
error, the FFS–CR participant may
request a reconsideration review in a
form and manner as specified by CMS.
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(2) The reconsideration request must
provide a detailed explanation of the
basis for the dispute and include
supporting documentation for the FFS–
CR participant’s assertion that CMS or
its representatives did not accurately
calculate the CR incentive payment in
accordance with subpart H of this part.
(3) If CMS does not receive a request
for reconsideration from the FFS–CR
participant within 10 calendar days of
the issue date of CMS’ response to the
FFS–CR participant’s notice of
calculation error, then CMS’ response to
the calculation error is deemed final and
CMS proceeds with the applicable
processes, as described in subpart H of
this part.
(4) The CMS reconsideration official
notifies the FFS–CR participant in
writing within 15 calendar days of
receiving the FFS–CR participant’s
review request of the following:
(i) The date, time, and location of the
review.
(ii) The issues in dispute.
(iii) The review procedures.
(iv) The procedures (including format
and deadlines) for submission of
evidence.
(5) The CMS reconsideration official
takes all reasonable efforts to schedule
the review to occur no later than 30
days after the date of receipt of the
notification.
(6) The provisions at § 425.804(b), (c),
and (e) of this chapter are applicable to
reviews conducted in accordance with
the reconsideration review process for
the FFS–CR participant.
(7) The CMS reconsideration official
issues a written determination within 30
days of the review. The determination is
final and binding.
(8) Only FFS–CR participants may use
the dispute resolution process described
in this part.
(c) Exception to the notice of
calculation error process. If the FFS–CR
participant contests a matter that does
not involve an issue contained in, or a
calculation which contributes to a CR
incentive payment report a notice of
calculation error is not required. In
these instances, if CMS does not receive
a request for reconsideration from the
FFS–CR participant within 10 calendar
days of the notice of the initial
determination, the initial determination
is deemed final and CMS proceeds with
the action indicated in the initial
determination. This does not apply to
the limitations on review in paragraph
(e) of this section.
(d) Notice of FFS–CR participant
termination from the CR incentive
payment model. If an FFS–CR
participant receives notification that it
has been terminated from the CR
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649
incentive payment model, it must
provide a written request for
reconsideration to CMS requesting
review of the termination within 10
calendar days of the notice. CMS has 30
days to respond to the FFS–CR
participant’s request for review. If the
FFS–CR participant fails to notify CMS,
the termination is deemed final.
(e) Limitations on review. In
accordance with section 1115A(d)(2) of
the Act, there is no administrative or
judicial review under sections 1869 or
1878 of the Act or otherwise for the
following:
(1) The selection of models for testing
or expansion under section 1115A of the
Act.
(2) The selection of organizations,
sites, or participants to test those
models selected.
(3) The elements, parameters, scope,
and duration of such models for testing
or dissemination.
(4) Determinations regarding budget
neutrality under section 1115A(b)(3) of
Act.
(5) The termination or modification of
the design and implementation of a
model under section 1115A(b)(3)(B) of
Act.
(6) Decisions to expand the duration
and scope of a model under section
1115A(c) of the Act, including the
determination that a model is not
expected to meet criteria described in
paragraph (e)(1) or (2) of this section.
§ 512.725 Data sharing for FFS–CR
participants.
(a) General. CMS makes available to
FFS–CR participants, through the most
appropriate means, data that CMS
determines may be useful to FFS–CR
participants to do the following:
(1) Determine appropriate ways to
increase the coordination of care.
(2) Improve quality.
(3) Enhance efficiencies in the
delivery of care.
(4) Otherwise achieve the goals of the
model described in this section.
(b) Beneficiary-identifiable data. (1)
CMS makes beneficiary-identifiable data
available to a FFS–CR participant in
accordance with applicable privacy and
security laws and only in response to
the FFS–CR participant’s request for
such data for a beneficiary who has been
furnished a billable service by the FFS–
CR participant corresponding to the
AMI care period or CABG care period
definitions.
(2) The minimum data necessary to
achieve the goals of the CR incentive
payment test, as determined by CMS,
may be provided under this section no
less frequently than on a quarterly basis
throughout the FFS–CR participant’s
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participation in the CR incentive
payment test.
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§ 512.730 Compliance enforcement for
FFS–CR participants.
(a) General. FFS–CR participants must
comply with all of the requirements
outlined in this subpart. Except as
specifically noted in this subpart, the
regulations under this subpart must not
be construed to affect the payment,
coverage, program integrity, or other
requirements (such as those in parts 412
and 482 of this chapter) that apply to
providers and suppliers under this
chapter.
(b) Failure to comply. (1) CMS may
take one or more of the remedial actions
set forth in paragraph (b)(2) of this
section if a FFS–CR participant does any
of the following:
(i) Fails to comply with any
requirements of this subpart or is
identified as noncompliant through
monitoring by HHS (including CMS and
OIG) of the CR incentive payment
model, including but not limited to the
following:
(A) Avoiding potentially high-severity
patients.
(B) Targeting potentially low-severity
patients.
(C) Failing to provide medically
appropriate services or systematically
engaging in the over or under-delivery
of appropriate care.
(D) Failing to provide beneficiaries
with complete and accurate
information.
(ii) Takes any action that threatens the
health or safety of patients.
(iii) Avoids at risk Medicare
beneficiaries, as this term is defined in
§ 425.20 of this chapter.
(iv) Avoids patients on the basis of
payer status.
(v) Is subject to sanctions or final
actions of an accrediting organization or
Federal, state, or local government
agency that could lead to the inability
to comply with the requirements and
provisions of this subpart.
(vi) Takes any action that CMS
determines for program integrity reasons
is not in the best interests of the CR
incentive payment model, or fails to
take any action that CMS determines for
program integrity reasons should have
been taken to further the best interests
of the CR incentive payment model.
(viii) Is subject to action by HHS
(including OIG and CMS) or the
Department of Justice to redress an
allegation of fraud or significant
misconduct, including intervening in a
False Claims Act qui tam matter, issuing
a pre demand or demand letter under a
civil sanction authority, or similar
actions.
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(ix) Is subject to action involving
violations of the physician self-referral
law, civil monetary penalties law,
Federal anti-kickback statute, antitrust
laws, or any other applicable Medicare
laws, rules, or regulations that are
relevant to the CR incentive payment
model.
(2) Remedial actions include the
following:
(i) Issuing a warning letter to the FFS–
CR participant.
(ii) Requiring the FFS–CR participant
to develop a corrective action plan,
commonly referred to as a CAP.
(iii) Reducing or eliminating the FFS–
CR participant’s CR incentive payment.
(iv) Terminating the FFS–CR
participant from the CR incentive
payment model.
§ 512.735 Enforcement authority for FFS–
CR participants.
(a) OIG authority. OIG authority is not
limited or restricted by the provisions of
the CR incentive payment model,
including the authority to audit,
evaluate, investigate, or inspect the
FFS–CR participant, or any other person
or entity or their records, data, or
information, without limitation.
(b) Other authorities. None of the
provisions of the CR incentive payment
model limits or restricts the authority of
any other government agency permitted
by law to audit, evaluate, investigate, or
inspect the FFS–CR participant or any
other person or entity or their records,
data, or information, without limitation.
§ 512.740 Beneficiary engagement
incentives for FFS–CR participant use.
(a) General. FFS–CR participants may
choose to provide in-kind patient
engagement incentives to beneficiaries
in an AMI care period or CABG care
period, subject to the following
conditions:
(1) The incentive must be provided
directly by the FFS–CR participant or by
an agent of the FFS–CR participant
under the FFS–CR participant’s
direction and control to the FFS–CR
beneficiary during an AMI care period
or CABG care period.
(2) The item or service provided must
be reasonably connected to medical care
provided to a FFS–CR beneficiary
during an AMI care period or CABG
care period.
(3) The item or service must be a
preventive care item or service or an
item or service that advances a clinical
goal, as listed in paragraph (c) of this
section, for a beneficiary during an AMI
care period or CABG care by engaging
the beneficiary in better managing his or
her own health.
(4) The item or service must not be
tied to the receipt of items or services
PO 00000
Frm 00472
Fmt 4701
Sfmt 4700
outside the AMI care period or CABG
care period.
(5) The item or service must not be
tied to the receipt of items or services
from a particular provider or supplier.
(6) The availability of items or
services must not be advertised or
promoted except that a beneficiary may
be made aware of the availability of
items or services at the time the
beneficiary could reasonably benefit
from them.
(7) The cost of the item or service
must not be shifted to another federal
health care program, as defined at
section 1128B(f) of the Act.
(b) Technology provided to an FFS–
CR beneficiary. Beneficiary engagement
incentives involving technology are
subject to the following additional
conditions:
(1) Items or services involving
technology provided to a beneficiary
may not exceed $1,000 in retail value
for any one beneficiary in any one AMI
care period or CABG care period.
(2) Items or services involving
technology provided to a beneficiary
must be the minimum necessary to
advance a clinical goal, as listed in
paragraph (c) of this section, for a
beneficiary in an AMI care period or
CABG care period.
(3) Items of technology exceeding
$100 in retail value must—
(i) Remain the property of the FFS–CR
participant; and
(ii) Be retrieved from the beneficiary
at the end of the AMI care period or
CABG care period. The FFS–CR
participant must document all retrieval
attempts, including the ultimate date of
retrieval. Documented, diligent, good
faith attempts to retrieve items of
technology will be deemed to meet the
retrieval requirement.
(c) Clinical goals of the CR incentive
payment model. The following are the
clinical goals of the CR incentive
payment model, which may be
advanced through beneficiary
incentives:
(1) Beneficiary adherence to drug
regimens.
(2) Beneficiary adherence to a care
plan.
(3) Reduction of readmissions and
complications resulting from treatment
for AMI or CABG.
(4) Management of chronic diseases
and conditions that may be affected by
treatment for AMI or CABG.
(d) Documentation of beneficiary
engagement incentives. (1) FFS–CR
participants must maintain
documentation of items and services
furnished as a beneficiary engagement
incentive that exceed $25 in retail value.
(2) The documentation established
contemporaneously with the provision
E:\FR\FM\03JAR2.SGM
03JAR2
Federal Register / Vol. 82, No. 1 / Tuesday, January 3, 2017 / Rules and Regulations
of the items and services must include
at least the following:
(i) The date the incentive is provided.
(ii) The identity of the beneficiary to
whom the item or service was provided.
(3) The documentation regarding
items of technology exceeding $100 in
retail must also include
contemporaneous documentation of any
attempt to retrieve technology at the end
of an AMI care period or CABG care
period as described in paragraph (b)(3)
of this section.
(4) The FFS–CR participant must
retain and provide access to the
required documentation in accordance
with § 512.715.
period, as defined in § 512.2. CMS
waives the physician definition to allow
the functions of supervising physician,
prescribing exercise, and establishing,
reviewing, and signing an
individualized treatment plan for CR or
ICR services to be furnished under the
direction of—
(1) A physician, as defined in section
1861(r)(1) of the Act; or
(2) A qualified nonphysician
practitioner, as defined by CMS.
(c) Other definitions and
requirements. All other definitions and
requirements in § 410.49 of this chapter
related to a physician or supervising
physician continue to apply.
§ 512.745 Waiver of physician definition
for furnishing CR and ICR services to a
FFS–CR beneficiary.
Subparts I–J [Reserved]
asabaliauskas on DSK3SPTVN1PROD with RULES
(a) General. Section 410.49 of this
chapter requires cardiac rehabilitation
and intensive cardiac rehabilitation
services to be furnished under the
direction of a physician as defined in
§ 410.49(a) of this chapter.
(b) Waiver of the physician definition.
For a provider or supplier of CR or ICR
services to a FFS–CR beneficiary during
an AMI care period or CABG care
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Jkt 241001
Subpart K—Model Termination
§ 512.900 Termination of an episode
payment model.
CMS may terminate any EPM for
reasons including but not limited to:
(a) CMS no longer has the funds to
support the EPM; or
(b) CMS terminates the EPM in
accordance with section 1115A(b)(3)(B)
of the Act. As provided by section
PO 00000
Frm 00473
Fmt 4701
Sfmt 9990
651
1115A(d)(2) of the Act, termination of
the model is not subject to
administrative or judicial review.
§ 512.905 Termination of the CR incentive
payment model.
CMS may terminate the CR incentive
payment model for reasons including,
but not limited to, one of the following:
(a) CMS no longer has the funds to
support the CR incentive payment
model.
(b) CMS terminates the CR incentive
payment model in accordance with
section 1115A(b)(3)(B) of the Act. As
provided by section 1115A(d)(2) of the
Act, termination of the model is not
subject to administrative or judicial
review.
Dated: December 13, 2016.
Andrew M. Slavitt,
Acting Administrator, Centers for Medicare
& Medicaid Services.
Dated: December 15, 2016.
Sylvia M. Burwell,
Secretary, Department of Health and Human
Services.
[FR Doc. 2016–30746 Filed 12–20–16; 4:15 pm]
BILLING CODE 4120–01–P
E:\FR\FM\03JAR2.SGM
03JAR2
Agencies
[Federal Register Volume 82, Number 1 (Tuesday, January 3, 2017)]
[Rules and Regulations]
[Pages 180-651]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2016-30746]
[[Page 179]]
Vol. 82
Tuesday,
No. 1
January 3, 2017
Part II
Book 2 of 2 Books
Pages 179-710
Department of Health and Human Services
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Centers for Medicare & Medicaid Services
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42 CFR Parts 510 and 512
Medicare Program; Advancing Care Coordination Through Episode Payment
Models (EPMs); Cardiac Rehabilitation Incentive Payment Model; and
Changes to the Comprehensive Care for Joint Replacement Model (CJR);
Final Rule
Federal Register / Vol. 82 , No. 1 / Tuesday, January 3, 2017 / Rules
and Regulations
[[Page 180]]
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DEPARTMENT OF HEALTH AND HUMAN SERVICES
Centers for Medicare & Medicaid Services
42 CFR Parts 510 and 512
[CMS-5519-F]
RIN 0938-AS90
Medicare Program; Advancing Care Coordination Through Episode
Payment Models (EPMs); Cardiac Rehabilitation Incentive Payment Model;
and Changes to the Comprehensive Care for Joint Replacement Model (CJR)
AGENCY: Centers for Medicare & Medicaid Services (CMS), HHS.
ACTION: Final rule.
-----------------------------------------------------------------------
SUMMARY: This final rule implements three new Medicare Parts A and B
episode payment models, a Cardiac Rehabilitation (CR) Incentive Payment
model and modifications to the existing Comprehensive Care for Joint
Replacement model under section 1115A of the Social Security Act. Acute
care hospitals in certain selected geographic areas will participate in
retrospective episode payment models targeting care for Medicare fee-
for-service beneficiaries receiving services during acute myocardial
infarction, coronary artery bypass graft, and surgical hip/femur
fracture treatment episodes. All related care within 90 days of
hospital discharge will be included in the episode of care. We believe
these models will further our goals of improving the efficiency and
quality of care for Medicare beneficiaries receiving care for these
common clinical conditions and procedures.
DATES: Effective dates: This rule is effective February 18, 2017,
except for the following amendatory instructions: number 3 amending 42
CFR 510.2; number 4 adding 42 CFR 510.110; number 6 amending 42 CFR
510.120; number 14 amending 42 CFR 510.405; number 15 42 CFR 510.410;
number 16 revising 42 CFR 510.500; number 17 revising 42 CFR 510.505;
number 18 adding 42 CFR 510.506; and number 19 amending 42 CFR 510.515,
which are effective July 1, 2017.
Applicability date: The regulations at 42 CFR part 512 are
applicable July 1, 2017.
FOR FURTHER INFORMATION CONTACT: For questions related to the EPMs:
EPMRULE@cms.hhs.gov.
For questions related to the CJR model: CJR@cms.hhs.gov.
SUPPLEMENTARY INFORMATION:
Electronic Access
This Federal Register document is also available from the Federal
Register online database through Federal Digital System (FDsys), a
service of the U.S. Government Printing Office. This database can be
accessed via the internet at https://www.gpo.gov/fdsys/.
Alphabetical List of Acronyms
Because of the many terms to which we refer by acronym,
abbreviation, or short form in this final rule, we are listing the
acronyms, abbreviations and short forms used and their corresponding
terms in alphabetical order.
ACE Acute-care episode
ACO Accountable Care Organization
ALOS Average length of stay
AMA American Medical Association
AMI Acute Myocardial Infarction
APM Alternative Payment Model
APRN Advanced Practice Registered Nurse
ASC QRP Ambulatory Surgical Center Quality Reporting Program
ASC Ambulatory Surgical Center
ASPE Assistant Secretary for Planning and Evaluation
BAA Business Associate Agreement
BPCI Bundled Payments for Care Improvement
CABG Coronary Artery Bypass Graft
CAD Coronary artery disease
CAH Critical access hospital
CBSA Core-Based Statistical Area
CC Complication or comorbidity
CCDA Consolidated clinical document architecture
CCDE Core clinical data elements
CCN CMS Certification Number
CEC Comprehensive ESRD Care Initiative
CEHRT Certified Electronic Health Record Technology
CEP Clinical Episode Payment
CFR Code of Federal Regulations
CHIP Children's Health Insurance Program
CJR Comprehensive Care for Joint Replacement
CMHC Community Mental Health Center
CMI Case Mix Index
CMP Civil monetary penalty
CQMC Core Quality Measure Collaborative
CMS Centers for Medicare & Medicaid Services
CoP Condition of Participation
CORF Comprehensive Outpatient Rehabilitation Facility
CPC Comprehensive Primary Care Initiative
CPT Current Procedural Terminology
CR Cardiac rehabilitation
CRNA Certified Registered Nurse Anesthetists
CSA Combined Statistical Area
CVICU Cardiovascular intensive care units
CY Calendar year
DES Drug-eluting stents
DME Durable medical equipment
DMEPOS Durable medical equipment, prosthetics, orthotics, and
supplies
DR Downside Risk
DSH Disproportionate Share Hospital
DUA Data Use Agreement
ED Emergency Department
ECMO Extracorporeal membrane circulation
ECQM Electronic Clinical Quality Measures
EFT Electronic funds transfer
EGM Episode Grouper for Medicare
EHR Electronic health record
E/M Evaluation and management
EPM Episode payment model
ESCO ESRD Seamless Care Organization
ESRD End-Stage Renal Disease
FFS Fee-for-service
FFR Fractional Flow Reserve
GAAP Generally-Accepted Accounting Principles
GEM General Equivalence Mapping
GPCI Geographic Practice Cost Index
HAC Hospital-Acquired Condition
HACRP Hospital-Acquired Condition Reduction Program
HCAHPS Hospital Consumer Assessment of Healthcare Providers and
Systems
HCC Hierarchical Condition Category
HCPCS Healthcare Common Procedure Coding System
HHA Home health agency
HHPPS Home Health Prospective Payment System
HHRG Home Health Resource Group
HHS U.S. Department of Health and Human Services
HH QRP Home Health Quality Reporting Program
HICN Health Insurance Claim Number
HIPAA Health Insurance Portability and Accountability Act
HIQR Hospital Inpatient Quality Reporting
HIV Human Immunodeficiency Virus
Health IT Health Information Technology
HLM Hierarchical Logistic Regression model
HLMR HCAHPS Linear Mean Roll Up
HOOS Hip Dysfunction and Osteoarthritis Outcome Score
HOPD Hospital outpatient department
HRRP Hospital Readmissions Reductions Program
HRR Hospital Referral Region
HVBP Hospital Value-Based Purchasing Program
ICD-9-CM International Classification of Diseases, 9th Revision,
Clinical Modification
ICHOM International Consortium for Health Outcomes Measurement
IRFQR Inpatient Rehabilitation Facilities Quality Reporting
ICD Implantable Cardioverter Defibrillator
ICD-10-CM International Classification of Diseases, 10th Revision,
Clinical Modification
ICR Intensive Cardiac Rehabilitation
I-I Inpatient to inpatient transfer
IME Indirect medical education
IP Inpatient
IPF Inpatient psychiatric facility
IPF QRP Inpatient Psychiatric Facility Quality Reporting Program
IPPS Inpatient Prospective Payment System
IRF Inpatient rehabilitation facility
IRF QRP Inpatient Rehabilitation Facility Quality Reporting Program
IVR Active Interactive Voice Recognition
KOOS Knee Injury and Osteoarthritis Outcome Score
[[Page 181]]
LAN Healthcare Payment Learning and Action Network
LBBB Left bundled branch block
LEJR Lower-extremity joint replacement
LEP limited English proficiency
LIP Low-income percentage
LOS Length-of-stay
LTCH QRP Long-Term Care Hospital Quality Reporting Program
LTCH Long-term care hospital
LUPA Low-utilization payment adjustment
MA Medicare Advantage
MAC Medicare Administrative Contractor
MACRA Medicare Access and CHIP Reauthorization Act of 2015
MAP Measure Application Partnership
MAPCP Multi-Payer Advanced Primary Care Practice
MAT Measure Authoring Tool
MCC Major complications or comorbidities
MCCM Medicare Care Choices Model
MDC Major diagnostic category
MDH Medicare-Dependent Hospital
MDM Master Database Management
MedPAC Medicare Payment Advisory Commission
MIPS Merit-based Incentive Payment System
MP Malpractice
MSA Metropolitan Statistical Area
MS-DRG Medical Severity Diagnosis-Related Group
MSPB Medicare Spending Per Beneficiary
NHDS National Hospital Discharge Survey
NCDR National Cardiovascular Data Registry
NDR No Downside Risk
NPI National Provider Identifier
NPPGP Non-Physician Practitioner Group Practice
NPRA Net Payment Reconciliation Amount
NQF National Quality Forum
NSTEMI Non ST-elevation myocardial infarction
OCM Oncology Care Model
OIG Department of Health and Human Services' Office of the Inspector
General
O-I Outpatient-to-inpatient transfer
OPPS Outpatient Prospective Payment System
OPT Outpatient Physical Therapist
OQR Outpatient Quality Reporting
PACE Program of All-Inclusive Care for the Elderly
PBPM Per-beneficiary per-month
PCI Percutaneous Coronary Intervention
PCMH Primary Care Medical Homes
PE Practice Expense
PEP Partial Episode Payment
PFS Physician Fee Schedule
PGP Physician group practice
PHA Partial hip arthroplasty
PQRS Physician Quality Reporting System
PPS Prospective Payment System
PRO Patient-Reported Outcome
PROMIS Patient-Reported Outcomes Measurement Information Systems
PROM Patient-Reported Outcome Performance Measure
PTAC Focused Payment Model Technical Advisory Committee
PTCA Percutaneous transluminal coronary angioplasty
PY Performance year
QCDR Qualified clinical data registries
QE Qualified Entity
QIO Quality Improvement Organization
QP Qualifying APM Participant
QPP Quality Payment Program
QRDA Quality Reporting Document Architecture
QRUR Quality and Resource Use Reports
RAC Recovery Audit Contractor
RRC Rural Referral Center
RSCR Risk-Standardized Complication Rate
RSRR Risk-Standardized Readmission Rate
RSMR Risk-Standardized Mortality Rate
RVU Relative Value Unit
SCH Sole Community Hospital
SDS Socio-demographic Status
SFT Secure File Transfer
SHFFT Surgical hip/femur fracture treatment
SHIP State Health Insurance Assistance Programs
SILS2 Single Item Health Literacy Screening
SLA Service level agreement
SNF Skilled nursing facility
SNF-QRP QRP Skilled Nursing Facility Quality Reporting Program
SSDMF Social Security Death Master file
STEMI ST-elevation myocardial infarction
STS Society of Thoracic Surgeons
ST-T ST-segment-T wave
TEP Technical Expert Panel
TGP Therapy Group Practice
THA Total hip arthroplasty
TIN Taxpayer identification number
TJA Total joint arthroplasty
TKA Total knee arthroplasty
TP Target price
UHDDS Uniform Hospital Discharge Data Set
VAD Ventricular Assist Device
VBP Value Based Purchasing
VR-12 Veterans Rand 12 Item Health Survey
Table of Contents
I. Executive Summary
A. Purpose
B. Summary of the Major Provisions
1. Model Overview--EPM Episodes of Care
2. Model Scope
3. Payment
4. Similar, Previous, and Concurrent Models
5. Overlap With Ongoing CMS Efforts
6. Quality Measures and Reporting Requirements
7. Beneficiary Protections
8. Financial Arrangements
9. Data Sharing
10. Program Waivers
C. Summary of Economic Effects
II. Background
III. Episode Payment Models
A. Selection of Episodes, Advanced Alternative Payment Model
Considerations, and Future Directions
1. Selection of Episodes for Episode Payment Models in This
Rulemaking
a. Overview
b. SHFFT Model
c. AMI and CABG Models
2. Advanced Alternative Payment Model Considerations
a. Overview for the EPMs
b. EPM Participant Tracks
c. Clinician Financial Arrangements Lists Under the EPMs
d. Documentation Requirements
3. Future Directions for Episode Payment Models
a. Refinements to the BPCI Initiative Models
b. Potential Future Condition-Specific Episode Payment Models
c. Potential Future Event-Based Episode Payment Models for
Procedures and Medical Conditions
d. Health Information Technology Readiness for Potential Future
Episode Payment Models
B. Definition of the Episode Initiator and Selected Geographic
Areas
1. Background
2. Definition of Episode Initiator
3. Financial Responsibility for Episode of Care
4. Geographic Unit of Selection and Exclusion of Selected
Hospitals
5. Overview and Options for Geographic Area Selection for AMI
and CABG Episodes
a. Exclusion of Certain MSAs
b. Selection Approach
(1) Factors Considered but Not Used
(2) Sample Size Calculations and the Number of Selected MSAs
(3) Method of Selecting MSAs
C. Episode Definition for EPMs
1. Background
2. Overview of Three New Episode Payment Models
3. Clinical Dimensions of AMI, CABG, and SHFFT Model Episodes
a. Definition of the Clinical Conditions Included in AMI, CABG,
and SHFFT Model Episodes
(1) AMI (Medical Management and PCI) Model
(2) CABG Model
(3) SHFFT (Excludes Lower Extremity Joint Replacement) Model
b. Definition of the Related Services Included in EPM Episodes
4. EPM Episodes
a. Beneficiary Care Inclusion Criteria and Beginning of EPM
Episodes
(1) General Beneficiary Care Inclusion Criteria
(2) Beginning AMI Episodes
(3) Beginning CABG Episodes
(4) Beginning SHFFT Episodes
(5) Special Policies for Hospital Transfers of Beneficiaries
With AMI
b. Middle of EPM Episodes
c. End of EPM Episodes
(1) AMI and CABG Models
(2) SHFFT Model
D. Methodology for Setting EPM Episode Prices and Paying EPM
Participants in the AMI, CABG, and SHFFT Models
1. Background
a. Overview
b. Key Terms for EPM Episode Pricing and Payment
2. Performance Years, Retrospective Episode Payments, and Two-
Sided Risk EPMs
a. Performance Period
b. Retrospective Payment Methodology
c. Two-Sided Risk EPMs
3. Adjustments to Actual EPM Episode Payments and to Historical
Episode Payments Used To Set Episode Prices
[[Page 182]]
a. Overview
b. Special Payment Provisions
c. Services That Straddle Episodes
d. High-Payment EPM Episodes
e. Treatment of Reconciliation Payments and Medicare Repayments
When Calculating Historical EPM-Episode Payments To Update EPM-
Episode Benchmark and Quality-Adjusted Target Prices
4. EPM-Episode Price-Setting Methodologies
a. Overview
(1) AMI Model DRGs
(2) CABG Model DRGs
(3) SHFFT Model DRGs
b. EPM-Episode Benchmark and Quality-Adjusted Target Price
Features
(1) Risk-Stratifying EPM-Episode Benchmark Prices Based on MS-
DRG and Diagnosis
(2) Adjustments To Account for EPM-Episode Price Variation
(a) Adjustments for Certain AMI Model Episodes With Chained
Anchor Hospitalizations
(b) Adjustments for CABG Model Episodes
(c) Adjustments for Certain AMI Model Episodes With CABG
Readmissions
(d) Potential Future Approaches To Setting Target Prices for AMI
and Hip Fracture Episodes
(e) Summary of Pricing Methodologies for AMI, CABG, and SHFFT
Model Episode Scenarios
(3) 3 Years of Historical Data
(4) Trending Historical Data to the Most Recent Year
(5) Update Historical EPM-Episode Payments for Ongoing Payment
System Updates
(6) Blend Hospital-Specific and Regional Historical Data
(7) Define Regions as U.S. Census Divisions
(8) Normalize for Provider-Specific Wage Adjustment Variations
(9) Combining Episodes To Set Stable Benchmark and Quality-
Adjusted Target Prices
(10) Effective Discount Factor
c. Approach To Combine Pricing Features for all SHFFT Model
Episodes and AMI Model Episodes Without CABG Readmissions
d. Approach To Combine Pricing Features for CABG Model Episodes
(1) Anchor Hospitalization Portion of CABG Model Episodes
(2) Approach To Combine Pricing Features for Post-Anchor
Hospitalization Portion of CABG Model Episodes
(3) Combine CABG Anchor Hospitalization Benchmark Price and CABG
Post-Anchor Hospitalization Benchmark Price
e. Approach To Combine Pricing Features for AMI Model Episodes
With CABG Readmissions
5. Process for Reconciliation
a. Net Payment Reconciliation Amount (NPRA)
b. Payment Reconciliation
c. Reconciliation Report
6. Adjustments for Overlaps With Other Innovation Center Models
and CMS Programs
a. Overview
b. Provider Overlap
(1) BPCI Participant Hospitals in Geographic Areas Selected for
EPMs
(2) BPCI Physician Group Practice (PGP) Episode Initiators in
Hospitals Participating in EPMs
c. Beneficiary Overlap
(1) Beneficiary Overlap With BPCI
(2) Beneficiary Overlap With the CJR Model and Other EPMs
(3) Beneficiary Overlap With Shared Savings Models and Programs
d. Payment Reconciliation of Overlap With Non-ACO CMS Models and
Programs
7. Limits or Adjustments to EPM Participants' Financial
Responsibility
a. Overview
b. Limit on Actual EPM-Episode Payment Contribution to Repayment
Amounts and Reconciliation Payments
(1) Limit on Actual EPM-Episode Payment Contribution to
Repayment Amounts
(2) Limitation on Reconciliation Payments
c. Additional Protections for Certain EPM Participants
(1) Policies for Certain EPM Participants to Further Limit
Repayment Responsibility
(2) Considerations for Hospitals Serving a High Percentage of
Potentially Vulnerable Populations
d. Application of Stop-Gain and Stop-Loss Limits
e. EPM Participant Responsibility for Increased Post-Episode
Payments
8. Appeals Process
a. Overview
b. Notice of Calculation Error (First Level Appeal)
c. Dispute Resolution Process (Second Level of Appeal)
d. Exception to the Notice of Calculation Error Process and
Notice of Termination
e. Limitations on Review
E. EPM Quality Measures, Public Display, and Use of Quality
Measures in the EPM Payment Methodology
1. Background
2. Selection of Quality Measures for the EPMs
a. Overview of Quality Measure Selection
b. AMI Model Quality Measures
c. CABG Model Quality Measures
d. SHFFT Model Quality Measures
3. Use of Quality Measures in the EPM Payment Methodologies
a. Overview of EPM Composite Quality Score Methodology
b. Determining Quality Measure Performance
c. Determining Quality Measure Improvement
d. Determining Successful Submission of Voluntary Data for AMI
and SHFFT Models
(1) Hybrid AMI Mortality (NQF #2473) Voluntary Data
(2) Patient-Reported Outcomes and Limited Risk Variable
Voluntary Data Following Elective Primary THA/TKA
e. Calculation of the EPM-Specific Composite Quality Score
(1) AMI Model Composite Quality Score
(2) CABG Model Composite Quality Score
(3) SHFFT Model Composite Quality Score
f. EPM Pay-for-Performance Methodologies To Link Quality and
Payment
(1) Overview of Pay-for-Performance Proposals Applicable to the
EPMs
(2) AMI and CABG Model Pay-for-Performance Methodology
(a) AMI Model Pay-for-Performance Methodology
(b) CABG Model Pay-for-Performance Methodology
(c) Alignment Between the AMI and CABG Model Methodologies
(3) SHFFT Model Pay-for-Performance Methodology
4. Details on Quality Measures for the EPMs
a. AMI Model-Specific Measures
(1) Hospital 30-Day, All-Cause, Risk-Standardized Mortality Rate
Following Acute Myocardial Infarction (AMI) Hospitalization (NQF
#0230) (MORT-30-AMI)
(a) Background
(b) Data Sources
(c) Cohort
(d) Inclusion and Exclusion Criteria
(e) Risk-Adjustment
(f) Calculating the Risk-Standardized Mortality Ratio (RSMR) and
Performance Period
(2) Excess Days in Acute Care After Hospitalization for Acute
Myocardial Infarction (AMI Excess Days)
(a) Background
(b) Data Sources
(c) Cohort
(d) Inclusion and Exclusion Criteria
(e) Risk-Adjustment
(f) Calculating the Rate and Performance Period
(3) Hybrid Hospital 30-Day, All-Cause, Risk-Standardized
Mortality Rate Following Acute Myocardial Infarction (AMI)
Hospitalization (NQF #2473) (Hybrid AMI Mortality)
(a) Background
(b) Data Sources
(c) Cohort
(d) Inclusion and Exclusion Criteria
(e) Risk-Adjustment
(f) Calculating the Risk-Standardized Mortality Ratio (RSMR) and
Performance Period
(g) Requirements for Successful Submission of AMI Voluntary Data
b. CABG Model-Specific Measure
(1) Hospital 30-Day, All-Cause, Risk-Standardized Mortality Rate
(RSMR) Following Coronary Artery Bypass Graft (CABG) Surgery (NQF
#2558) (MORT-30-CABG)
(a) Background
(b) Data Source
(c) Cohort
(d) Inclusion and Exclusion Criteria
(e) Risk-Adjustment
(f) Calculating the Risk-Standardized Mortality Ratio (RSMR) and
Performance Period
c. SHFFT Model-Specific Measures
(1) Hospital Level Risk Standardized Complication Rate (RSCR)
Following Elective Primary Total Hip Arthroplasty (THA) and/or Total
Knee Arthroplasty (TKA) (NQF #1550) (Hip/Knee Complications)
(a) Background
(b) Data Sources
[[Page 183]]
(c) Cohort
(d) Inclusion and Exclusion Criteria
(e) Risk Adjustment
(f) Calculating the Risk Standardized Complication Rate and
Performance Period
(2) Hospital-Level Performance Measure(s) of Patient-Reported
Outcomes Following Elective Primary Total Hip and/or Total Knee
Arthroplasty
(a) Background
(b) Data Sources
(c) Cohort
(d) Inclusion and Exclusion Criteria
(e) Outcome
(f) Risk Adjustment (If Applicable)
(g) Calculating the Risk Standardized Rate
(h) Performance Period for Successful Submission of THA/TKA
Patient-Reported Outcome-Based Voluntary Data
(i) Requirements for Successful Submission of THA/TKA Patient-
Reported-Outcome-Based Voluntary Data
d. Measure Used for All EPMs
(1) Hospital Consumer Assessment of Healthcare Providers and
Systems (HCAHPS) Survey (NQF #0166)
(a) Background
(b) Data Sources
(c) Cohort
(d) Inclusion and Exclusion Criteria
(e) Case-Mix Adjustment
(f) HCAHPS Scoring
(g) Calculating the Rate and Performance Period
e. Potential Future Measures
5. Form, Manner, and Timing of Quality Measure Data Submission
6. Display of Quality Measures and Availability of Information
for the Public From the AMI, CABG, and SHFFT Models
F. Compliance Enforcement and Termination of an Episode Payment
Model
1. Overview and Background
2. Compliance Enforcement for EPMs
3. Termination of an Episode Payment Model
G. Monitoring and Beneficiary Protection
1. Introduction and Summary
2. Beneficiary Choice
3. Beneficiary Notification
4. Monitoring for Access To Care
5. Monitoring for Quality of Care
6. Monitoring for Delayed Care
H. Access to Records and Record Retention
I. Financial Arrangements Under EPM
1. Background
2. Overview of the EPM Financial Arrangements
3. EPM Collaborators
4. Sharing Arrangements Under EPM
a. General
b. Requirements
c. Gainsharing Payment, Alignment Payment, and Internal Cost
Savings Conditions and Restrictions
d. Documentation Requirements
5. Distribution Arrangements Under the EPM
a. General
b. Requirements
6. Downstream Distribution Arrangements Under the EPM
a. General
b. Requirements
7. Summary of Proposals for Sharing, Distribution, and
Downstream Distribution Arrangements Under the EPM
8. Enforcement Authority
9. Beneficiary Engagement Incentives Under the EPM
a. General
b. Technology Provided to an EPM Beneficiary
c. Clinical Goals of the EPM
d. Documentation of Beneficiary Incentives
10. Compliance With Fraud and Abuse Laws
J. Waivers of Medicare Program Requirements
1. Overview
2. Summary of Waivers Adopted Under the CJR Model
3. Analysis of Current Model Data
a. Analysis of Waiver Usage
b. Analysis of Discharge Destination--Post-Acute Care Usage
c. Analysis of Hospital Mean Length of Stay Data
4. Post-Discharge Home Visits
a. AMI Model
b. CABG Model
c. SHFFT Model
5. Billing and Payment for Telehealth Services
6. SNF 3-Day Rule
a. Waiver of SNF 3-Day Rule
b. Additional Beneficiary Protections Under the SNF 3-Day Stay
Rule Waiver
7. Waivers of Medicare Program Rules To Allow Reconciliation
Payment or Repayment Actions Resulting From the Net Payment
Reconciliation Amount
8. New Waiver for Providers and Suppliers of Cardiac
Rehabilitation and Intensive Cardiac Rehabilitation Services
Furnished to EPM Beneficiaries During an AMI or CABG Episode
K. Data Sharing
1. Overview
2. Beneficiary Claims Data
3. Aggregate Regional Data
4. Timing and Period of Baseline Data
5. Frequency and Period of Claims Data Updates for Sharing
Beneficiary-Identifiable Claims Data During the Performance Period
6. Legal Permission To Share Beneficiary-Identifiable Data
7. Data Considerations With Respect to EPM and CJR Collaborators
L. Coordination With Other Agencies
IV. Evaluation Approach
A. Background
B. Design and Evaluation Methods
C. Data Collection Methods
D. Key Evaluation Research Questions
E. Evaluation Period and Anticipated Reports
V. Comprehensive Care for Joint Replacement Model
A. Participant Hospitals in the CJR Model
B. Inclusion of Reconciliation and Repayment Amounts When
Updating Data for Quality-Adjusted Target Prices
C. Quality-Adjusted Target Price
D. Reconciliation
1. Hospital Responsibility for Increased Post-Episode Payments
2. ACO Overlap and Subsequent Reconciliation Calculation
3. Stop-Loss and Stop-Gain Limits
4. Modifications to Reconciliation Process
E. Use of Quality Measures and the Composite Quality Score
1. Hospitals Included in Quality Performance Distribution
2. Quality Improvement Points
3. Relationship of Composite Quality Score to Quality Categories
4. Maximum Composite Quality Score
5. Acknowledgement of Voluntary Data Submission
6. Calculation of the HCAHPS Linear Mean Roll-Up (HLMR) Score
F. Accounting for Overlap With CMS ACO Models and the Medicare
Shared Savings Program
G. Appeals Process
H. Beneficiary Notification
I. Compliance Enforcement
1. Failure To Comply
J. Financial Arrangements Under the CJR Model
1. Definitions Related to Financial Arrangements
a. Addition to the Definition of CJR Collaborators
b. Deleting the Term Collaborator Agreements
c. Addition of CJR Activities
2. Sharing Arrangements
a. General
b. Requirements
c. Gainsharing Payment, Alignment Payment, and Internal Cost
Savings Conditions and Restrictions
d. Documentation
3. Distribution Arrangements
a. General
b. Requirements
4. Downstream Distribution Arrangements Under the CJR Model
a. General
b. Requirements
5. Summary of Proposals for Sharing, Distribution, and
Downstream Distribution Arrangements Under the CJR Model
K. Beneficiary Incentives Under the CJR Model
L. Access to Records and Record Retention
M. Waivers of Medicare Program Rules To Allow Reconciliation
Payment or Repayment Actions Resulting From the Net Payment
Reconciliation Amount
N. SNF 3-Day Waiver Beneficiary Protections
O. Advanced Alternative Payment Model Considerations
1. Overview for CJR
2. CJR Participant Hospital Track
3. Clinician Financial Arrangements Lists Under the CJR Model
4. Documentation Requirements
VI. Cardiac Rehabilitation Incentive Payment Model
A. Background
B. Overview of the CR Incentive Payment Model
1. Rationale for the CR Incentive Payment Model
2. General Design of the CR Incentive Payment Model
C. CR Incentive Payment Model Participants
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D. CR/ICR Services That Count Towards CR Incentive Payments
E. Determination of CR Incentive Payments
1. Determination of CR Amounts That Sum To Determine a CR
Incentive Payment
2. Relation of CR Incentive Payments to EPM Pricing and Payment
Policies and Sharing Arrangements for EPM-CR Participants
3. CR Incentive Payment Report
4. Timing for Making CR Incentive Payments
F. Provisions for FFS-CR Participants
1. Access to Records and Retention for FFS-CR Participants
2. Appeals Process for FFS-CR Participants
a. Overview
b. Notice of Calculation Error (First Level Appeal)
c. Dispute Resolution Process (Second Level of Appeal)
d. Exception to the Notice of Calculation Error Process and
Notice of Termination
e. Limitations on Review
3. Data Sharing for FFS-CR Participants
a. Overview
b. Data Sharing With CR Participants
4. Compliance Enforcement for FFS-CR Participants and
Termination of the CR Incentive Payment Model
5. Enforcement Authority for FFS-CR Participants
6. Beneficiary Engagement Incentives for FFS-CR Participants
7. Waiver of Physician Definition for FFS-CR Participants
Furnishing CR and ICR Services
a. Overview of Program Rule Waivers Under an EPM
b. General Physician Requirements for Furnishing CR/ICR Services
c. Waiver of Physician Definition For EPM-CR Participants
Furnishing CR and ICR Services
d. Waiver of Physician Definition For FFS-CR Participants
Furnishing CR and ICR Services
G. Considerations Regarding Financial Arrangements Under the CR
Incentive Payment Model
VII. Collection of Information Requirements
VIII. Regulatory Impact Analysis
A. Statement of Need
1. Need for EPM Final Rule
2. Need for CJR Modifications
3. Need for CR Incentive Payment Model
4. Aggregate Impact of EPMs, CJR, and CR Incentive Payment Model
B. Overall Impact
C. Anticipated Effects
1. Overall Magnitude of the Model and Its Effects on the Market
a. EPMs
b. CJR
c. CR Incentive Payment Model
d. Aggregate Effects on the Market
2. Effects on the Medicare Program
a. EPMs
(1) Assumptions and Uncertainties
(2) Analyses
(3) Uncertainties
b. CJR
(1) Assumptions and Uncertainties
(2) Analyses
c. CR Incentive Payment Model
(1) Assumptions and Uncertainties
(2) Analysis
d. Further Consideration
3. Effects on Beneficiaries
4. Effects on Small Rural Hospitals
5. Effects on Small Entities
6. Effects on Collection of Information
7. Unfunded Mandates
D. Alternatives Considered
E. Accounting Statement and Table
F. Conclusion
Regulations Text
I. Executive Summary
A. Purpose
The purpose of this final rule--Advancing Care Coordination through
Episode Payment Models is to implement the creation and testing of
three new episode payment models (EPMs) and a Cardiac Rehabilitation
(CR) incentive payment model under the authority of the Center for
Medicare and Medicaid Innovation (``the Innovation Center''), as well
as to implement several modifications to the Comprehensive Care for
Joint Replacement model. Section 1115A of the Social Security Act
(``the Act'') authorizes the Innovation Center to test innovative
payment and service-delivery models to reduce Medicare, Medicaid, and
Children's Health Insurance Program (CHIP) expenditures while
preserving or enhancing the quality of care furnished to such programs'
beneficiaries. Under the fee-for-service (FFS) program, Medicare makes
separate payments to providers and suppliers for the items and services
furnished to a beneficiary over the course of treatment (an episode of
care). With the amount of payments dependent on the volume of services
delivered, providers may not have incentives to invest in quality-
improvement and care-coordination activities. As a result, care may be
fragmented, unnecessary, or duplicative. The goal for the EPMs is to
improve the quality of care provided to beneficiaries in an applicable
episode while reducing episode spending through financial
accountability.\1\ The EPMs include models for episodes of care
surrounding an acute myocardial infarction (AMI), coronary artery
bypass graft (CABG), and surgical hip/femur fracture treatment
excluding lower extremity joint replacement (SHFFT). Under this final
rule, the Centers for Medicare & Medicaid Services (CMS) will test
whether an EPM for AMI, CABG, and SHFFT episodes of care will reduce
Medicare expenditures while preserving or enhancing the quality of care
for Medicare beneficiaries. We anticipate that the finalized models
will benefit Medicare beneficiaries by improving the coordination and
transition of care, improving the coordination of items and services
paid for through FFS Medicare, encouraging more provider investment in
infrastructure and redesigned care processes for higher-quality and
more efficient service delivery, and incentivizing higher-value care
across the inpatient and post-acute care spectrum. We proposed on
August 2, 2016 to test the proposed EPMs for 5 performance years,
beginning July 1, 2017, and ending December 31, 2021 (81 FR 50799) and
we are finalizing those dates as proposed in this final rule.
---------------------------------------------------------------------------
\1\ In this final rule, we use the terms ``AMI episode,'' ``CABG
episode,'' and ``SHFFT episode'' to refer to episodes of care as
described in section III.C. of this final rule.
---------------------------------------------------------------------------
Within this final rule, we discuss three distinct EPMs focused on
episodes of care for AMI, CABG, and SHFFT episodes. We chose these
episodes for the models because, as discussed in depth in section
III.A. of this final rule and as stated in the proposed rule, we
believe hospitals would have a significant opportunity to redesign care
and to improve the quality of care furnished during the applicable
episode. The EPMs will enable hospitals to consider the most
appropriate strategies for care redesign, including: (1) Increasing
post-hospitalization follow-up and medical management for patients; (2)
coordinating across the inpatient and post-acute care spectrum; (3)
conducting appropriate discharge planning; (4) improving adherence to
treatment or drug regimens; (5) reducing readmissions and complications
during the post-discharge period; (6) managing chronic diseases and
conditions that may be related to the EPMs' episodes; (7) choosing the
most appropriate post-acute care setting; and (8) coordinating between
providers and suppliers such as hospitals, physicians, and post-acute
care providers. The EPMs would offer hospitals the opportunity to
examine and better understand their own care processes and patterns
with regard to patients in AMI, CABG, and SHFFT episodes, as well as
the processes of post-acute care providers and physicians.
We previously have used our statutory authority under section 1115A
of the Act to test other episode payment models such as the Bundled
Payments for Care Improvement (BPCI) initiative and Comprehensive Care
for Joint Replacement (CJR) model. Bundled payments for multiple
services in an episode of care hold participating organizations
financially accountable for that episode of care. Such models also
allow participants to receive payments based in part on the reduction
in Medicare expenditures that arise
[[Page 185]]
from such participants' care redesign efforts. This payment can be used
for investments in care redesign strategies and infrastructure, as well
as to incentivize collaboration with other providers and suppliers
furnishing services to beneficiaries included in the models.
We believe the EPMs will further the Innovation Center's mission
and the Administration's goal of increasingly paying for value and
outcomes, rather than for volume alone,\2\ by promoting the alignment
of financial and other incentives for all health care providers caring
for beneficiaries during SHFFT, CABG, or AMI episodes. The acute care
hospital where an eligible beneficiary has a hospitalization for one of
the procedures or clinical conditions included in these EPMs will be
held accountable for spending during the episode of care. EPM
participants could earn reconciliation payments by appropriately
reducing expenditures and meeting certain quality metrics. EPM
participants will also gain access to data and educational resources to
better understand care patterns during the inpatient hospitalization
and post-acute periods, as well as associated spending. Payment
approaches that reward providers for assuming financial and performance
accountability for a particular episode of care create incentives for
the implementation and coordination of care redesign between
participants and other providers and suppliers such as physicians and
post-acute care providers.
The AMI, CABG, and SHFFT models will require the participation of
hospitals in multiple geographic areas that might not otherwise
participate in testing episode payment for the episodes of care. CMS is
testing other episode payment models with the BPCI initiative and the
CJR model. The BPCI initiative is voluntary; providers applied to
participate and chose from 48 clinical episodes. BPCI participants
entered the at-risk phase between 2013 and 2015 and have the option to
continue participating in the initiative through FY 2018. In the CJR
model, acute care hospitals in selected geographic areas are required
to participate in the CJR model for all eligible lower-extremity joint
replacement (LEJR) episodes that initiate at a CJR participant
hospital. The CJR model began its first of 5 performance years on April
1, 2016. Realizing the full potential of new EPMs will require the
engagement of an even broader set of providers than have participated
to date in our episode payment models such as the BPCI initiative and
the CJR model. As such, we are interested in testing and evaluating the
impact of episode payment for the three EPMs in a variety of
circumstances, including those hospitals that may not otherwise
participate in such a test.
While we note that testing of the CJR model that began in April
2016 will allow CMS to gain experience with requiring hospitals to
participate in an episode payment model, the clinical circumstances of
the episodes we proposed (AMI, CABG, and SHFFT) differ in important
ways from the LEJR episodes included in the CJR model. LEJR procedures
are common among the Medicare population, and the majority of such
procedures are elective. In contrast, under the three EPMs, CMS will
test episode payment for certain cardiac conditions and procedures, as
well as SHFFT. We expect the patient population included in these
episodes will be substantially different from the patient population in
CJR episodes, due to the clinical nature of the cardiac and SHFFT
episodes. Beneficiaries in these episodes commonly have chronic
conditions that contribute to the initiation of the episodes, and need
both planned and unplanned care throughout the EPM episode following
discharge from the hospitalization that begins the episode. Both AMI
and CABG model episodes primarily include beneficiaries with
cardiovascular disease, a chronic condition which likely contributed to
the acute events or procedures that initiate the episodes. About half
the average AMI model historical episode spending was for the
hospitalization, with the majority of spending following discharge from
the hospitalization due to hospital readmissions, while there was
relatively less spending on SNF services, Part B professional services,
and hospital outpatient services. In CABG model historical episodes,
about three-quarters of episode spending was for the hospitalization,
with the remaining episode spending relatively evenly divided between
Part B professional services and hospital readmissions, and a lesser
percentage on SNF services. Similar to AMI episodes, post-acute care
provider use was relatively uncommon in CABG model historical episodes,
while hospital readmissions during CABG model historical episodes were
relatively common. SHFFT model historical episodes also were
accompanied by substantial spending for hospital readmissions, and
post-acute care provider use in these episodes also was high.\2\ The
number of affected beneficiaries and potential impact of the models on
quality and Medicare spending present an important opportunity to
further the Administration's goal of shifting health care payments to
support the quality of care over the quantity of services by promoting
better coordination among health care providers and suppliers and
greater efficiency in the care of beneficiaries in these models, while
reducing Medicare expenditures.\3\ Pay-for-performance episode payment
models such as the three EPMs in this rule financially incentivize
improved quality of care and reduced cost by aligning the financial
incentives of all providers and suppliers caring for model
beneficiaries with these goals. This alignment leads to a heightened
focus on care coordination and management throughout the episode that
prioritizes the provision of those items and services which improve
beneficiary outcomes and experience at the lowest cost. A more detailed
discussion of the evidence supporting the episode selection for these
models can be found in section III.A.1. of this final rule.
---------------------------------------------------------------------------
\2\ Episodes for AMI, CABG, and SHFFT beneficiaries initiated by
all U.S. IPPS hospitals not in Maryland and constructed using
standardized Medicare FFS Parts A and B claims, as proposed in this
rule that end in CY 2014.
\3\ Sylvia Mathews Burwell, HHS Secretary, Progress Towards
Achieving Better Care, Smarter Spending, Healthier People, https://www.hhs.gov/blog/2015/01/26/progress-towards-better-care-msarter-spending-healthier-people.html (January 26, 2015).
---------------------------------------------------------------------------
These models will also allow CMS to gain additional experience with
episode-payment based approaches for hospitals with variance in (1)
historic care and utilization patterns; (2) patient populations and
care patterns; (3) roles within their local markets; (4) volumes of
services; (5) levels of access to financial, community, or other
resources; and (6) levels of population and health-care-provider
density, including local variations in the availability and use of
different categories of post-acute care providers. We believe that
participation in the EPMs by a large number of hospitals with diverse
characteristics will result in a robust data set for evaluating this
payment approach and will stimulate the rapid development of new
evidence-based knowledge. Testing the EPMs in this manner will also
allow us to learn more about patterns of inefficient utilization of
health care services and how to incentivize quality improvement for
beneficiaries receiving services in AMI, CABG, and SHFFT episodes. This
knowledge could potentially inform future Medicare payment policies.
We proposed the CR incentive payment model to test the effects on
[[Page 186]]
quality of care and Medicare expenditures of providing financial
incentives to hospitals for beneficiaries hospitalized for treatment of
AMI or CABG to encourage care coordination and greater utilization of
medically necessary CR and intensive cardiac rehabilitation (ICR)
services for 90 days post-hospital discharge where the beneficiary's
overall care is paid under either an EPM or the Medicare FFS program.
Despite the evidence from multiple studies that CR services improve
health outcomes, the literature also indicates that these services are
underutilized, estimating that only about 35 percent of AMI patients
older than 50 receive this indicated treatment.4 5 6 Recent
analysis confirms a similar pattern of underutilization for Medicare
beneficiaries who are eligible for and could benefit from CR.
---------------------------------------------------------------------------
\5\ Anderson L. et al. Exercise-based cardiac rehabilitation for
coronary heart disease. Cochrane Database Syst Rev. 2016 Jan
5;1:CD001800.
\6\ Receipt of outpatient cardiac rehabilitation among heart
attack survivors--United States, 2005. MMWR Morbidity and mortality
weekly report. 2008 Feb 1:57(4):89-94.
---------------------------------------------------------------------------
Considering the evidence demonstrating that CR/ICR services improve
long-term patient outcomes, the room for improvement in CR/ICR service
utilization for beneficiaries eligible for this benefit, and the need
for ongoing, chronic treatment for underlying coronary artery disease
(CAD) among beneficiaries that have had an AMI or a CABG, we believe
that there is a need for improved long-term care management and care
coordination for beneficiaries that have had an AMI or a CABG and that
incentivizing the use of CR/ICR services is an important component of
meeting this need. We want to reduce barriers to high-value care by
testing a financial incentive for hospitals that encourages the
management of beneficiaries that have had an AMI or a CABG in ways that
may contribute to long-term improvements in quality and reductions in
Medicare spending.
We sought public comment on the proposals contained in the proposed
rule (81 FR 50794) published on August 2, 2016, and also on any
alternatives considered. Public comment and our responses to those
comments follow under the applicable sections. The applicable sections
contain our proposed policy changes, commenters' reactions, and our
responses.
We received approximately 175 timely pieces of correspondence
containing multiple comments on the EPM proposed rule. We note that
some of these public comments were outside of the scope of the proposed
rule. These out-of-scope public comments are mentioned in this section
but are not addressed with the policy responses in this final rule. The
following is a summary of the comments received on the proposed model
as a whole, including the authority for the model and general comments
on CMS' implementation of the EPM model at this time and our responses.
Comment: Some commenters expressed support for the proposed EPMs
and for requiring participation from specific hospitals in the selected
geographic regions. Other commenters requested whether CMS has the
authority under section 1115A of the Social Security Act (the Act) to
implement the EPMs as proposed, while others stated specifically that
they believe CMS cannot compel provider participation and further
stated that they did not believe Congress intended to delegate its
authority to make permanent changes to the Medicare program to the
Secretary through the Innovation Center.
Many commenters raised concerns that interpreting section 1115A to
mean that requiring participation in models is permissible under
statute holds significant implications for the patients and providers
included in the proposed EPMs, as required models could negatively
impact the Medicare Shared Savings Program (Shared Savings Program)
and/or Accountable Care Organizations (ACOs).
Response: While we appreciate the support expressed by some
commenters, we disagree with the contention that the Innovation Center
lacks the authority to test models under section 1115A of the Act in
which participation is required. Section 1115A of the Act authorizes
the Secretary to test innovative payment and service delivery models to
reduce program expenditures while preserving or enhancing the quality
of care furnished to Medicare, Medicaid, and Children's Health
Insurance Program (CHIP) beneficiaries, and section 1115A of the Act
does not specify that participation in models must be voluntary. As
discussed in section IV. of this final rule, one of the reasons that we
have determined it is necessary to test the EPM models by requiring the
participation of certain hospitals is to obtain more generalizable
evaluation results.
Moreover, the Secretary has authority to establish regulations to
carry out the administration of Medicare. Specifically, the Secretary
has authority under both sections 1102 and 1871 of the Act to implement
regulations as necessary to administer Medicare, including testing
these Medicare payment and service delivery models. We note that the
EPMs will test different methods for delivering and paying for services
covered under the Medicare program, which the Secretary has clear legal
authority to regulate.
To be clear, we did not propose, and are not finalizing, permanent
changes to Medicare, but rather are testing payment and service
delivery models under section 1115A(b) of the Act. While the EPMs
require the participation of certain participant hospitals, the EPMs
are not permanent changes to the Medicare program. We acknowledge the
importance of examining the impact of the EPMs as this test will
implement models at the geographic regional level. The EPMs are thus
intended to enable CMS to test and evaluate the effects of episode
payment approaches on a broader range of Medicare providers and
suppliers than would choose to participate in an alternative payment
model. More specifically, the evaluation is to conduct a multifaceted
and multi-pronged examination of issues of quality, access, and
consequences. Randomized evaluation designs of this kind helps to
reduce the systematic differences among hospitals that are and are not
participating in the EPMs, which helps to ensure that, on average,
differences in outcomes between participating and non-participating
hospitals reflect the impact of the model. Testing these models in this
manner also allows us to learn more about patterns of inefficient
utilization of health care services and how to incentivize the
improvement of quality for AMI, CABG, and SHFFT procedure/diagnosis
episodes. This learning can potentially inform future Medicare payment
policy.
We do not believe the EPMs will harm the continuation of a
permanent Medicare program such as the Shared Savings Program, We
continue to believe that while we test the EPMs, ACOs will still work
towards the goals of the Shared Savings Program. These goals have been
previously described (76 FR 67801) and include ensuring the
coordination of care for beneficiaries, regardless of the time or place
of that care, being innovative in service delivery by drawing upon the
best, most advanced models of care, and using modern technologies,
including telehealth and electronic health records, and other tools to
continually reinvent care in the modern age.
We refer to our discussion about ACO overlap with the proposed EPMs
that was included in the proposed rule (81 FR 50870) and acknowledge
the concerns expressed by some ACOs that the current CJR and BPCI ACO
overlap
[[Page 187]]
policies deprive them of a key source of savings. Because ACOs in
certain types of two-sided risk arrangements have stronger incentives
than those in one-sided risk arrangements to reduce total cost of care,
especially given the possibility of paying CMS shared losses, we
believe that ACOs in such two-sided risk arrangements may be best
positioned to assume the risk associated with EPM episodes, while ACOs
in one-sided risk arrangements may be less well-positioned to do so.
Furthermore, it is more operationally feasible to identify and exclude
beneficiaries who are prospectively aligned to ACOs.
Comment: One commenter believed that the EPMs did not satisfy the
requirement that the model address ``a defined population for which
there are deficits in care leading to poor clinical outcomes or
potentially avoidable costs'' as is required by section 1115A(b)(2)(A)
of the Act.
Response: Models tested under section 1115A of the Act must address
a defined population for which there are either deficits in care
leading to poor clinical outcomes or potentially avoidable
expenditures. As discussed in section III.C. of the proposed rule (81
FR 50829-50843) and section III.C. of this final rule, these models
satisfy the requirements of section 1115A(b) of the Act, as the EPMs
address defined populations (FFS Medicare beneficiaries experiencing
acute myocardial infarctions, coronary artery bypass grafting
procedures and/or surgical hip/femur fracture treatment) for which
there are potentially avoidable expenditure because there are no strong
incentives for coordinated care, which can lead to suboptimal care. As
discussed in section IV. of this final rule, one of the reasons that we
have determined it is necessary to require the participation of
hospitals in multiple geographic areas that might not otherwise
participate in testing episode payment for the episodes of care is to
provide more generalizable evaluation results of the impacts of these
models.
Comment: A few commenters asserted that the SHFFT model is
equivalent to an expansion of the CJR model under section 1115A(c) of
the Act. The same commenters stated that the SHFFT EPM model test
should not be finalized in this rule as the CJR model has not yet
satisfied the requirements of section 1115A(c) of the Act. One
commenter stated that before implementing the SHFFT EPM, CMS must first
complete the evaluation of the CJR model required under section
1115A(b)(4) of the Act; make the determinations required under section
1115A(c)(1) and (3) of the Act; and receive the certification from the
Chief Actuary required under section 1115A(c)(2) of the Act.
Response: Regarding the commenters' assertion that the proposed
SHFFT model expands the CJR model prior to the CJR evaluation, we note
that this is not the case. We agree that section 1115A of the Act
establishes the necessary criteria for the Secretary to expand payment
and service delivery models. However, the SHFFT model we are finalizing
in this rule is not an expansion of the CJR model under section
1115A(c) of the Act. Rather, the SHFFT EPM model is a new model test
under section 1115A(b) of the Act. The CJR model is still at the
initial model test stage, and we will not make any determinations about
continuing the CJR model test through expansion under section 1115A(c)
of the Act until there is sufficient information from evaluation(s) to
assess its potential for expansion. While the SHFFT EPM model test
complements the CJR model test, it is a separate and distinct model
test. Specifically, the SHFFT model differs from the CJR model in that
the CJR model is largely for planned admissions for hip and knee
replacements and the episode of care begins with an admission to a
participant hospital of a beneficiary who is ultimately discharged
under MS-DRG 469 (Major joint replacement or reattachment of lower
extremity with major complications or comorbidities) or 470 (Major
joint replacement or reattachment of lower extremity without major
complications or comorbidities). In contrast, the SHFFT model tests a
hospital payment for hip fixation and the episode of care eventually
results from a discharge paid under MS-DRG 480 (Hip and femur
procedures except major joint with major complication or comorbidity--
CC), MS-DRG 481 (Hip and femur procedures except major joint with
complication or comorbidity--MCC), or MS-DRG 482 (Hip and femur
procedures except major joint without CC or MCC). Therefore, the
interventions under each model test would not overlap. Further, the
SHFFT model test would give hospitals already participating in the CJR
model different experience in managing care for hip and femur fracture
cases that typically present emergently, rather than the planned,
elective surgery that is most common for lower extremity joint
replacement. Despite this geographic overlap, beneficiaries who
initiate an episode in either the SHFFT or CJR model remain in that
initial model and are precluded from initiating a simultaneous episode
in the CJR or SHFFT models respectively. As a result, the evaluations
of the CJR model and the SHFFT model will assess the effect of discrete
episodes.
Comment: Some commenters expressed support for the intended goals
of the EPMs, and stated they want to contribute to moving our health
care system to a value-based system. However, many commenters disagreed
with the process used by CMS to achieve this goal. Specifically,
commenters stated that CMS moved too fast and too soon in implementing
these models. Furthermore, commenters believe that the breadth and
speed of the CMS models expanded exponentially. Commenters stated that
in situations when multiple initiatives are being implemented
simultaneously, for example Meaningful Use, new conditions of
participation for emergency preparedness, multiple clinical and payment
changes to the existing fee-for-service payment systems, performance
requirements of payment reforms such as the MACRA, and state regulatory
changes to health care, commenters stated that hospitals may have
little time or resources available for thoughtful care redesigns to be
applied to the proposed model. A few commenters noted that the
insurance marketplace in general remains volatile, adding further
complication to the health care landscape, while others believe
generally that CMS is putting the existing initiatives' success at risk
as a result of the proposed pace of implementation of new programs and
models.
Commenters raised concerns that they were unable to submit informed
comments on the proposed rule because they did not have sufficient data
on the CJR model, making it difficult to assess even early experience
with the process of implementation of models that require
participation. Other commenters submitted statements of experience
related to implementation of the CJR model, specifically that
implementation was administratively challenging due to the need to
first develop a process of care redesign and then implement operational
changes related to efficiency as well as specific provisions of the
model, including but not limited to collaboration agreements,
provisions for beneficiary notifications, and data analysis. As a
result of this experience, commenters requested that CMS delay the
implementation time line of the EPMs. The alternative time lines
proposed by commenters varied. A few commenters stated that it would be
unreasonable to implement a new episode payment model before
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evaluation of the outcomes and processes of existing bundled payment
models. Other commenters suggested that CMS generally delay
implementation until the agency can address concerns related to risk
adjustment, minimum volume thresholds, comprehensiveness of payment,
and episode definitions. Commenters believed that launching the
proposed models simultaneously will require an incredible
administrative effort, which may hinder the ability to effectively
direct clinical resources towards best practices for success. To this
end, commenters also suggested alternative proposals, including but not
limited to reconsideration of implementing cardiac EPMs; delay, pilot,
or narrow the scope of the proposed SHFFT model; delay the start date
of the proposed EPMs until no earlier than January 1, 2018; provide
hospitals with at least 12 months of preparation time from the date the
final rule is finalized. Other commenters believed hospitals should not
be subject to downside risk for at least 12 months from the
implementation date of the final rule, and other commenters suggested
that CMS delay the onset of downside risk beyond the first quarter of
performance year 2. Commenters suggested CMS delay implementation to
allow both CMS and EPM participants to prepare to be successful during
testing of the model. Specifically, commenters stated that CMS should
use the delay to establish a dialogue with hospitals to improve the
existing bundled payment experience, perform outcomes studies on
existing models and programs, analyze the existing CJR model to
determine the model's impact to beneficiaries' outcomes and longer term
well-being, and create infrastructure to more easily attribute patients
to the EPMs. Commenters also stated that such a delay would allow time
for EPM participants to better understand the clinical and financial
risk of their patient populations, to establish collaborator
relationships and to create the internal organization structure to
manage payment bundles. A few commenters specifically suggested changes
in payment once the risk-bearing phase begins, to allow a prospective
payment to the EPM participants upon determination of an eligible
diagnosis, as this change could permit all collaborating providers to
share in both the upside and downside financial risk, and not be
constrained by what Medicare pays for services during the episode.
Overall, most commenters requested that CMS generally apply a more
strategic process to achieve the intended goals by building on the
experience to date to set the health care system on a pathway to
success rather than rolling out new models before anything concrete is
gleaned from existing models.
Response: We appreciate the comments we received in support of our
proposed performance period and start date. We also appreciate comments
expressing concerns around the timing of this model. Although we
believe that it is important to initiate these EPMs now since they are
different than CJR and BPCI and will provide essential information
about the potential for episode payment to improve care and lower
spending, we are sensitive to commenters' concerns that our proposed
date to implement downside risk may not provide sufficient time for
participants to implement the kinds of changes needed to successfully
participate in the model, particularly given the availability of
baseline data. Accordingly, this final rule will increase available
preparation time by not implementing downside risk for all participants
in the EPMs until October 1, 2018. Downside risk for EPM episodes will
be applied to episodes ending on or after January 1, 2019. As discussed
in detail in section III.D. of this final rule, participants who are
interested in taking on downside risk earlier can choose to begin
downside risk for episodes ending on or after January 1, 2018.
Additionally, specific amendments to the regulations regarding the CJR
model access to records and records retention policy, compliance
enforcement policy, and waiver of the SNF 3 day rule will take effect
July 1, 2017. We refer readers to sections V.H., V.I., and V.L. of the
final rule for discussions of our final decisions. We believe that
these changes will both facilitate participants' abilities to be
successful under these models and allow for a more gradual transition
to full financial responsibility under the models. CMS will also
continue to work internally to determine the extent to which the
suggestions submitted by commenters, including performing education and
outreach activities or outcomes studies on existing models, will impact
the implementation of the EPMs. The EPMs will only include a limited
number of episode types, and as such we believe it is reasonable for
hospitals to begin to analyze data and identify care patterns and
opportunities for care redesign for these episodes prior to assuming
financial responsibility for spending for episode beginning after
October 1, 2018. We also note that due to the gradual implementation of
financial responsibility that was proposed and that will still be
incorporated in the models even given the start of the phased-in
downside risk that we are finalizing in this rule, we expect that
hospitals will spend the first performance year of the model analyzing
data, identifying care pathways, forming clinical and financial
relationships with other providers and suppliers, and assessing
opportunities for savings under the model, utilizing in part the claims
data we provide to them. As a result of these changes, we do not
believe that further changes are needed to the start date of
implementation. We also do not agree with commenters that
implementation of the model is premature or that it should not be
implemented until results for CJR or other episode-based payment models
are available. While we anticipate that these models will offer
valuable information that should assist CMS in developing future
episode payment models, the EPMs will offer additional insights that
are not available under the CJR model; in particular, insights with
respect to episode payment models on a distinct set of episodes for
participants that would not otherwise participate under a model such as
BPCI.
Likewise, we do not agree that the models should be implemented
after certain other actions have occurred or because of the multiple
competing mandates faced by hospitals and other providers. Since the
Medicare program's inception, providers have and will continue to
contend with constantly evolving statutory and administrative
requirements that often require them to make concurrent changes in
their practices and procedures. We do not believe the EPMs are
dissimilar to those requirements.
Also as discussed earlier in this section, some commenters pointed
to the potential for unintended consequences that could result from our
proposed start date, including impediments to beneficiary access and
reduced quality of care. As discussed in section III.E. of this final
rule, we are including quality measures for purposes of evaluating
hospitals' performance both individually and in aggregate across the
models. Also, as discussed in section III.F. of this final rule, we are
making final policies and actions to monitor both care access and
quality. We believe these features will help ensure that beneficiary
access to high quality care is not compromised under the EPMs.
Comment: Commenters raised specific concerns that the proposed
EPMs' emphasis on cost-savings could incentivize hospitals to use the
least
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costly post-acute alternative rather than the option that is most
appropriate for the beneficiary. Furthermore, commenters stated that
under an episode payment structure, EPM participants that admit
healthier patients would have better financial results. Some commenters
believe this design will consequently impact Medicare beneficiaries and
the Medicare Trust Fund by increasing the frequency of Medicare
payments from participants initiating a higher volume of episodes in a
healthier population of beneficiaries. Other commenters believed that
the proposed regulation would have serious negative impacts on Medicare
beneficiaries by encouraging unnecessary surgeries and on health care
stakeholders by discouraging innovation. One commenter encouraged us to
create a patient advisory panel so that beneficiary viewpoints could be
incorporated into model planning for the EPMs and any other Innovation
Center bundled payment models.
Response: We appreciate the commenters' concerns regarding the
quality of care for Medicare beneficiaries. Improving the quality of
care is a central goal of the Innovation Center's work to test new
payment and service delivery models. We disagree with commenters that
the models will negatively impact the quality of care for beneficiaries
in these models and we refer readers to the monitoring and beneficiary
protections discussion in section III.G. of this final rule which we
believe will address the commenters' concerns about care stinting. We
emphasize that care stinting or denying the provision of medically
necessary care is not permitted under the EPMs. Medicare beneficiaries
in the EPMs will retain the right to obtain health services from any
individual or organization qualified to participate in the Medicare
program, and EPM participants are required to supply beneficiaries with
written information regarding the design and implications of these
models as well as the beneficiaries' rights under Medicare, including
their right to use their providers of choice. We disagree with
commenters that the EPMs will stifle innovation for care furnished
during an EPM episode. We proposed, and are finalizing in this final
rule, a payment methodology that will account for changes in care
patterns and utilization trends for EPM episodes as described in
section III.D. of this final rule and will have a monitoring contractor
actively reviewing claims and monitoring behavior of participant
providers to ensure beneficiary choice and care are not compromised by
the EPMs. The Federal Government has long recognized the important role
of the public in developing effective policies. Advisory committees are
a way of ensuring public and expert involvement and advice in federal
decision-making. In compliance with the Federal Advisory Committee Act
(FACA) the number of advisory committees is carefully managed and
committee memberships reflect a balance of viewpoints, education, and
experience. Although the establishment of a Patient Advisory Committee
for all Innovation Center models is beyond the scope of this rule, we
believe that stakeholder engagement is essential to the success of
these models and our learning and monitoring contractors as well as our
evaluation contractor will be soliciting beneficiary feedback on their
experiences with the EPMs.
Comment: While some commenters appreciated the approach of CMS to
implement episode-based payment models for a select group of clinical
scenarios, others suggested that participation be voluntary, in order
to allow hospitals and providers implementing other payment reforms
like the MACRA a more gradual adoption process of EPMs. An additional
voluntary component to the proposed EPMs, commenters stated, would also
permit additional participants who are interested in the models but not
located in the MSAs in which the models will be tested to volunteer for
participation. Still, other commenters stated that single-episode
initiatives fail to encourage systemic change within organizations, and
may hinder competition if implemented. Commenters stated that as a
result of mandated participation, many surgeons who and facilities
which lack familiarity, experience, or proper infrastructure to support
care redesign efforts will hamper provider participation, bias model
performance evaluation, and negatively affect patient care. One
commenter suggested that the nature of the models will provide
information about how many organizations, and which organizations,
fail. Other commenters commended CMS for the episode payment models.
The commenters believed that this overall strategy will motivate
hospitals to work more closely with other members of the patient's care
team, which could reduce avoidable complications after surgery and
decrease the risk of additional hospitalizations.
Response: We thank the commenters for their feedback, but disagree
with the suggestion to finalize the proposed EPMs as a voluntary
initiative. The EPMs will give CMS the ability to test how an episode
payment model might function among participants that would otherwise
not participate in such a model. As such, we expect the results from
these models will produce data that are more broadly representative
than what might be achieved under a voluntary model. Also, these models
test a regional target pricing approach to consider a participant
hospital's performance relative to its regional peers. As part of this
test, we will learn whether our alternative pricing approach in these
models will better incentivize participants who are already delivering
high quality and efficient care while still incentivizing historically
less efficient providers to improve. We would not be able to test such
a regional pricing approach under a purely voluntary model, nor could
the appropriate evaluation approach be implemented if participants
could volunteer, because it is likely that only the already high
quality and efficient providers would sign up.
Comment: Many commenters supported our use of notice and comment
rulemaking for the EPMs and encouraged us to continue to use the notice
and comment rulemaking process to facilitate a robust public dialogue
on important issues related to the EPMs and the CR incentive payment
model. These commenters generally agreed with the proposed EPM
episodes. A few commenters were concerned that we would avoid notice
and comment rulemaking requirements.
Response: We appreciate the commenters' support for the use of
notice and comment rule-making for the EPM models. The EPMs are
intended to enable CMS to better understand the effects of payment
models on a broader range of Medicare providers than what is currently
being tested under the BPCI initiative. To this end, testing the EPMs
in the proposed manner will also allow us to learn more about patterns
of inefficient utilization of health care services and how to
incentivize improvement in quality for common AMI episodes.
We respectfully disagree that we are avoiding notice and comment
rulemaking. We note that the proposed rule (81 FR 50794), promulgated
in accordance with the requirements of 5 U.S.C. 553, went into great
detail about the provisions of the proposed EPMs, enabling the public
to fully understand and comment on how the proposed models were
designed and could apply to those affected providers and beneficiaries.
In this final rule, which is also being promulgated in accordance with
the requirements of 5 U.S.C. 553,
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we respond to the public comments received on our proposals, and after
considering them, we are finalizing our proposals with some
modifications.
Comment: Commenters questioned the extent to which EPM participants
would have the knowledge, skills, and experience to successfully drive
improvements in care delivery and health outcomes. Many commenters
asserted they do not have enough experience to even know where the
efficiencies in care delivery are available to take advantage of them,
which limits the ability of the EPMs' potential success. Another
commenter recommended CMS inform the participants that will be in these
episode payment models as early as possible. To this end, many
commenters recommended that CMS implement a broad-based education
campaign regarding the new EPMs that uses all of CMS' communication
channels to reach hospitals, post-acute care providers, physicians, and
community-based providers of long term services and supports.
There were many unique suggestions by commenters to appropriately
communicate the proposed EPMs to affected stakeholders. A few
commenters were generally uncertain where CMS could articulate its
vision for innovative payment models. A few other commenters believed
CMS should explain in detail the applicable EPMs, provide contact
information and a publicly accessible list of all the providers that
are part of the model in each region. Other commenters requested more
opportunity to analyze the lessons learned from Health Care Payment
Learning and Action Network (HCP-LAN), Clinical Episode Payment (CEP)
work group, and BPCI so they can be broadly applied to care redesigns
as part of the proposed EPMs. To support learning efforts, some
commenters recommended CMS to include in final regulations a
requirement that participating hospitals must develop, have approved by
CMS, and implement a comprehensive, effective clinical care model and
leadership structure for coordinating care and managing implementation
of the EPMs. A few suggested that CMS assign a Medicare Project Officer
to assist CJR and EPM participants. One commenter suggested that CMS
provide advanced education and clinical-financial tools attainable
through a blend of registries, databases and CMS claims data. Other
commenters supported the intention of CMS to establish a learning and
diffusion program.
Response: We agree with commenters regarding the need to
continually improve stakeholder outreach for models to succeed and we
intend to do as much as we can to work to design and deploy a helpful
learning and diffusion program. CMS is committed to continuing to
facilitate performance improvement by identifying areas of excellence
for the purposes of extrapolating best practices. CMS encourages
collaboration amongst organizations and can provide guidance on the
development and implementation of specific learning systems. We
currently deploy the expertise and experience of The Innovation
Center's Learning and Diffusion Group to facilitate learning within
models by disseminating the lessons learned across models so that
participants can benefit from the experiences of other models, and are
always looking for better ways to educate and assist participants in
knowledge sharing. For example, BPCI includes a shared learning network
that brings experienced stakeholders together for knowledge sharing,
collaboration, and peer-to-peer learning. We continue to believe that
these efforts contribute to reducing the administrative burden on the
health care delivery system and will be responsive to commenters'
concerns.
Comment: One commenter stated that they believe CMS should engage
in models which enhance sharing of best practices rather than financial
incentives.
Response: We appreciate the commenter's submission and agree with
the sentiment that providers of care in the EPMs should ensure quality
of care is maintained or improved. The design of the episode-based
payments directly corresponds with CMS' stated goal of decreasing costs
while maintaining or improving quality. Within this framework, we
anticipate best practices naturally evolving as participants explore
care redesign to achieve efficiencies in the episode.
Comment: Many commenters applauded many of the design features in
the new proposed models--suggesting that the proposed rule outlined the
framework for models that could become very successful at reducing
Medicare spending and improving patient care. One commenter suggested
that CMS develop accreditation standards for participation and only
select accredited EPM participants. Another commenter suggested
considering Quality Improvement Organizations (QIOs) as participants,
or that QIOs be more centrally involved in such models to continue to
recognize the importance of care transitions.
Response: We thank commenters for their support of the proposed
design features in the new proposed models. The QIO Care Transitions
Project \7\ previously tested the extent to which QIOs lead
improvements in care transitions. Research found reduced rates of 30-
day re-hospitalization and all-cause hospitalization per 1,000, however
the reduced rate of all-cause 30-day re-hospitalization as a percentage
of hospital discharges was not statistically significant. We will
continue to work internally to evaluate the extent to which QIOs
complement the operations of the EPMs. We disagree with the suggestion
to develop accreditation standards, as such actions are distinct from
testing of EPMs, and the proposal to define EPM episode initiators as
only those accredited EPM participants. The definition of the episode
initiator is discussed further in section III.B of this final rule.
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\7\ Brock J, et al., Association between quality improvement for
care transitions in communities and rehospitalizations among
Medicare beneficiaries. JAMA. 2013 Jan 23;309(4):381-91.
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As discussed in more detail in section V. of this final rule, we
proposed numerous modifications to the CJR model, which began on April
1, 2016. Section V. of this final rule contains our proposed policy
changes, commenters' reactions, and our responses. We discuss here
comments we received on the CJR model as a whole, including several
comments pertaining to model policies for which we did not propose any
changes, as well as our responses.
Comment: In general, commenters expressed support for the CJR
model. One commenter suggested that CMS extend the model on a voluntary
basis after the conclusion of the model's 5 performance years, to allow
for successful participants to continue under CJR. The commenter also
suggested that in such a scenario, CMS allow for convening
organizations to participate (as is the case currently under the BPCI
initiative) and modify the model design to include features such as
financial risk for the post-acute care period only. The commenter noted
that such flexibility would encourage participation in alternative
payment models.
Another commenter expressed support for the CJR model but noted the
significant time and effort required for hospitals to implement the
model. Commenters also requested several policy changes out of scope
for this rulemaking, including: Additional relaxation of regulatory
barriers to integration between hospitals and other stakeholders,
removal of fractures in
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their entirety from this episode payment model, additional waivers of
Medicare program rules, additional quality measures, policies that
would encourage use of specific medical devices associated with lower
revision rates, and modifications to the pricing methodology that would
include comprehensive risk adjustment. Finally, one commenter requested
that data be provided on a more frequent basis.
Response: We thank the commenters for their support of the CJR
model. With regard to the CJR model policies for which we did not
propose any changes, we will continue to consider the issues commenters
brought forward and if warranted, would address any changes through
future rulemaking as necessary. In addition, we note that while
currently we provide CJR hospitals with episode data on a quarterly
basis, we may begin to consider providing such data on a monthly basis
when practicable.
Comment: A few commenters supported CMS' pursuit of opportunities
to spread value-based payment to more providers through additional
episode payment models beyond lower extremity joint replacement.
Response: We acknowledge and appreciate the commenters' remarks.
Comment: A few commenters addressed issues on the following
subject-matter areas: Alternative administration of medications, non-
medically directed anesthesia delivery, remote patient monitoring, data
collection for global surgical services, and the long term care
hospital certification program.
Response: These comments pertain to issues for which we did not
include any proposals in the proposed rule. Therefore, we believe these
comments are outside the scope of the proposed rule, and we are not
addressing them in this final rule. After carefully considering all of
the comments we received on the proposed model, including those
discussed previously and within the following pages, for the reasons
described elsewhere in this rule, we have concluded that we can
successfully test the Episode Payment Models with several modifications
and timing changes. The final model design we are implementing includes
additional lead time for participants prior to the onset of downside
risk to ensure that the models have time to incorporate risk adjustment
into pricing, a commitment to conduct public listening sessions on risk
adjustment during the 2017 calendar year and rulemaking during the 2018
calendar year on risk adjustment methods, an exemption for the Medicare
Shared Savings Program Track 3 ACOs from participation in the EPMs and
adjustments to the AMI transfer policy and the CABG quality measures.
All of these changes are discussed in detail in this final rule.
B. Summary of the Major Provisions
1. Model Overview--EPM Episodes of Care
The EPMs, as described further in section III.B.2. of this final
rule, are an AMI, CABG, or SHFFT model episode that will begin with an
inpatient admission to an anchor hospital assigned to one of the
following MS-DRGs upon beneficiary discharge. Acute care hospital
services furnished to beneficiaries in AMI, CABG, and SHFFT episodes
currently are paid under the Inpatient Prospective Payment System
(IPPS) through several Medicare Severity-Diagnosis Related Groups (MS-
DRGs): For AMI episodes, AMI MS-DRGs (280-282) and those Percutaneous
Coronary Intervention (PCI) MS-DRGs (246-251) representing IPPS
admissions for AMI that are treated with PCIs; CABG MS-DRGs (231-236);
and SHFFT MS-DRGs (480-482). Episodes will end 90 days after the date
of discharge from the anchor hospital, as defined under Sec. 512.2.
Defining EPMs' episodes of care in such a manner offers operational
simplicity for both providers and CMS. The EPMs' episodes will include
the inpatient stays and all related care covered under Medicare Parts A
and B within the 90 days after discharge, including hospital care,
post-acute care, and physician services.
2. Model Scope
Consistent with the CJR model, we proposed that acute care
hospitals would be the episode initiators and bear financial risk under
the proposed AMI, CABG and SHFFT models. In comparison to other health
care facilities, hospitals are more likely to have resources that would
allow them to appropriately coordinate and manage care throughout an
episode, and hospital staff members already are involved in hospital-
discharge planning and post-acute care recommendations for recovery,
key dimensions of high-quality and efficient care. We proposed to
require all hospitals to participate that are paid under the IPPS, have
a CMS Certification Number (CCN), and have an address located in
selected geographic areas to participate in the EPMs, with limited
exceptions. An eligible beneficiary who receives care at such a
hospital will automatically be included in the applicable EPM. We
proposed to select geographic areas through a random sampling
methodology.
For the CR incentive payment model, we proposed to provide a CR
incentive payment specifically to selected hospitals with financial
responsibility for AMI or CABG model episodes (hereinafter EPM-CR
participants) because they are already engaged in managing the AMI or
CABG model beneficiary's overall care for a period of time following
hospital discharge. Similarly, we believe there are opportunities to
test the same financial incentives for hospitals where the
beneficiary's overall care is paid under the Medicare FFS program.
Thus, we also proposed to provide a CR incentive payment specifically
to selected hospitals that are not AMI or CABG model participants
(hereinafter FFS-CR participants).
Our geographic-area selection process is detailed further in
section III.B.4. of this final rule.
3. Payment
We will test the AMI, CABG, and SHFFT EPMs for 5 performance years.
The first performance year would begin July 1, 2017. During these
performance years we will continue paying hospitals and other providers
and suppliers according to the appropriate Medicare FFS payment
systems. However, after the completion of a performance year, the
Medicare claims payments for services furnished to an eligible
beneficiary during an episode, based on claims data, will be combined
to calculate an actual episode payment. The actual episode payment will
then be reconciled against an established EPM quality adjusted target
price. The amount of this calculation, if positive, will be paid to the
EPM participant as a ``reconciliation payment'' provided they had
achieved a quality category of ``acceptable'' or higher. If the amount
of this calculation is negative, we will require a ``Medicare
repayment'' from the participant hospital beginning with episodes
ending in performance year 3 of the EPMs. We had proposed to phase in
the requirement that participants whose actual episode payments exceed
the quality adjusted target price pay the difference back to Medicare
beginning in the second quarter of performance year 2, and under this
proposal, CMS would not require a Medicare repayment from hospitals for
actual episode payments that exceed their target price in performance
year 1 and the first quarter of performance year 2. Our final rule
implements the requirement for Medicare repayments during performance
year 3 and includes
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an applicable discount factor that would be used for calculating
repayment amounts for performance years 3 and 4. Also, participants may
elect to assume downside risk for performance year 2, which would also
include an applicable discount factor for calculating repayment
amounts.
In contrast to the CJR model, due to the clinical characteristics
and common patterns of care in AMI episodes, we proposed payment
adjustments in the cases of certain transfers and readmissions of
beneficiaries to inpatient hospitals for these episodes. These payment
adjustments are discussed in detail in sections III.D.4.b.(1). through
III.D.4.b.(2).(a). of the proposed and this final rule. We did not
finalize one of these proposals--a payment adjustment for AMI episodes
involving an inpatient-to-inpatient transfer or what we referred to as
a chained anchor hospitalization. We also proposed payment adjustments
for CABG model episodes, which we are finalizing in this rule. We
proposed and are making final with modification limits on how much a
hospital can gain or lose based on its actual episode payments relative
to quality adjusted target prices, including policies to further limit
the risk of high payment cases for special categories of participants
as described in sections III.D.7.a. through III.D.7.d. of this final
rule. In response to comments, we are finalizing a policy to extend
separate financial loss protections to participants with a low volume
of episodes under a model, which we refer to as EPM volume protection
hospitals.
In addition to the EPMs, we proposed to test a CR incentive payment
model (81 FR 50800) to encourage the utilization of CR/ICR services for
beneficiaries hospitalized for treatment of AMI or CABG. To determine
the CR incentive payment, we proposed to count the number of CR/ICR
services for the relevant time periods under the Outpatient Prospective
Payment System (OPPS) and PFS on the basis of the presence of paid
claims of the HCPCS codes that report CR/ICR services and the units of
service billed. The initial level of the per service CR incentive
amount would be $25 per CR/ICR service for each of the first 11 CR/ICR
services paid for by Medicare during an AMI or CABG model episode or
AMI or CABG care period. After 11 CR/ICR services are paid for by
Medicare for a beneficiary, the level of the per service CR incentive
amount will increase to $175 per CR/ICR service for each additional CR/
ICR service paid for by Medicare during the AMI or CABG model episode
or AMI care period or CABG care period. A more detailed discussion of
the CR incentive payment is located in section VI.E.1 of this final
rule. The CR performance years would be the same as the performance
years for the EPMs in section III.D.2.a. of this final rule. Further
details about the payment structure and design of the CR incentive
payment model can be found in section VI. of this final rule.
4. Similar, Previous, and Concurrent Models
The EPMs are informed by other models and demonstrations currently
and previously conducted by CMS, and will explore additional ways to
use episode payment to enhance coordination of care and improve the
quality of care.
We recently announced practices that will participate in the
Oncology Care Model (OCM), an episode payment model for physician
practices administering chemotherapy. Under OCM, practices will enter
into payment arrangements that include both financial and performance
accountability for episodes of care surrounding chemotherapy
administration to cancer patients. We will coordinate with other payers
to align with OCM in order to facilitate enhanced services and care at
participating practices.\8\
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\8\ More information on the OCM can be found on the Innovation
Center's Web site at https://innovation.cms.gov/initiatives/Oncology-Care/.
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The Innovation Center previously tested innovative episode payment
approaches in the Medicare Acute Care Episode (ACE) demonstration,\9\
and, as described in this final rule, currently is testing additional
approaches under the BPCI initiative and the CJR model. The ACE
demonstration tested an alternative payment approach for cardiac and
orthopedic inpatient surgical services and procedures. All Medicare
Part A and Part B services pertaining to the inpatient stay were
included in the ACE demonstration episodes of care. Evaluations of the
ACE demonstration found that while there was not strong quantitative
evidence indicating improvements in quality, there was qualitative
evidence that hospitals worked to improve processes and outcomes as a
result of their participation in the demonstration.
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\9\ Information on the ACE Demonstration can be found on the
Innovation Center's Web site at https://innovation.cms.gov/initiatives/ACE/.
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Currently, we are testing the BPCI initiative, which is composed of
related payment models that link payments for multiple services that a
Medicare beneficiary receives during an episode of care into a bundled
payment. Under the initiative, entities enter into payment arrangements
with CMS that include financial and performance accountability for
episodes of care. Episodes of care under the BPCI initiative begin with
either: (1) An inpatient hospital stay or (2) post-acute care services
following a qualifying inpatient hospital stay. The BPCI initiative is
evaluating the effects of episode-based payment approaches on patient
experience of care, outcomes, and cost of care for Medicare FFS
beneficiaries. Participating organizations chose from 48 clinical
episodes, including hip and femur procedures except major joint, acute
myocardial infarction, percutaneous coronary intervention, and coronary
artery bypass graft surgery. BPCI Model 2 is an episode payment model
in which a qualifying acute care hospitalization initiates a 30-, 60-,
or 90-day episode of care. The episode includes the inpatient stay in
an acute care hospital and all related services covered under Medicare
Parts A and B during the episode, including post-acute care
services.\10\ Our experience testing BPCI Model 2 informed the design
of the three proposed EPMs. Although some interim evaluation results
from the BPCI models are available, final evaluation results for the
models within the BPCI initiative are not yet available. However, we
believe that CMS' experiences with BPCI support the design of the
proposed EPMs. Stakeholders both directly and indirectly involved in
testing BPCI models have conveyed that they perceive the initiative to
be an effective mechanism for advancing better, more accountable care
and aligning providers along the care continuum. This message has been
reinforced through CMS site visits to participating entities, the
Bundled Payments summit in Washington, in-person meetings with Awardees
at CMS, and Awardee-led Affinity Group discussions. The BPCI initiative
incorporates 48 clinical episodes, including cardiac and orthopedic
episodes similar to the AMI, CABG, and SHFFT models. These clinical
episodes are being tested by over 1,200 Medicare providers, including
acute care hospitals, physician group practices, skilled nursing
facilities, and home health agencies. Cardiac and orthopedic clinical
episodes are among the most popular episodes in BPCI, indicating that
BPCI awardees participating in BPCI believe they can reduce cost and
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improve quality for beneficiaries in these episodes of care.
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\10\ More information on BPCI Model 2 can be found on the
Innovation Center's Web site at https://innovation.cms.gov/initiatives/BPCI-Model-2/.
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Our design and implementation of the CJR model, which is an episode
payment model for LEJR episodes, also informed the design of the AMI,
CABG, and SHFFT EPMs. After releasing a proposed rule in July 2015 and
receiving nearly 400 comments from the public, in November 2015 we
released final regulations implementing the CJR model. Approximately
800 acute care hospitals (approximately 23 percent of all IPPS
hospitals) now participate in the CJR model. The first CJR performance
year began on April 1, 2016. The CJR model will continue for 5
performance years, ending on December 31, 2020. The AMI, CABG, and
SHFFT models build upon our experience designing and implementing the
CJR model, including feedback from providers and other public
stakeholders during the CJR model's rulemaking and implementation
processes.
Further information on why specific elements of the models and
initiatives were incorporated into the EPMs' designs is discussed later
in this final rule.
5. Overlap With Ongoing CMS Efforts
We proposed to exclude from participation in the AMI, CABG, and
SHFFT models certain acute care hospitals participating in BPCI Models
2 and 4 for the hip and femur procedures except major joint or for all
three of the BPCI cardiac episodes (AMI, PCI, and CABG). We proposed to
exclude from EPMs beneficiaries prospectively aligned to Innovation
Center ACO models which had downside financial risk such as the Next
Generation ACO and the Comprehensive ESRD Care models. We also sought
comment regarding whether this exclusion should be extended to include
beneficiaries assigned to Track 3 Shared Savings Program ACOs as these
ACOs also have prospective assignment and downside financial risk. As
discussed in the proposed rule, other CMS programs, such as the Shared
Savings Program (Tracks 1 and 2) and other accountable care
organization (ACO) or total cost of care initiatives will remain
eligible for EPM episode initiation. We proposed to account for
overlap, that is, where EPM beneficiaries also are included in other
models and programs to ensure the financial policies of the models are
maintained and results and spending reductions are attributed to one
model or program. Specifically, as with CJR, we have proposed to give
precedence to existing BPCI models when a beneficiary is admitted to an
acute care hospital for what would otherwise be a covered EPM episode
but that acute care hospital or the treating physician is participating
in BPCI and the admission would meet the criteria to be covered under
BPCI. In addition, as with CJR, an EPM episode will be cancelled if a
beneficiary whose hospitalization initiates an EPM episode receives
treatment during the post discharge period that would also result in
the episode being covered under BPCI. Based on the comments received,
we are finalizing these proposals with the modification that we will
exclude from EPMs not only those beneficiaries prospectively assigned
to the Next Generation ACO and the Comprehensive ESRD Care models which
also share in downside risk with CMS, but also those beneficiaries
prospectively assigned to Track 3 Shared Savings Program ACOs. More
detail on our policies for accounting for provider- and beneficiary-
level overlap is discussed in section III.D.6. of this final rule.
The amendments made by the Medicare Access and CHIP Reauthorization
Act of 2015 (MACRA) (Pub. L. 114-10, April 16, 2015) created two paths
for eligible clinicians to link quality to payments: The Merit-Based
Incentive Payment System (MIPS) and Advanced Alternative Payment Models
(APMs). These two paths create a flexible payment system called the
Quality Payment Program as finalized by CMS in the Quality Payment
Program final rule with comment period (81 FR 77008 through 77831). The
MIPS streamlines and improves on three current programs--the Physician
Quality Reporting System (PQRS), the Physician Value-based Payment
Modifier (VM), and the Medicare Electronic Health Record (EHR)
Incentive Program--and continues the focus on quality and value in one
cohesive program. Through sufficient participation in Advanced APMs,
eligible clinicians can become Qualifying APM Participants (QPs) for a
payment year beginning with CY 2019 and potentially receive an APM
Incentive Payment (or, in later years, a more favorable payment update
under the PFS) for the year.
So that the EPMs may be able to meet the criteria to be Advanced
APMs based on the requirements in the Quality Payment Program final
rule with comment period, we proposed to require EPM participants to
use Certified Electronic Health Record Technology (CEHRT) (as defined
in section 1848(o)(4) of the Act) in Track 1 of each EPM. We proposed
that EPM participants in these tracks must use certified health
information technology (IT) functions, in accordance with the
definition of CEHRT under our regulation at 42 CFR 414.1305, to
document and communicate clinical care with patients and other health
care professionals as described in the Quality Payment Program final
rule with comment period. We also made similar proposals with respect
to CJR.
We proposed to implement two different tracks within the EPMs
whereby EPM participants that meet requirements for use of CEHRT and
financial risk would be in Track 1 (an Advanced APM track) and EPM
participants that do not meet these requirements would be in Track 2 (a
non-Advanced APM track). The different tracks would not change how EPM
participants operate within the EPM itself, beyond the requirements
associated with selecting to meet CEHRT use requirements. The only
distinction between the two tracks is that only Track 1 EPMs could be
considered an Advanced APM for purposes of the Quality Payment Program
based on the criteria in the Quality Payment Program final rule with
comment period. We made similar proposals with respect to CJR. We
considered modifying requirements proposed in this rule as necessary to
reconcile them with policies adopted in the Quality Payment Program
final rule. A more detailed discussion of how EPMs and CJR could
qualify as Advanced APMs, and how eligible clinicians participating in
the EPMs and CJR will be identified and affected, can be found in
sections III.A.2 and V.O. of this final rule.
Comment: One commenter suggested that the most relevant definition
of CEHRT to the EPM is found at Sec. 495.4.
Response: The definition at 42 FR 495.4 relates to Medicaid
eligible professionals, eligible hospitals, and CAHs, as defined for
the EHR Incentive Programs. The definition at 45 FR 414.1305 relates to
Medicare eligible clinicians and groups participating as defined for
the CMS Quality Payment Program. These two definitions are
substantively the same; however, we refer readers to the definition at
42 FR 495.4 as this most closely relates to the eligibility status of
EPM participants. We have updated and finalized this technical
correction.
6. Quality Measures and Reporting Requirements
Similar to the quality measures selected for the CJR model, we
proposed to use established measures used in other CMS quality-
reporting programs for the proposed EPMs' episodes. We proposed to use
these measures to test
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EPMs' success in achieving its goals under section 1115A of the Act and
to monitor for beneficiary safety. For the SHFFT model, we proposed
applying the same quality measures selected for the CJR model.
The quality measures for SHFFT episodes are as follows:
THA/TKA Complications: Hospital-Level Risk-Standardized
Complication Rate (RSCR) Following Elective Primary Total Hip
Arthroplasty (THA) and/or Total Knee Arthroplasty (TKA) (National
Quality Forum [NQF] #1550).
Hospital Consumer Assessment of Healthcare Providers and
Systems (HCAPHS) Survey (NQF #0166).
Successful Voluntary Reporting of Patient-Reported
Outcomes.
The measures for the AMI model are as follows:
MORT-30-AMI: Hospital 30-Day, All-Cause, Risk-Standardized
Mortality Rate (RSMR) Following Acute Myocardial Infarction (AMI)
Hospitalization (NQF #0230).
AMI Excess Days: Excess Days in Acute Care after
Hospitalization for Acute Myocardial Infarction (acute care days
include emergency department, observation, and inpatient readmission
days).
HCAPHS Survey (NQF #0166), linear mean roll-up (HLMR)
scores like CJR.
The measures for the CABG model are as follows:
MORT-30-CABG: Hospital 30-Day, All-Cause, Risk-
Standardized Mortality Rate (RSMR) Following Coronary Artery Bypass
Graft Surgery (NQF #2558).
HCAPHS Survey (NQF #0166), HLMR scores like CJR.
We proposed and requested public feedback on options for including
successful implementation testing of the Hybrid AMI measure as a
quality measure for the AMI episode. The Hybrid AMI measure will assess
a hospital's 30-day risk-standardized acute myocardial infarction
mortality rate and will incorporate a combination of claims data and
EHR data submitted by hospitals. Public comment and our responses to
those comments follow under the applicable sections in section III. of
this final rule.
We are finalizing as proposed the following quality measures for
SHFFT episodes:
THA/TKA Complications: Hospital-Level Risk-Standardized
Complication Rate (RSCR) Following Elective Primary Total Hip
Arthroplasty (THA) and/or Total Knee Arthroplasty (TKA) (National
Quality Forum [NQF] #1550).
Hospital Consumer Assessment of Healthcare Providers and
Systems (HCAPHS) Survey (NQF #0166).
Successful Voluntary Reporting of Patient-Reported
Outcomes.
We are finalizing as proposed the following measures for the AMI
model:
MORT-30-AMI: Hospital 30-Day, All-Cause, Risk-Standardized
Mortality Rate (RSMR) Following Acute Myocardial Infarction (AMI)
Hospitalization (NQF #0230).
AMI Excess Days: Excess Days in Acute Care after
Hospitalization for Acute Myocardial Infarction (acute care days
include emergency department, observation, and inpatient readmission
days).
HCAPHS Survey (NQF #0166), linear mean roll-up (HLMR)
scores like CJR.
We are finalizing as proposed the following measures for the CABG
model:
MORT-30-CABG: Hospital 30-Day, All-Cause, Risk-
Standardized Mortality Rate (RSMR) Following Coronary Artery Bypass
Graft Surgery (NQF #2558).
HCAPHS Survey (NQF #0166), HLMR scores like CJR.
In addition, after consideration of comments received, we are
finalizing an additional measure for the CABG model. Successful
voluntary reporting of the Society of Thoracic Surgeons (STS) CABG
composite score (NQF #0696) is a comprehensive NQF-endorsed composite
measure and will be weighted at 10 percent of the composite quality
score for those hospitals that report this voluntary measure.
Additionally, similar to the CJR model, we proposed to adopt a pay-
for-performance methodology for EPMs that relies upon a composite
quality score to assign respective EPM participants to four quality
categories. These quality categories will determine an EPM
participant's eligibility for a reconciliation payment should such EPM
participant achieve spending below the quality-adjusted target price,
as well as the effective discount percentage at reconciliation. Points
for quality performance and improvement (as applicable) will be awarded
for each episode measure and then summed to develop a composite quality
score that will determine the EPM participant's quality category for
the episode. Quality performance will make up the majority of available
points in the composite quality score, with improvement points
available as ``bonus'' points for the measure. This approach resembles
the CJR model methodology.
7. Beneficiary Protections
As with the CJR model, Medicare beneficiaries in the EPM models
will retain the right to obtain health services from any individual or
organization qualified to participate in the Medicare program. Eligible
beneficiaries who receive services from EPM participants would not have
the option to opt out of inclusion in the applicable model. We proposed
to require EPM participants to supply beneficiaries with written
information regarding the design and implications of these models as
well as the beneficiaries' rights under Medicare, including their right
to use their providers of choice. We will make a robust effort to reach
out to beneficiaries and their advocates to help them understand the
models. We also proposed to use our existing authority, if necessary,
to audit participant hospitals if claims analysis indicates an
inappropriate change in furnished services. Beneficiary protections are
discussed in greater depth in section III.G. of this final rule.
8. Financial Arrangements
We proposed a regulatory structure for financial relationships
under the EPM to advance the goals of improving the quality and
efficiency of model episodes, which also included program integrity
safeguards to protect against abuse under the financial relationships
permitted for the EPM. Our EPM proposals reflected changes from the
current CJR model regulations that generally fell into the following
four categories: (1) Removing duplication of requirements in similar
provisions; (2) streamlining and reorganizing the provisions for
clarity and consistency; (3) providing additional flexibility in
response to feedback from CJR participant hospitals and other
stakeholders; and (4) expanding the scope of financial arrangements
under the EPM. In addition to the collaborators permitted under the CJR
model, we proposed to add hospitals and critical access hospitals
(CAHs) to the list of providers and suppliers eligible for gainsharing
as EPM collaborators due to the expected participation of multiple
hospitals in the episode care for some beneficiaries in AMI and CABG
episodes. We specifically proposed that ACOs be eligible for
gainsharing as EPM collaborators due to the interest of ACOs in
gainsharing during the CJR model rulemaking and the ongoing challenges
of addressing overlap between episode payment models and ACOs. We made
additional proposals that would allow ACOs to enter into financial
arrangements under the EPM with ACO participants and ACO providers/
suppliers and to allow physicians group practices (PGPs) that are ACO
participants in an ACO that is an EPM collaborator to enter into
financial
[[Page 195]]
arrangements under the EPM with PGP members.
As discussed in section III.I. of this final rule, after
consideration of the public comments received we are finalizing the
proposed structure for financial arrangements under the EPM, including
that EPM participants may enter into sharing arrangements with EPM
collaborators, EPM collaborators may enter into distribution
arrangements with collaboration agents, and collaboration agents may
enter into downstream distribution arrangements with downstream
collaboration agents, subject to the requirements specific to each type
of arrangement. Our final policies also include modifications to
specify individually based on their enrollment in Medicare the specific
providers and suppliers of outpatient therapy services that may be EPM
collaborators. We also make modifications to clarify that groups of
nonphysician practitioners and groups of therapists (physical therapy,
occupational therapy, and speech-language pathology) enrolled in
Medicare may be EPM collaborators and may enter into distribution
arrangements or downstream distribution arrangements under the EPM that
are similar to those we are finalizing for PGPs and their members.
9. Data Sharing
Based on our experience with various Medicare programs and models,
including the BPCI initiative, the CJR model, the Shared Savings
Program, and the Pioneer ACO model, we believe that providing certain
beneficiary claims data to model participants will be essential to
their success. We proposed to share data with participants upon request
throughout the performance period of the models to the extent permitted
by the Health Insurance Portability and Accountability Act of 1996
(HIPAA) Privacy Rule and other applicable law. We proposed to share
upon request both raw claims-level data and claims summary data with
participants. This approach would allow participants without prior
experience analyzing claims to use summary data for analysis of care
and spending patterns, while allowing those participants who prefer raw
claims-level data the opportunity to analyze claims. We proposed to
provide participants with up to 3 years of retrospective claims data
upon request that will be used to develop their quality-adjusted target
price. In accordance with the HIPAA Privacy Rule, we will limit the
content of this data to the minimum data necessary for the participant
to conduct quality assessment and improvement activities and
effectively coordinate care.
10. Program Waivers
Section 1115A of the Act authorizes the Secretary to waive Medicare
program requirements as necessary to implement provisions for testing
models. Under the CJR model, CMS waived certain program rules regarding
the direct supervision requirement for certain post-discharge home
visits, telehealth services, and the skilled nursing facility (SNF) 3-
day rule. CMS finalized these waivers to offer providers and suppliers
more flexibility so that they may increase coordination of care and
management of beneficiaries in model episodes. Adopting the CJR waivers
for the proposed EPMs required further examination to determine if such
adoption would increase financial vulnerability to the Medicare program
or would create inappropriate incentives to reduce the quality of
beneficiary care. As discussed in section III.J. of this final rule, we
will do the following:
Adopt waivers of the telehealth originating site and
geographic site requirement and to allow in-home telehealth visits for
all three proposed EPMs, as well as the general waiver to allow post-
discharge nursing visits in the home;
Provide model-specific limits to the number of post-
discharge nursing visits and make model-specific decisions about
offering the SNF 3-day stay waiver; and
Adopt a waiver for furnishing cardiac and intensive
cardiac rehabilitation services to allow a Nurse Practitioner, Clinical
Nurse Specialist, or Physician Assistant, in addition to a physician,
to perform specific physician functions.
C. Summary of Economic Effects
As shown in our impact analysis, we expect the EPMs to result in
savings to Medicare of $159 million over the 5 performance years of the
models. We note that a composite quality score will be calculated for
each hospital in order to determine eligibility for a reconciliation
payment and whether the hospital qualifies for quality incentive
payments that will reduce the effective discount percentage experience
by the hospital at reconciliation for a given performance year. More
specifically, in performance year 1 of the models, we estimate a
Medicare cost of approximately $10 million, as hospitals will not be
subject to downside risk in the first performance year of the models.
In performance year 2 of the models, we estimate a Medicare cost of
approximately $25 million, as some hospitals will voluntarily assume
downside risk in the second performance year of the models and some
hospitals will receive payments made by CMS. As we introduce downside
risk beginning in performance year 3 of the models, we estimate
Medicare savings of approximately $34 million. In performance years 4
and 5 of the models, we will move from target episode pricing that is
based on a hospital's experience to target pricing based on regional
experience, and we estimate Medicare savings of $49 million and $112
million, respectively.
As a result, we estimate the net savings to Medicare to be $159
million over the 5 performance years of the models. We anticipate there
will be a broader focus on care coordination and quality improvement
for EPMs among hospitals and other providers and suppliers within the
Medicare program that will lead to both increased efficiency in the
provision of care and improved quality of the care provided to
beneficiaries.
Additionally, the CR incentive model estimates that the impact on
the Medicare program may range from up to $29 million of additional
spending to $32 million of savings between 2017 and 2024, depending on
the change in utilization of CR/ICR services based on the proposed
incentive structure.
Finally, the change in the estimated net financial impact to the
Medicare program from the CJR model modifications in this final rule is
$22 million in spending, and the updated assumptions regarding the
number of hospitals that will report quality data result in an increase
of $4 million in spending. The total estimated net financial impact to
the Medicare program from both the modifications in the final rule and
revised assumptions are $26 million in spending. We note that under
section 1115A(b)(3)(B) of the Act, the Secretary is required to
terminate or modify a model unless certain findings can be made with
respect to savings and quality after the model has begun. If during the
course of testing a model it is determined that termination or
modification is necessary, such actions will be undertaken through
rulemaking.
II. Background
This final rule finalizes the implementation of three new EPMs and
a CR incentive payment model under the authority of section 1115A of
the Act. Under the AMI, CABG, and SHFFT EPMs, acute care hospitals in
certain selected geographic areas will be financially accountable for
quality
[[Page 196]]
performance and spending for applicable episodes of care. We proposed
to retrospectively apply through a reconciliation process the episode
payment methodology; hospitals and other providers and suppliers would
continue to submit claims and receive payment via the usual Medicare
FFS payment systems throughout the proposed EPMs' performance years.
Critical Access Hospitals (CAHs) acting as EPM collaborators would
continue to receive payment via the usual cost-based reimbursement
system. Hospitals participating in the proposed EPMs would receive
target prices, which reflect expected spending for care during an
episode as well as a discount to reflect savings to Medicare, on a
prospective basis, prior to the beginning of a performance year. All
related care covered under Medicare Parts A and B and furnished within
90 days after the date of hospital discharge from the anchor
hospitalization which initiated the applicable EPM episode would be
included in the episode of care. We proposed the CR incentive payment
model to test the effects on quality of care and Medicare expenditures
of providing explicit financial incentives to a subset of EPM
participants and selected hospitals that are not AMI or CABG model
participants for beneficiaries hospitalized for treatment of AMI or
CABG to encourage care coordination and greater utilization of
medically necessary CR/ICR services for 90 days post-hospital discharge
where the beneficiary's overall care is paid under either an EPM or the
Medicare FFS program. We believe the models will further our goals of
improving the efficiency and quality of care for Medicare beneficiaries
for these medical conditions and procedures.
III. Episode Payment Models
A. Selection of Episodes, Advanced Alternative Payment Model
Considerations, and Future Directions
1. Selection of Episodes for Episode Payment Models in This Rulemaking
a. Overview
We have been engaged since 2013 in testing various approaches to
episode payment for Medicare FFS beneficiaries for 48 clinical episodes
in the BPCI initiative. As of October 1, 2016, the BPCI initiative has
1,403 participants in the risk-bearing phase, comprised of 297 Awardees
and 1,107 Episode Initiators. The breakdown of BPCI participants by
provider type is as follows: Acute care hospitals (354); skilled
nursing facilities (642); physician group practices (257); home health
agencies (81); and inpatient rehabilitation facilities (9).\11\ In BPCI
Models 2 and 3, there is participation across all 48 clinical episodes,
and in Model 4 there is participation in 19 clinical episodes.
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\11\ https://innovation.cms.gov/initiatives/bundled-payments/.
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The 10 clinical episodes with the most participation are: Major
joint replacement of the lower extremity; simple pneumonia and
respiratory infections; congestive heart failure; chronic obstructive
pulmonary disease; bronchitis; asthma; hip and femur procedures except
major joint; sepsis; urinary tract infection; acute myocardial
infarction (medical management only); medical non-infectious
orthopedic; and other respiratory.\12\
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\12\ https://innovation.cms.gov/Files/x/bpcianalyticfile.xlsx.
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In November 2015, CMS released the Final Rule for the Comprehensive
Care for Joint Replacement (CJR) model (80 FR 73274 through 73554), the
first test of episode-based payment model for Medicare FFS
beneficiaries in which providers are required to participate. The CJR
model, which began on April 1, 2016, focuses on the episode-of-care for
lower-extremity joint replacement (LEJR) procedures. As discussed in
the CJR Final Rule (80 FR 73277), LEJR episodes were chosen for the CJR
model because they represent one of the most common high-expenditure,
high-utilization procedures furnished to Medicare beneficiaries and
have significant variation in episode spending. We believe this high
volume, coupled with substantial variation in utilization and spending
across individual providers and geographic regions, created a
significant opportunity to test whether an episode payment model
focused on a defined set of procedures could improve the quality and
coordination of care, as well as result in savings to Medicare.
Notably, both the BPCI initiative and the CJR model are focused on care
that is related to an inpatient hospitalization, with CJR model and
BPCI Model 2 episodes beginning with an inpatient hospitalization
(anchor hospitalization) and extending up to 90 days post-hospital
discharge.
In the proposed rule (81 FR 50805), we proposed three new EPMs
that, like the CJR model, would require provider participation in
selected geographic areas. Episodes in the new EPMs would begin with
admissions for hospitalizations in IPPS hospitals, and would extend 90
days post-hospital discharge. The episodes included in these three
proposed EPMs would be AMI, CABG, and SHFFT excluding lower extremity
joint replacement. The proposed AMI model included beneficiaries
discharged under AMI MS-DRGs (280-282), representing IPPS admissions
for AMI that are treated with medical management. The proposed AMI
model also included beneficiaries discharged under PCI MS-DRGs (246-
251) with AMI International Classification of Disease, Tenth Edition,
Clinical Modification (ICD-10-CM) diagnosis codes for initial AMI
diagnoses in the principal or secondary diagnosis code positions,
representing IPPS admissions for AMI that are treated with PCIs. The
proposed CABG model included beneficiaries discharged under CABG MS-
DRGs (231-236), representing IPPS admissions for this coronary
revascularization procedure irrespective of AMI diagnosis. The proposed
SHFFT model included beneficiaries discharged under hip and femur
procedures except major joint replacement MS-DRGs (480-482),
representing IPPS admissions for hip-fixation procedures in the setting
of hip fractures.
Similar to the selection of LEJR episodes for the CJR model (80 FR
73277), we selected the AMI, CABG, and SHFFT episodes because they
represent high-expenditure, high-volume episodes-of-care experienced by
Medicare beneficiaries. Based on analysis of historical episodes
beginning in CY 2012-2014, the average annual number of episodes that
began with IPPS hospitalizations and extended 90 days post-hospital
discharge, and therefore would have been included in the proposed
models, is approximately 168,000 for AMI; 48,000 for CABG; and 109,000
for SHFFT.\13\ The total annual Medicare spending for these historical
episodes was approximately $4.1 billion, $2.3 billion, and $4.7
billion, respectively.\14\ Each of the episodes provides different
opportunities in an EPM to improve the coordination and quality of
care, as well as efficiency of care during the episode, based on
varying current patterns of utilization and Medicare spending.
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\13\ Episodes for AMI, CABG, and SHFFT beneficiaries initiated
by all U.S. IPPS hospitals not in Maryland and constructed using
standardized Medicare FFS Parts A and B claims, as proposed in the
proposed rule that began in CY 2012-2014.
\14\ Episodes for AMI, CABG, and SHFFT beneficiaries initiated
by all U.S. IPPS hospitals not in Maryland and constructed using
standardized Medicare FFS Parts A and B claims, as proposed in the
proposed rule that began in CY 2012-2014.
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However, in contrast to LEJR episodes in the CJR model, which are
predominantly elective and during which hospital readmissions are rare
[[Page 197]]
and substantial post-acute care provider utilization is common, the
proposed AMI, CABG, and SHFFT episodes have very different current
patterns of care. Beneficiaries in these episodes commonly have chronic
conditions that contribute to the initiation of the episodes and need
both planned and unplanned care throughout the EPM episode following
discharge from the initial hospitalization that begins the episode.
Both AMI and CABG episodes primarily include beneficiaries with
cardiovascular disease, a chronic condition which likely contributed to
the acute events or procedures that initiate the episodes. About half
the average AMI model historical episode spending was for the initial
hospitalization, with the majority of spending following discharge from
the initial hospitalization due to hospital readmissions, while there
was relatively less spending on SNF services, Part B professional
services, and hospital outpatient services. In CABG model historical
episodes, about three-quarters of episode spending was for the initial
hospitalization, with the remaining episode spending relatively evenly
divided between Part B professional services and hospital readmissions,
and a lesser percentage on SNF services. Similar to AMI episodes, post-
acute care provider use was relatively uncommon in CABG model
historical episodes, while hospital readmissions during CABG model
historical episodes were relatively common. SHFFT model historical
episodes also were accompanied by substantial spending for hospital
readmissions, and post-acute care provider use in these episodes also
was high.\15\ The number of affected beneficiaries and potential impact
of the models on quality and Medicare spending present an important
opportunity to further the Administration's goal of shifting health
care payments to support the quality of care over the quantity of
services by promoting better coordination among health care providers
and suppliers and greater efficiency in the care of beneficiaries in
these models, while reducing Medicare expenditures.\16\ Pay-for-
performance episode payment models, such as the three EPMs proposed in
the proposed rulemaking, financially incentivize improved quality of
care and reduced cost by aligning the financial incentives of all
providers and suppliers caring for model beneficiaries with these
goals. This alignment leads to a heightened focus on care coordination
and management throughout the episode that prioritizes the provision of
those items and services which improve beneficiary outcomes and
experience at the lowest cost.
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\15\ Episodes for AMI, CABG, and SHFFT beneficiaries initiated
by all U.S. IPPS hospitals not in Maryland and constructed using
standardized Medicare FFS Parts A and B claims, as proposed in the
proposed rule that end in CY 2014.
\16\ Sylvia Mathews Burwell, HHS Secretary, Progress Towards
Achieving Better Care, Smarter Spending, Healthier People, https://www.hhs.gov/blog/2015/01/26/progress-towards-better-care-smarter-spending-healthier-people.html (January 26, 2015).
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We selected all of the proposed EPM episodes based on their
clinical homogeneity, site-of-service, and MS-DRG assignment
considerations. We anticipated these proposed new EPMs, like the CJR
model, would benefit Medicare beneficiaries by improving the
coordination and transition of care among various care settings to
facilitate beneficiaries' return to their communities as their
recoveries progress, improving the coordination of items and services
paid through Medicare FFS, encouraging provider investment in
infrastructure and redesigned care processes for higher quality and
more efficient service delivery, and incentivizing higher value care
across the inpatient and post-acute care spectrum spanning the episode-
of-care (80 FR 73276). However, improving value in the EPMs through
these means requires a cohort of beneficiaries with similar clinical
features such that coordination and care redesign efforts can be
targeted. Therefore, we proposed EPM episodes built on common
pathologic and treatment processes; that is, beneficiaries included in
both the AMI and CABG models have cardiovascular pathologies that drive
their clinical courses during the episodes, and SHFFT model
beneficiaries all share similar diagnoses of hip fracture and treatment
with hip fixation that drive their clinical courses during their
respective episodes.
The following is a summary of the comments received on our overall
proposal of three new EPMs in which participation would be required and
our responses.
Comment: Many commenters commended CMS for its continued commitment
to testing episode-based payments demonstrated through the proposal to
implement three new EPMs. MedPAC identified conditions with high post-
acute care use as an appropriate setting to test bundled payments that
would offer ample opportunities to improve care and lower spending.
MedPAC also suggested that another consideration for bundled payments
is whether the condition has a relatively uniform clinical pathway that
simplifies the rules defining and pricing the bundle. In addition,
MedPAC emphasized that conditions that lend themselves to patient
selection should be avoided in bundled payment models, at least in the
near term, to limit the undesirable provider responses to financial
incentives that may occur. Other commenters expressed appreciation for
the opportunity to test innovative care models under the Innovation
Center authority. They stated that EPMs could hold significant promise
for furthering the Triple Aim goals of providing high quality care at
lower cost to produce better outcomes and advance population health.
However, some commenters expressed concern about the pace of
changes proposed by CMS through its models and the associated
expectation and burden that rapid changes in the delivery system and
related payment structure place on hospitals and providers. Some
commenters noted that CMS has been swift in releasing rules aimed at
improving the quality of care delivered, reducing the cost of care, and
coordinating patient care across multiple settings. The commenters
pointed out the large volume of significant requirements announced by
CMS over the last 2 years, including MACRA, the CJR model, and the
proposed Part B drug payment model, as well as alternative payment
models and programs, including the Shared Savings Program, Next
Generation ACOs, BPCI initiative, and OCM, coupled with state level
initiatives. The commenters believe the breadth and amount of new
activities make it difficult to understand how the various models and
program will interact with each other and impact individual delivery
systems. While directed toward laudable goals, the commenters
encouraged CMS to be vigilant in its review and analysis of these
models and programs and to consider the impact and burden on hospitals
as it continues to release models and programs impacting the hospital
community. The commenters believe it is in everyone's best interest
that these models are successful, yet the pace and complexity of
implementation likely will be a critical factor in the achievement of
these goals. Therefore, they encouraged CMS to slow the pace of EPM
implementation to establish ``proof of concept'' through the CJR model
and BPCI Model 2 results before implementing new EPMs where
participation is required. Without adequate time to understand the
appropriate role these payment innovations play in transforming care
delivery and build upon lessons learned and best practices, the
commenters
[[Page 198]]
concluded that both CMS and the provider community would miss an
important opportunity to create programs that will advance patient care
and successfully transform systems of care.
The commenters recommended that CMS establish a solid framework
upon which to build payment initiatives and transform care. Before
finalizing any more bundled payment initiatives, some commenters
believe that CMS should articulate its vision and set a clear path for
innovative payment models, establishing a consistent, predictable and
transparent framework, giving providers the necessary tools to succeed
in creating a higher-quality, more efficient health care system. The
commenters suggested that the framework should include tools such as
incorporating a predictable pricing trend factor so that participants
can make decisions about investing in care design in the context of
stable future prices; providing necessary risk adjustment
methodologies; releasing consistent quality measures and reporting
requirements and reliable target pricing; and holding fast to the
principle of attributing no more than one patient to one bundled
payment initiative at a time.
A few commenters expressed concerns about CMS' proposal to test
three new bundled payment models. The commenters contended that the
proposed EPMs would make treatment more difficult to access for high
need patients; discourage truly innovative approaches to managing
underlying health problems; encourage unnecessary surgeries; encourage
further consolidation in the health care industry; provide fewer
choices for consumers; and result in higher prices for private payers.
One commenter requested that CMS present a much more comprehensive
analytic work to understand the prevalence and needs of the
beneficiaries who have serious illness or disabilities prior to and
during the episode and who therefore require substantial attention to
the elements of comprehensive care and quality measurement that are
tailored for these beneficiaries prior to implementing the EPMs.
Several commenters recommended CMS not to limit alternative payment
models to episode payment approaches because for many types of
patients, the biggest opportunity for improving quality and achieving
savings is avoiding unnecessary episodes and events, and not simply
paying differently for episodes and events when they occur. Some
commenters strongly cautioned against EPMs that may subordinate future
provider-led models. Other commenters recommended CMS to develop and
implement payment reform models that incorporate population-based
models, rather than look exclusively at episode payment models which
can hamper growth of population-based models by limiting their
financial opportunity.
Response: We appreciate the support of many commenters for CMS'
continued development of new episode payment models and agree with
these commenters that episode payment models provide substantial
opportunity to improve the quality and efficiency of care for specific
clinical conditions. We also agree that bundled payment models are just
one strategy to incentivize the health care system moving toward the
provision of more accountable, coordinated, high-value care, while
provider-led and population-based models, as well as other types of
payment reform models, play complementary roles. The Innovation Center
is continuing to develop, implement, and evaluate a variety of
different types of models that test different approaches to achieving
better care, lower costs, and improved health. The three EPMs are part
of that portfolio of models. Issues of concern raised by some of the
commenters about the proposed EPMs, including the implementation
timeline, are discussed in the specific sections of this final rule
that address the relevant policies.
b. SHFFT Model
The SHFFT model was selected to complement the CJR model. We
proposed to test the SHFFT model in most of the same hospitals
participating in the CJR model as discussed in section III.B.4. of the
proposed rule (81 FR 50794), so that all surgical treatment options for
Medicare beneficiaries with hip fracture (hip arthroplasty and
fixation) would be included in episode payment models. Hip fracture is
a serious and sometimes catastrophic event for Medicare beneficiaries.
In 2010, 258,000 people aged 65 and older were admitted to the hospital
for hip fracture, with an estimated $20 billion in lifetime cost for
all hip fractures in the United States in a single year.\17\ In 2013,
fracture of the neck of the femur (the most common location for hip
fracture) was the eighth most common principal discharge diagnosis for
hospitalized Medicare FFS beneficiaries, constituting 2.7 percent of
discharges.\18\ Mortality associated with hip fracture is 5-10 percent
after 1 month and approximately 33 percent at 1 year.\19\ Hip
arthroplasty and hip fixation, or ``hip pinning,'' represent the two
broad surgical options for treating hip fractures.\20\ The CJR episodes
begin with admission to acute care hospitals for LEJR procedures
assigned to MS-DRG 469 (Major joint replacement or reattachment of
lower extremity with major complications or comorbidities) or MS-DRG
470 (Major joint replacement or reattachment of lower extremity without
major complications or comorbidities) upon beneficiary discharge and
paid under the IPPS, including total and partial hip replacement in the
setting of hip fracture (80 FR 73280). Therefore, the SHFFT model,
which would test an additional episode payment for hip fixation,
provides an opportunity to complete the transition to episode payment
for the surgical treatment and recovery of the significant clinical
condition of hip fracture.
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\17\ Smith et al. Increase in Disability Prevalence Before Hip
Fracture. J Am Geriatr Soc. 2015 Oct;63(10):2029-35.
\18\ Krumholz HM, Nuti SV, Downing NS, Normand ST, Wang Y.
Mortality, Hospitalizations, and Expenditures for the Medicare
Population Aged 65 Years or Older, 1999-2013. JAMA. 2015;
314(4):355-365.
\19\ Parker et al. Hip Fracture. BMJ. 2006 Jul 1;333(7557):27-
30.
\20\ American Academy of Orthopaedic Surgeons, OrthoInfo: Hip
Fractures, https://orthoinfo.aaos.org (April 12, 2016).
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The following is a summary of the comments received and our
responses.
Comment: Some commenters expressed support for the SHFFT model,
which CMS proposed to implement in the same MSAs as the CJR model,
which was implemented beginning in April 2016, and in particular
expressed appreciation for the design consistency proposed for the
SHFFT model with the CJR model and the two proposed cardiac EPMs.
Analysis by MedPAC found that most SHFFT episodes include at least some
post-acute care services use and that the spending on post-acute care
services comprises a sizable share of total episode spending, about
one-third. MedPAC concluded that SHFFT was a good candidate for bundled
payment. MedPAC also reasoned that the SHFFT episode would give
hospitals already participating in the CJR model the experience of
managing care for hip and femur fracture cases that typically present
emergently, rather than as the planned, elective surgery that is most
common for lower extremity joint replacement. MedPAC, which recommended
proceeding only with the SHFFT model in the context of CMS' proposal
for three new EPMs, maintained that this
[[Page 199]]
would simplify the set of models that providers are adapting to and
simplify the administrative requirements for CMS because CMS would not
need to select new markets for testing the cardiac EPMs. Other
commenters found it positive that CMS noted that there are differences
between CJR and SHFFT beneficiaries, notably the latter being more
likely to have multiple chronic conditions and frailty.
However, many commenters opposed CMS' proposal for the SHFFT model,
encouraging CMS either to abandon the model altogether or to
substantially delay implementation pending additional CJR model
experience and evaluation results from BPCI Model 2 regarding SHFFT
episodes. These commenters recommended that CMS proceed at a more
deliberate pace and simplify the proposed rule for the three different
EPMs by eliminating the SHFFT model because CMS is already testing an
episode payment model that requires participation through the CJR
model. Therefore, they believe that CMS should test only a cardiac
bundled payment model in a different clinical area as a next step in
required bundled payment models. The commenters stated that the SHFFT
model would be overly burdensome to providers who just began
participating in the CJR model in April 2016 and had insufficient
financial safeguards for hospitals and quality safeguards for
beneficiaries, including no quality measures specific to SHFFT model
beneficiaries, to substantially improve beneficiaries' care experience
through successful surgery and recovery. Several commenters stated that
the proposed SHFFT model was not a true value-based payment model
because the clinical outcome quality measures that were proposed did
not capture hip fracture patients. Given CMS' proposal to implement the
SHFFT model in the same MSAs as the CJR model, the commenters stated
that due to limited implementation time of the CJR model, it would be
inappropriate to add the very sick and frail SHFFT cohort to the
relatively stable CJR model cohort without substantial investigation as
to how to proceed with adequate monitoring against harm. They also
recommended not proceeding without risk adjustment to account for
variable costs experienced by hospitals treating different populations
of SHFFT model beneficiaries. Several commenters claimed that because
SHFFT beneficiaries would receive emergency care, care coordination
would be less predictable and no planning would be possible prior to
hospital admission, so the burden on potential family caregivers would
be escalated in comparison to the CJR model if there was only a short
hospital and/or SNF stay. The commenters stated that in comparison with
beneficiaries undergoing elective LEJR, those with hip fracture require
more time and resources from providers to optimize planning and
rehabilitation and, therefore, limited efficiencies would be possible
for SHFFT model beneficiaries without significant risk to the quality
of care.
Response: We appreciate the perspective of some commenters that the
opportunities for care redesign to improve quality and reduce spending
are substantial for Medicare beneficiaries undergoing SHFFT procedures.
We agree with those commenters about the potential value of the SHFFT
model for beneficiaries, providers, and CMS to complement the CJR model
by testing bundled payment for beneficiaries requiring emergency lower
extremity joint surgery compared to testing episode payment for lower
extremity surgeries that are mainly elective. We also acknowledge the
concerns of the commenters around various proposed design elements of
the SHFFT model, specifically the lack of risk adjustment to protect
SHFFT model participants from undue financial risk for complex
beneficiaries and the lack of quality measures that are specific to
SHFFT beneficiaries in the pay-for-performance methodology to reward
SHFFT model participants that improve quality for these beneficiaries
and protect SHFFT beneficiaries from harm due to the model. We refer to
sections III.D.4.b.(2) and III.E.2.d. of this final rule for further
discussion of the comments on these issues and our responses.
We also appreciate the concerns of commenters regarding the
proposed implementation of the SHFFT model in the same MSAs as CJR
participant hospitals, and the additional responsibilities this model
would place on participants early in their CJR model implementation
experience. However, we continue to believe that there are efficiencies
in care redesign that can be achieved by testing the models
concurrently at the same hospitals. We note that those commenters
opposing CMS' proposal to implement the SHFFT model did not dispute the
care redesign opportunities identified by CMS for such a model. We
refer to section III.D.2.a. of this final rule for a discussion of the
comments on the proposed implementation timeline for the SHFFT model
and our responses.
Final Decision: After consideration of the public comments
received, we are finalizing the proposal to implement the SHFFT model,
with modifications to specific policies as described throughout this
final rule. We refer to section III.D.2.a. of this final rule for the
implementation timeline that applies to the SHFFT model.
c. AMI and CABG Models
The AMI and CABG models, which we proposed to be tested at a single
set of hospitals as discussed in section III.B.5. of the proposed rule
(81 FR 50794), were selected to include all beneficiaries who have an
AMI treated medically or with revascularization with PCI, as well as
all beneficiaries who undergo CABG (whether performed during the care
of an AMI or performed electively for stable ischemic heart disease or
other indication). Both cardiac models represent clinical conditions
that result in a significant burden of morbidity and expenditures in
the Medicare population. CABG typically is the preferred
revascularization modality for patients with ST (the part of an
electrocardiogram between the QRS complex and the T wave) elevation AMI
where the coronary anatomy is not amenable to PCI or there is a
mechanical complication (for example, ventricular septal defect,
rupture of the free wall of the ventricle, or papillary-muscle rupture
with severe mitral regurgitation); for patients with CAD other than ST
elevation AMI where there is left main coronary artery disease or
multivessel disease with complex lesions; and for patients with
clinically significant CAD in at least one vessel and refractory
symptoms despite medical therapy and PCI.\21\ Despite the greater acute
morbidity related to major cardiothoracic surgery, CABG is associated
with lower longer-term rates of major adverse cardiac and
cerebrovascular events in comparison to PCI for certain groups of
patients.\22\ Moreover, a recent study found that in a group of
patients with ischemic cardiomyopathy, the rates of death from any
cause, death from cardiovascular causes, and death from any cause or
hospitalization for cardiovascular causes were significantly lower over
10 years among patients who underwent CABG in addition to receiving
medical
[[Page 200]]
therapy than among those who received medical therapy alone.\23\ While
about 30 percent of CABGs are performed during the care of AMIs, we
proposed to include these particular AMI beneficiaries generally in the
same episode as CABG for other indications, rather than in the AMI
episode, since we anticipate hospitals will seek to improve the quality
and efficiency of care for that surgical intervention, regardless of
indication.\24\
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\21\ Alexander JH, Smith PK. Coronary-Artery Bypass Grafting. N
Engl J Med. 2016 May 19;374(2):1954-1964.
\22\ Sepehripour et al. Developments in surgical
revascularization to achieve improved morbidity and mortality.
Expert Rev Cardiovasc Ther. 2016 Mar;14(3):367-79. doi: 10.1586/
14779072.2016.1123619. Epub 2015 Dec 17.
\23\ Velazquez et al. Coronary Artery Bypass Surgery in Patients
with Ischemic Cardiomyopathy. N Engl J Med. 2016 Apr 3.
\24\ Episodes for CABG beneficiaries initiated by all U.S. IPPS
hospitals not in Maryland and constructed using standardized
Medicare FFS Parts A and B claims, as proposed in the proposed rule
that end in CY 2014.
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We proposed AMI as the episode for an EPM because we recognized it
as a significant clinical condition for which evidence-based clinical
guidelines are available for the most common AMI scenarios that begin
with a beneficiary's presentation for urgent care, most commonly to a
hospital emergency department. The hospital phase involves medical
management for all patients, as well as potential revascularization,
most commonly with PCI. Secondary prevention and plans for long-term
management begin early during the hospitalization, extend following
hospital discharge, and are addressed in clinical
guidelines.25 26 The AMI model is the first Innovation
Center episode payment model that includes substantially different
clinical care pathways (medical management and PCI) for a single
clinical condition in one episode in a model and, as such, represents
an important next step in testing episode payment models for clinical
conditions which involve a variety of different approaches to treatment
and management.
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\25\ Amsterdam EA, Wenger NK, Brindis RG, Casey DE Jr, Ganiats
TG, Holmes DR Jr, Jaffe AS, Jneid H, Kelly RF, Kontos MC, Levine GN,
Liebson PR, Mukherjee D, Peterson ED, Sabatine MS, Smalling RW,
Zieman SJ. 2014 ACC/AHA guideline for the management of patients
with non-ST-elevation acute coronary syndromes: a report of the
American College of Cardiology/American Heart Association Task Force
on Practice Guidelines. Circulation. 2014;130:e344-e426.
\26\ O'Gara PT, Kushner FG, Ascheim DD, Casey DE Jr, Chung MK,
de Lemos JA, Ettinger SM, Fang JC, Fesmire FM, Franklin BA, Granger
CB, Krumholz HM, Linderbaum JA, Morrow DA, Newby LK, Ornato JP,Ou N,
Radford MJ, Tamis-Holland JE, Tommaso CL, Tracy CM, Woo YJ, Zhao DX.
2013 ACCF/AHA guideline for the management of ST-elevation
myocardial infarction: a report of the American College of
Cardiology Foundation/American Heart Association Task Force on
Practice Guidelines. Circulation. 2013;127:
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The American Heart Association estimates that every 42 seconds,
someone in the United States has a myocardial infarction.\27\ AMI
remains one of the most common hospital diagnoses among Medicare FFS
beneficiaries, and almost 20 percent of beneficiaries discharged for
AMI are readmitted within 30 days of hospital
discharge.28 29 In 2013, AMI was the sixth most common
principal discharge diagnosis for hospitalized Medicare FFS
beneficiaries, constituting 2.9 percent of discharges.\30\ Of the
approximately 395,000 Medicare FFS beneficiaries with short-term acute
care hospital discharges (excluding Maryland) for AMI in FY 2014, 60
percent were discharged under MS-DRGs proposed to be included in the
AMI model, specifically 33 percent under AMI MS-DRGs and 25 percent
under PCI MS-DRGs.\31\ An additional 3 percent of beneficiaries were in
MS-DRGs for death from AMI in the hospital. Although 5 percent of
beneficiaries with hospital discharges for AMI were discharged under
CABG MS-DRGs, we note that because both PCI and fibrinolysis can
restore blood flow in an acutely occluded coronary artery more quickly
than CABG, these interventions are currently preferred to CABG in most
cases of AMI. Furthermore, over recent years cardiovascular clinical
practice patterns have generally shifted away from surgical treatment
of coronary artery occlusion toward percutaneous, catheter-based
interventions.\32\ The remaining 34 percent of beneficiaries with AMI
diagnoses were distributed across a heterogeneous group of over 300
other MS-DRGs, such as septicemia, respiratory system diagnosis with
ventilator support, and major cardiovascular procedures. For this
latter group of beneficiaries, the AMI diagnosis appeared in a
secondary position on the hospital claim in more than 90 percent of the
cases, therefore most likely representing circumstances where the
beneficiary while hospitalized for another clinical condition
experienced an AMI during the hospital stay. By focusing the AMI model
on AMIs treated medically or with revascularization with PCI, we
proposed to test a condition-specific EPM that was discretely defined
and includes a significant majority of beneficiaries with AMI in the
AMI model. In CYs 2012-2014, the average Medicare spending for an AMI
episode that extends 90 days post-hospital discharge was approximately
$24,200.\33\ From the AMI model, we expect to better understand the
impact that such an EPM can have on efficiency and quality of care for
beneficiaries across the entire spectrum of AMI care, including
diagnosis, treatment, and recovery, as well as short-term secondary
prevention.
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\27\ Mozaffarian D, Benjamin EJ, Go AS, Arnett DK, Blaha MJ,
Cushman M, Das SR, de Ferranti S, Despr[eacute]s J-P, Fullerton HJ,
Howard VJ, Huffman MD, Isasi CR, Jim[eacute]nez MC, Judd SE, Kissela
BM, Lichtman JH, Lisabeth LD, Liu S, Mackey RH, Magid DJ, McGuire
DK, Mohler ER III, Moy CS, Muntner P, Mussolino ME, Nasir K, Neumar
RW, Nichol G, Palaniappan L, Pandey DK, Reeves MJ, Rodriguez CJ,
Rosamond W, Sorlie PD, Stein J, Towfighi A, Turan TN, Virani SS, Woo
D, Yeh RW, Turner MB; on behalf of the American Heart Association
Statistics Committee and Stroke Statistics Subcommittee. Heart
disease and stroke statistics--2016 update: a report from the
American Heart Association. Circulation. 2016 Jan 26; 133(4):447-54.
\28\ Krumholz HM, Nuti SV, Downing NS, Normand ST, Wang Y.
Mortality, Hospitalizations, and Expenditures for the Medicare
Population Aged 65 Years or Older, 1999-2013. JAMA. 2015;
314(4):355-365.
\29\ Dharmarajan K, Hsieh AF, Lin Z, et al. Diagnoses and Timing
of 30-Day Readmissions After Hospitalization for Heart Failure,
Acute Myocardial Infarction, or Pneumonia. JAMA. 2013; 309(4):355-
363.
\30\ Krumholz HM, Nuti SV, Downing NS, Normand ST, Wang Y.
Mortality, Hospitalizations, and Expenditures for the Medicare
Population Aged 65 Years or Older, 1999-2013. JAMA. 2015;
314(4):355-365.
\31\ Inpatient claims from all U.S. IPPS hospitals not in
Maryland were derived from the October 2013--September 2014
Inpatient Claims File located in the Chronic Conditions Warehouse.
\32\ Epstein et al. JAMA. 2011 May 4; 305(17):1769-1776.
\33\ Episodes for beneficiaries with AMI diagnosis initiated by
all U.S. IPPS hospitals not in Maryland and constructed using
standardized Medicare FFS Parts A and B claims, as proposed in the
proposed rule that began in CYs 2012-2014.
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Beneficiaries in the AMI and CABG models will all have CAD. In 2010
in the U.S., the prevalence of CAD in the population 65 years and older
was about 20 percent.\34\ Patients with CAD also often experience other
significant health conditions, including diabetes. To improve care for
patients with CAD, most approaches in the private and public sectors
focus on improving the efficiency and quality of care around procedures
such as PCI and CABG. The BPCI models are an example of such an
approach. As discussed previously in this section, our proposal for the
AMI model extends beyond a procedure-based EPM to include beneficiaries
hospitalized for medical management or PCI for AMI in a single EPM, and
we proposed to test the CABG model, which also would include
beneficiaries with AMI, at the same participant hospitals. We believe
that hospitalization for AMI, whether accompanied solely by medical
management or including revascularization during the initial
hospitalization or in a planned CABG
[[Page 201]]
readmission, is a sentinel event indicating the need for an increased
focus on condition-specific management, as well as on care coordination
and active management to prevent future acute events, both during the
AMI and CABG episodes and beyond. We also believe that improving the
quality and efficiency of CAD care over a long period of time is
important given the chronic nature of this condition that has serious
implications for beneficiary health.
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\34\ National Center for Chronic Disease Prevention and Health
Promotion, Division for Heart Disease and Stroke Prevention, August
10, 2015.
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The AMI and CABG models provide an opportunity for us to
incentivize CAD-specific care management and care coordination for AMI
and CABG model beneficiaries that lays the groundwork for longer-term
improvements in quality and efficiency of care for beneficiaries with
CAD. We note that the quality measures proposed for use in the pay-for-
performance methodologies of the AMI and CABG models do not currently
include longer-term outcomes or patient experience outside of the AMI
or CABG episode itself, as discussed in sections III.E.2.b. and c. of
the proposed rule (81 FR 50794), although we were interested in
comments about potential future measures that could incorporate longer-
term outcomes. Moreover, as discussed in section VI. of the proposed
rule (81 FR 50794), we also proposed to test a cardiac rehabilitation
(CR)/intensive cardiac rehabilitation (ICR) incentive payment,
hereinafter CR incentive payment, in AMI and CABG model participants
located in some of the MSAs selected for AMI and CABG model
participation, as well as in hospitals located in some of the MSAs that
are not selected for AMI or CABG model participation. We proposed to
evaluate the effects of the CR incentive payment in the context of an
episode payment model and Medicare FFS on utilization of CR/ICR, as
well as short-term (within the period of time extending 90 days
following hospital discharge from an AMI or CABG hospitalization) and
longer-term outcomes. We believe this test may result in valuable
findings about effective strategies to increase utilization of CR/ICR
services that have a strong evidence-base for their effectiveness but a
long history of underutilization.
The following is a summary of the comments received and our
responses.
Comment: A number of commenters expressed support for the proposed
AMI and CABG models, characterizing the proposals as a good first step
toward achieving greater focus not only on cardiac care quality
improvement but also care coordination for the anchor admission through
post-acute care management of patients and families. Several commenters
believe that CMS' proposal to implement separate models for
beneficiaries undergoing treatment for AMI versus CABG surgery was
sensible given the typical recovery pathways experienced by
beneficiaries. One commenter noted that while the majority of
beneficiaries with AMI or CABG have CAD, not all will have this
condition as CMS stated in the proposed rule (81 FR 50807).
Several commenters commended CMS for developing a clinically
appropriate definition for AMI because AMI is a condition that can
require a range of treatments, including both medical treatments and
PCI. The commenters observed that the combination of AMI medical
management and PCI into a single AMI episode is likely to present AMI
model participants with greater opportunity than if the hospital
managed just one of the MS-DRG groupings. They stated that the proposal
to include both medical and PCI MS-DRG groupings in the AMI model would
increase each hospital's AMI episode volume relative to a single MS-DRG
grouping, and further noted that sufficient volume in any bundled
payment model is key to ensuring that financial results are not
primarily driven by random variation.
Several commenters observed that the proposed AMI model would be
the first Innovation Center bundled payment model to combine medical
and procedural care in a single episode and that the majority of
beneficiaries in the AMI model would be experiencing a life-threatening
emergency. These commenters believe the proposed AMI model has the
potential for patient harm and serious unintended consequences and
recommended CMS to maintain a dialogue with practicing clinicians from
medical specialty and subspecialty societies so that unintended
consequences are caught early. One commenter recommended that CMS
refocus the proposed AMI model to be treatment-based, separating
beneficiaries with AMI into two different treatment-based EPMs based on
medical management or PCI. The commenter contended that this approach
would be more straightforward for model participants and allow CMS to
conduct longer-term analyses of BPCI-like models in a more
representative cross-section of hospitals.
Other commenters recommended that CMS pursue only the CABG model,
arguing that the proposed AMI model, with complex, care pathway-
dependent prices and transfer pathways, would influence attribution and
result in serious uncertainties for AMI model participants. One
commenter reasoned that isolated CABG procedures are particularly well-
positioned for a bundled payment model that requires participation
because, despite the availability of robust clinical guidelines,
variability in the costs and outcomes of CABG persist. The commenter
noted that other entities, such as Arkansas and Tennessee Medicaid,
Washington State's Bree Collaborative, and commercial payers, have seen
the potential to improve the cost and quality of CABG through the
implementation of bundled payments. Several commenters stated that
initial implementation of the CABG model alone would allow CABG model
participants to focus efforts on a specific population that includes
the opportunity to excel in the care of CAD and gain some experience in
the care of emergent patients. This limited implementation strategy
would allow model participants to start to develop systems and models
of care that address the unique needs of these populations in a value-
driven equation. The commenters added that as hospitals work through
implementation and gain experience with the CABG model, CMS could then
phase in the inclusion of the much more complicated AMI model, which
would introduce a myriad of factors that would add to the complexity of
EPMs in which the hospital was a participant.
Another commenter who did not favor implementation of the proposed
AMI model reasoned that, in addition to the built-in incentives of MS-
DRGs that currently reward hospitals and physicians for complications
that occur during the beneficiary's hospitalization by providing a
higher IPPS payment for beneficiaries with complications, the proposed
AMI model lacked incentives to manage beneficiaries to reduce CAD
complications such as AMI. Instead, the commenter stated that the
proposed AMI model would incentivize admitting patients who are
marginally symptomatic for AMI that is a complication of CAD, contrary
to the overall goals of EPMs to lower the incidence of complications.
The commenter cited a body of research that has shown that optimal
management of CAD can significantly lower the incidence of AMI. The
commenter recommended CMS to move toward condition-specific episode
payment defined by diagnosis codes, and to halt implementation of an
event-based EPM for AMI that is, in itself, a complication from the
lack of optimal management of CAD. The commenter also stated that CMS
should implement site-agnostic
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PCI episodes so the incentives under the model would be to provide care
in the place of service best suited for the patient. Another commenter
expressed concerns about bundling AMI care, as it encompasses a broad
spectrum of many different complex illnesses. Several commenters
observed that while some AMI patients require less complex care, other
patients are admitted with multiple comorbidities and require a higher
intensity of care, which may involve multiple organs and a variety of
care resources. Other commenters believe that if CMS implements the AMI
model as proposed, more beneficiaries would move into the CABG model
because of the AMI model financial incentives, which would not be in
the best interests of beneficiaries.
While some commenters recommended a short implementation delay for
the AMI and/or CABG models, several other commenters recommended that
CMS delay the AMI and CABG models, with recommendations ranging from 6
to 36 months. These commenters believe this delay would provide
sufficient time for CMS to incorporate known best practices from the
Healthcare Payment Learning and Action Network (LAN) Clinical Episode
Payment (CEP) Work Group and lessons learned from both the BPCI and CJR
models into the design of the cardiac EPMs. Otherwise, the commenters
were concerned that the cardiac EPMs would both put beneficiaries at
risk and disadvantage providers, as the episodes would be built using
designs that were not supported by CMS' own panel of industry experts.
Some commenters expressed concern about expanding EPMs to complex
conditions such as AMI and CABG, where treatment can follow multiple
evidence-based care pathways. One commenter pointed out that the
proposed AMI and CABG models would generally include beneficiaries
receiving unplanned care due to an acute event, making the population's
care difficult to manage. The commenter requested that CMS not
implement the proposed cardiac EPMs. Several commenters stated that the
complexity of the proposed cardiac EPMs was so great that CMS had
essentially proposed a completely different payment system for cardiac
care and would provide EPM participants with little time to prepare and
plan for implementation. The commenters believe that decisions about
appropriate care should be made by physicians and their patients and
should be based on each patient's medical necessity and care
preferences. They stated that bundling clinically complex episodes with
multiple care pathways may lead to factors other than medical necessity
and care preferences influencing the decisions that providers make, and
that such decisions could have a long-term impact on a patient's health
and well-being and may increase costs in the long run while achieving
the short-term goal of reducing episodic costs. The commenters believe
that this potentially serious issue warranted immediate attention by
CMS, given the lack of evidence on the impact of the EPMs on key
patient-centered outcomes, and concluded that the proposed EPMs require
further consideration and study before additional bundling initiatives
are implemented.
MedPAC stated that the proposed AMI episodes did not appear to be a
promising place to further test bundled payment because AMI episodes
have relatively low post-acute care use and the associated post-acute
care spending makes up a small share of total episode spending. They
concluded that savings opportunities for participating providers would
be smaller compared with other conditions. Consistent with the
observations of a few other commenters, MedPAC stated that complex
medical conditions such as AMI do not involve a single clinical pathway
but rather can involve patient transfers to hospitals with more
intensive cardiac capabilities and subsequent readmissions for CABG.
While MedPAC acknowledged that CMS' proposed rule addressed these
issues, they noted that if the benchmark prices are not accurate, the
prices could inadvertently shape clinical practice or encourage
selective admissions. Instead of an EPM, MedPAC suggested that CMS
consider allowing hospitals to share savings with physicians as a way
to focus physicians on reducing the cost of the inpatient stay for AMI
care.
MedPAC further concluded that CABG was also not an ideal condition
for testing bundled payment models because, although the majority of
beneficiaries undergoing CABG go on to use post-acute care services,
the spending on post-acute care services is relatively low compared to
other clinical conditions. They noted that with the inpatient stay
comprising the vast majority of total episode spending, the
opportunities to realize savings by changing clinical practice would be
small. MedPAC presented an additional concern regarding the potential
for undesirable provider responses to financial incentives, including
patient selection, in the proposed CABG model. They claimed that
providers of cardiac care have been shown to engage in patient
selection and expressed concern that, with larger savings at stake,
these behaviors could increase. They recommended that CMS delay testing
the CABG model until the benefits of episode efficiency outweigh the
concerns about patient selection.
Response: We appreciate the support of some of the commenters for
our proposal to implement the AMI and CABG models. The proposed cardiac
models represent clinical conditions that result in a significant
burden of morbidity and expenditures in the Medicare population.
However, we acknowledge the great diversity of views about the AMI and
CABG models reflected in the comments.
We proposed AMI as the episode for an EPM because we recognized it
as a significant clinical condition for which evidence-based clinical
guidelines are available for the most common AMI scenarios that begin
with a beneficiary's presentation for urgent care, most commonly to a
hospital emergency department. The hospital phase involves medical
management for all patients, as well as potential revascularization,
most commonly with PCI. As commenters observed, the AMI model is the
first Innovation Center episode payment model that includes
substantially different clinical care pathways (medical management and
PCI) for a single clinical condition in one episode in a model. In this
sense the AMI model is a condition-specific EPM, although it is not
focused on the underlying CAD condition that puts some beneficiaries at
risk for the AMI but rather on the AMI itself. While we recognize that
AMI may be a complication of care from inadequately managed CAD, we
continue to believe that there is an important role for the AMI model
in testing bundled payment for beneficiaries with AMI who follow a
variety of clinical pathways because AMI is a sentinel event indicating
the need for an increased focus on condition-specific management. The
proposed 90 day post-discharge episode duration would provide a
springboard to heighten the focus on CAD-specific management. While
future models may focus on CAD management itself, including reducing
the risk of AMI, in addition to the current Million Hearts[supreg]
Cardiovascular Risk Reduction Model, we believe that the proposed AMI
model also plays an important role in testing an EPM for this clinical
condition which is not always avoidable even in the context of the best
practices to manage CAD on an ongoing basis.\35\
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\35\ Million Hearts[supreg]: Cardiovascular Disease Risk
Reduction Model. https://innovation.cms.gov/initiatives/Million-Hearts-CVDRRM/.
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We believe that it is important to test EPMs like the AMI model
where
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beneficiaries can follow multiple clinical pathways, including
transfers among hospitals with different cardiac care capacity because,
more commonly than not, beneficiaries who are hospitalized for an
emergent clinical condition do not constitute as homogeneous a group as
those who choose to undergo elective surgery. However, there likely are
significant opportunities to improve the quality and efficiency of
episode care through care redesign that improves care coordination and
management for beneficiaries unexpectedly hospitalized for treatment
following a cardiac event. We disagree with the commenter who
recommended that we create two treatment-based EPMs, AMI medical
management and PCI, because, in the context of our proposed pricing
methodology that sets MS-DRG-specific EPM-episode benchmark prices and
quality-adjusted target prices as discussed in section III.D.4.b.(1).
of this final rule, we believe we can appropriately include
beneficiaries following the two different treatment approaches in the
same EPM without concern that the financial incentives of the EPM are
influencing the treatment choice for beneficiaries.
We appreciate the support of many commenters for the proposed CABG
model. We believe that CABG may play a role for some beneficiaries with
symptomatic CAD, either with or without AMI, because CABG is associated
with lower longer-term rates of major adverse cardiac and
cerebrovascular events in comparison to PCI for certain groups of
patients. As a number of commenters pointed out, multiple other
entities, including states, are testing CABG bundled payment models due
to the variability in costs and outcomes despite robust clinical
guidelines.
In response to those commenters who recommended that the AMI and
CABG models be delayed in order to incorporate known best practices
from the LAN CEP Work Group, we note that the LAN is a public-private
partnership established by the U.S. Department of Health and Human
Services (HHS) to increase the adoption of APMs that promote better
care, smarter spending, and healthier people. The LAN has a voluntary
collaborative structure and its consensus recommendations do not
necessarily reflect the views of its individual participants.
Representatives from CMS, along with representatives from states,
purchasers, providers, commercial payers, and consumers, were active
participants in the CEP Work Group and developed, with input from the
broader LAN network, a set of recommendations that reflect a consensus
view, balancing innovation with current practice to move the health
care delivery system forward. The CEP Work Group full recommendations
have not yet been tested in the market. The LAN CEP Work Group
recommendations and the proposed CMS CABG and AMI EPMs, although
incorporating different design features, both support the
implementation of episode-based payment models for cardiac care. We
anticipate that both the LAN recommendations and the CMS AMI and CABG
models will expand provider experience and expertise regarding the
necessary resources and most effective strategies for providing high
quality, efficient care through episode-based payment models and will
help prepare the market for further adoption of innovative payment
models in the future. Therefore, we believe that best practices for
episode payment models are continuously being identified and refined
based on providers' actual implementation experiences with episode
payment models of various designs. Rather than redesigning the proposed
cardiac care models to conform to the LAN CEP Work Group
recommendations, we look forward to testing the AMI and CABG models
based on the policies included in this final rule and sharing our
evaluation findings with stakeholders to inform other episode payment
models for cardiac care.
We do not agree with MedPAC's conclusion that the proposed AMI and
CABG models do not hold promise because of limited post-acute care
spending in AMI episodes and the high percentage of CABG episode
spending due to the anchor hospitalization in CABG episodes coupled
with the risk of patient selection due to the financial incentives of
the CABG model. While care redesign to improve the efficiency of post-
acute care use may be an obvious strategy to address variation in
episode spending for those episodes, such as SHFFT and LEJR episodes
with high utilization of post-acute care services, AMI and CABG
beneficiaries have substantial episode spending during 90 days post-
discharge from the anchor hospitalization as a result of complications,
further treatment, and ongoing care management of their underlying
chronic conditions. We believe that increased efficiencies in the post-
discharge care and improved care coordination represent a significant
opportunity to improve the quality and reduce the cost of AMI and CABG
episodes.
As commenters pointed out, the cardiac EPMs create some risks of
harm to beneficiaries from patient selection and different treatment
choices EPM participants could adopt based on the financial incentives
under the EPMs, although we believe these concerns are generally
present for every episode payment model that sets a price that Medicare
pays for an episode-of-care. As discussed further in sections III.G.4.
through 6. of this final rule, we will take steps to prevent potential
harm by monitoring for access to care, quality of care, and delayed
care under the EPMs and may take remedial action against EPM
participants if we find evidence that supports concerns in these areas.
In addition, the evaluation as discussed in section IV. of this final
rule will analyze beneficiary outcomes and their relationship to
clinical pathways under the EPMs.
We refer to section III.D.2.a. of this final rule for a discussion
of the comments on the proposed implementation timeline for the AMI and
CABG models and our responses.
Final Decision: After consideration of the public comments
received, we are finalizing the proposal to implement the AMI and CABG
models, with modifications to specific policies as described throughout
this final rule. We refer to section III.D.2.a. of this final rule for
the implementation timeline that applies to the AMI and CABG models.
2. Advanced Alternative Payment Model Considerations
For ease of reading the subsequent sections regarding our proposals
and our final policies around the EPMs as Advanced APMs, we first
present the proposals outlined in the Quality Payment Program proposed
rule (81 FR 28161) followed by the policies outlined in the Quality
Payment Program final rule with comment period (81 FR 77008).
a. Overview for the EPMs
The MACRA created two paths for eligible clinicians to link quality
to payments: The MIPS and Advanced APMs. These two paths create a
flexible payment system called the Quality Payment Program as proposed
by CMS in the Quality Payment Program proposed rule (81 FR 28161
through 28586).
As proposed in the Quality Payment Program proposed rule, an APM
must meet three criteria to be considered an Advanced APM (81 FR
28298). First, the APM must provide for payment for covered
professional services based on quality measures comparable to measures
described under the performance category described in section
1848(q)(2)(B)(i) of the Act,
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which is the MIPS quality performance category. We interpret this
criterion to require the APM to incorporate quality measure results as
a factor when determining payment to participants under the terms of
the APM. Under the Quality Payment Program proposed rule, we proposed
that the quality measures on which the Advanced APM bases payment for
covered professional services (as that term is defined in section
1848(k)(3)(A) of the Act) must include at least one of the following
types of measures, provided that they have an evidence-based focus and
are reliable and valid (81 FR 28302):
Any of the quality measures included on the proposed
annual list of MIPS quality measures.
Quality measures that are endorsed by a consensus-based
entity.
Quality measures developed under section 1848(s) of the
Act.
Quality measures submitted in response to the MIPS Call
for Quality Measures under section 1848(q)(2)(D)(ii) of the Act.
Any other quality measures that CMS determines to have an
evidence-based focus and be reliable and valid.
As we discussed in the Quality Payment Program proposed rule,
because the statute identifies outcome measures as a priority measure
type and we wanted to encourage the use of outcome measures for quality
performance assessment in APMs, we further proposed in that rule that,
in addition to the general quality measure requirements, an Advanced
APM must include at least one outcome measure if an appropriate measure
is available on the MIPS list of measures for that specific QP
Performance Period, determined at the time when the APM is first
established (81 FR 28302 through 28303).
Second, the APM must either require that participating APM Entities
bear risk for monetary losses of a more than nominal amount under the
APM or be a Medical Home Model expanded under section 1115A(c) of the
Act. Except for Medical Home Models, we proposed in the Quality Payment
Program proposed rule that, for an APM to meet the nominal amount
standard, the specific level of marginal risk must be at least 30
percent of losses in excess of expected expenditures; a minimum loss
rate, to the extent applicable, must be no greater than 4 percent of
expected expenditures; and total potential risk must be at least 4
percent of expected expenditures (81 FR 28306).
Third, the APM must require participants to use CEHRT (as defined
in section 1848(o)(4) of the Act), as specified in section
1833(z)(3)(D)(i)(I) of the Act, to document and communicate clinical
care with patients and other health care professionals. Specifically,
where the APM participants are hospitals, the APM must require each
hospital to use CEHRT (81 FR 28298 through 28299).
In the proposed rule (81 FR 50794), we proposed to adopt two
different tracks for the EPMs--Track 1 in which EPMs and EPM
participants would meet the criteria for Advanced APMs as proposed in
the Quality Payment Program proposed rule, and Track 2 in which the
EPMs and EPM participants would not meet those proposed criteria. For
the proposed AMI, CABG, and SHFFT models, we proposed pay-for-
performance methodologies that use quality measures that we believe
would meet the proposed Advanced APM quality measure requirements in
the Quality Payment Program proposed rule. As discussed in sections
III.E.2. and 3. of the proposed rule (81 FR 50794), all but one of the
AMI, CABG, and SHFFT model measures used in the EPM pay-for-performance
methodologies are NQF-endorsed and have an evidence-based focus and are
reliable and valid. Therefore, we believe they would meet the proposed
Advanced APM general quality measure requirements. The Excess Days in
Acute Care after Hospitalization for AMI (AMI Excess Days) measure,
which was proposed for the AMI model, is not currently NQF-endorsed,
but was reviewed, recommended for endorsement, and is expected to be
formally endorsed within the first quarter of 2017. We believe it meets
the measure requirements by having an evidence-based focus and being
reliable and valid because this measure has been proposed and adopted
through rulemaking for use in the Hospital Inpatient Quality Reporting
(HIQR) Program.
Each of the proposed EPM pay-for-performance methodologies included
one outcome measure that is NQF-endorsed, has an evidence-based focus,
and is reliable and valid. The EPM quality measures were discussed in
detail in section III.E. of the proposed rule (81 FR 50794), where we
assigned the quality measures to quality domains. For the AMI model, we
proposed to use the Hospital 30-Day, All-Cause, Risk-Standardized
Mortality Rate (RSMR) Following Acute Myocardial Infarction (NQF #0230)
(MORT-30-AMI) outcome measure. For the CABG model, we proposed to use
the Hospital 30-Day, All-Cause, Risk-Standardized Mortality Rate (RSMR)
Following Coronary Artery Bypass Graft (CABG) Surgery (NQF# 2558)
(MORT-30-CABG) outcome measure. Finally, for the SHFFT model, we
proposed to use the Hospital-level RSCR following elective primary THA
and/or TKA (NQF #1550) (Hip/Knee Complications) outcome measure. Thus,
based on the proposed use of these three outcomes measures in the EPMs,
we believed the proposed AMI, CABG, and SHFFT models would meet the
requirement proposed for Advanced APMs in the Quality Payment Program
proposed rule for use of an outcome measure that also meets the general
quality measure requirements.
In terms of the proposed nominal risk criteria for Advanced APMs,
beginning in performance year 2 for episodes ending between April 1,
2018 and December 31, 2018, we proposed that EPM participants would
begin to bear downside risk for excess actual EPM-episode spending
above the quality-adjusted target price as discussed in section
III.D.2.c. of the proposed rule (81 FR 50794). The marginal risk for
excess actual EPM-episode spending above the quality-adjusted target
price would be 100 percent over the range of spending up to the stop-
loss limit, which would exceed 30 percent marginal risk, and there
would be no minimum loss rate. As a result, we believed the EPMs would
meet the marginal risk and minimum loss rate elements of the nominal
risk criteria for Advanced APMs proposed in the Quality Payment Program
proposed rule. We proposed that total potential risk for most EPM
participants would be 5 percent of expected expenditures beginning in
the second quarter of performance year 2, and increasing in subsequent
performance years as discussed in section III.D.7.b. of the proposed
rule (81 FR 50794). Therefore, in the proposed rule, we stated our
belief that the total proposed potential risk applicable to most EPM
participants, with the lowest total potential risk being 5 percent for
EPM episodes ending on or after April 1, 2018 in performance year 2,
would meet the total potential risk element of the nominal risk amount
standard for Advanced APMs proposed in the Quality Payment Program
proposed rule because it was greater than the value of at least 4
percent of expected expenditures.
We note that we proposed that EPM participants that are rural
hospitals, sole community hospitals (SCHs), Medicare Dependent
Hospitals (MDHs) and Rural Referral Centers (RRCs) would have a stop-
loss limit of 3 percent beginning in the second quarter of performance
year 2 as discussed in section III.D.7.c. of the proposed rule (81 FR
50794). Because 3 percent was less than the proposed
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threshold of at least 4 percent of expected expenditures for total
potential risk proposed for Advanced APMs in the Quality Payment
Program proposed rule, those rural hospitals, SCHs, MDHs, and RRCs that
are EPM participants subject to special protections would be in Track 2
EPMs that would not meet the proposed nominal risk standard for
Advanced APMs for performance year 2. We recognized that this proposal
might initially limit the ability of rural hospitals, SCHs, MDHs, and
RRCs to be in Track 1 EPMs that are Advanced APMs. In the proposed
rule, we explained our belief that this potential limitation on rural
hospitals, SCHs, MDHs, and RRCs is appropriate for the following
reasons: (1) Greater risk protections for these hospitals proposed for
the EPMs beginning in the second quarter of performance year 2 and
subsequent performance years compared to other EPM participants are
necessary, regardless of their implications regarding Advanced APMs
based on the nominal risk standard proposed in the Quality Payment
Program proposed rule, because these hospitals have unique challenges
that do not exist for most other hospitals, such as being the only
source of health care services for beneficiaries or certain
beneficiaries living in rural areas or being located in areas with
fewer providers, including fewer physicians and post-acute care
facilities; and (2) under the risk arrangements proposed for the EPMs,
these hospitals would not bear an amount of risk in performance year 2
that we determined to be more than nominal in the Quality Payment
Program proposed rule. However, we sought comment on whether we should
allow EPM participants that are rural hospitals, SCHs, MDHs, or RRCs to
elect a higher stop-loss limit for the part of performance year 2 where
downside risk applies in order to permit these hospitals to be in Track
1 EPMs for that part of performance year 2. We noted that by
performance year 3, the stop-loss limit for these hospitals with
special protections under the EPMs would increase to 5 percent under
our proposal, so these hospitals could be in Track 1 EPMs based on the
nominal risk standard proposed in the Quality Payment Program proposed
rule.
As addressed in the Quality Payment Program proposed rule, it would
be necessary for an APM to require the use of CEHRT in order to meet
the criteria to be considered to be an Advanced APM. Therefore,
according to the requirements proposed in the Quality Payment Program
proposed rule, so that the EPMs may meet the proposed criteria to be
Advanced APMs, we proposed to require EPM participants to use CEHRT (as
defined in section 1848(o)(4) of the Act) to participate in Track 1 of
the EPMs. We proposed that Track 1 EPM participants must use certified
health IT functions, in accordance with the definition of CEHRT under
our regulation at Sec. 414.1305 (81 FR 77537), to document and
communicate clinical care with patients and other health care
professionals as proposed in the Quality Payment Program proposed rule
(81 FR 28299). We believed this proposal would allow Track 1 EPMs to be
able to meet the proposed criteria to be Advanced APMs.
Without the collection of identifying information on eligible
clinicians (physicians, non-physician practitioners, physical and
occupational therapists, and qualified speech-language pathologists)
who would be considered Affiliated Practitioners as proposed in the
Quality Payment program proposed rule under the EPMs, CMS would not be
able to consider participation in the EPMs in making determinations as
to whom could be considered a QP (81 FR 28320). As detailed in the
Quality Payment Proposed rule, these determinations are based on
whether the eligible clinician meets the QP threshold under either the
Medicare Option starting in payment year 2019 or the All-Payer
Combination Option, which is available starting in payment year 2021
(81 FR 28165). Thus, we made proposals in the following sections to
specifically address these issues that might otherwise preclude the
EPMs from being considered Advanced APMs, or prevent us from
operationalizing them as Advanced APMs. Based on the proposals for
Advanced APM criteria in the Quality Payment Program proposed rule, we
sought to align the design of the proposed EPMs with the proposed
Advanced APM criteria and enable CMS to have the necessary information
on eligible clinicians to make the requisite QP determinations.
For ease of reading the subsequent sections regarding our proposals
and final policies for the EPMs as Advanced APMs, we present the
following definitions from Sec. 414.1305 that have now been finalized
in the Quality Payment Program final rule with comment period (81 FR
77008).
Alternative Payment Model (APM) means any of the following: (1) A
model under section 1115A of the Act (other than a health care
innovation award); (2) The shared savings program under section 1899 of
the Act; or (3) A demonstration under section 1866C of the Act. (4) A
demonstration required by federal law.
Episode payment model means an APM or other payer arrangement
designed to improve the efficiency and quality of care for an episode
of care by bundling payment for services furnished to an individual
over a defined period of time for a specific clinical condition or
conditions.
APM Entity means an entity that participates in an APM or payment
arrangement with a non-Medicare payer through a direct agreement or
through Federal or State law or regulation.
Advanced Alternative Payment Model (Advanced APM) means an APM that
CMS determines meets the criteria set forth in Sec. 414.1415.
Advanced APM Entity means an APM Entity that participates in an
Advanced APM or Other Payer Advanced APM.
Participation List means the list of participants in an APM Entity
that is compiled from a CMS-maintained list.
Eligible Clinician means ``eligible professional'' as defined in
section 1848(k)(3) of the Act, as identified by a unique TIN and NPI
combination and, includes any of the following: (1) A physician; (2) A
practitioner described in section 1842(b)(18)(C) of the Act; (3) A
physical or occupational therapist or a qualified speech language
pathologist; or (4) A qualified audiologist (as defined in section
1861(ll)(3)(B) of the Act).
Affiliated Practitioner means an eligible clinician identified by a
unique APM participant identifier on a CMS-maintained list who has a
contractual relationship with the Advanced APM Entity for the purposes
of supporting the Advanced APM Entity's quality or cost goals under the
Advanced APM.
Affiliated Practitioner List means the list of Affiliated
Practitioners of an APM Entity that is compiled from a CMS-maintained
list.
Qualifying APM Participant (QP) means an eligible clinician
determined by CMS to have met or exceeded the relevant QP payment
amount or QP patient count threshold under Sec. 414.1430(a)(1),
(a)(3), (b)(1), or (b)(3) for a year based on participation in an
Advanced APM Entity.
QP Patient Count Threshold means the minimum threshold score
specified in Sec. 414.1430(a)(3) and (b)(3) that an eligible clinician
must attain through a patient count methodology described in Sec. Sec.
414.1435(b) and 414.1440(c) to become a QP for a year.
QP Payment Amount Threshold means the minimum threshold score
specified in Sec. 414.1430(a)(1) and (b)(1) that an eligible clinician
must attain through the payment amount methodology described in
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Sec. Sec. 414.1435(a) and 414.1440(b) to become a QP for a year.
Threshold Score means the percentage value that CMS determines for
an eligible clinician based on the calculations described in Sec.
414.1435 or Sec. 414.1440.
Merit-based Incentive Payment System (MIPS) means the program
required by section 1848(q) of the Act.
MIPS APM means an APM that meets the criteria specified under Sec.
414.1370(b).
Improvement Activities means an activity that relevant MIPS
eligible clinicians, organizations and other relevant stakeholders
identify as improving clinical practice or care delivery and that the
Secretary determines, when effectively executed, is likely to result in
improved outcomes.
Based on the proposals for Advanced APM criteria in the Quality
Payment Program proposed rule (81 FR 28161), we sought to align the
design of the proposed EPM Advanced APM track with the proposed
Advanced APM criteria and enable CMS to have the necessary information
on Eligible Clinicians to make the requisite QP determinations. As
detailed in the Quality Payment Program final rule with comment period,
QP determinations are based on whether the Eligible Clinician meets the
QP threshold under either the Medicare Option starting in payment year
2019 or the All-Payer Combination Option, which is available starting
in payment year 2021 (81 FR 77013). Eligible clinicians seeking QP
determinations as early as performance year 2 would need to meet the QP
threshold under the Medicare Option. The three criteria for an Advanced
APM were finalized in the Quality Payment Program final rule with
comment period (81 FR 77008), and we continue to align the design of
the finalized EPMs with the finalized Advanced APM criteria so that EPM
participants who choose to use and attest to use of CEHRT may
participate in an EPM that meets the criteria of an Advanced APM. To be
determined to be an advanced APM, an APM must meet three Advanced APM
criteria identified in Sec. 414.1415 and discussed specifically later
in this section.
First, the APM must require participants to use CEHRT (as defined
in section 1848(o)(4) of the Act), as specified in section
1833(z)(3)(D)(i)(I) of the Act, to document and communicate clinical
care with patients and other health care professionals (81 FR 77406).
Specifically, where the APM participants are hospitals, the APM must
require each hospital to use CEHRT. As addressed in the Quality Payment
Program final rule with comment period, it is necessary for an APM to
require the use of CEHRT in order to meet the criteria to be considered
to be an Advanced APM. Therefore, according to the requirements now
finalized in the Quality Payment Program final rule with comment
period, so that the EPMs may meet the finalized criteria to be Advanced
APMs, we proposed that those EPM participants who choose to participate
in Track 1 of the EPMs must use certified health IT functions, in
accordance with the definition of CEHRT under our regulation at 42 CFR
414.1305, to document and communicate clinical care with patients and
other health care professionals. We believe that this proposal set
forth in the EPM proposed rule would allow EPM participants who use and
attest to use of CEHRT to be in an EPM that meets the first finalized
Advanced APM criterion.
Second, the APM must provide for payment to participants based on
performance on quality measures comparable to measures described under
the performance category described in section 1848(q)(2)(B)(i) of the
Act, which is the MIPS quality performance category. We interpret this
criterion to require the APM to incorporate quality measure results as
a factor when determining payment to participants under the terms of
the APM as described in the Quality Payment Program final rule with
comment period (81 FR 77414). In order to align the EPMs with the
Quality Payment Program final rule with comment period, the quality
measures on which the Advanced APM bases payment to participants must
include at least one of the following types of measures, provided that
they have an evidence-based focus and are reliable and valid (81 FR
77418):
Any of the quality measures included on the proposed annual list of
MIPS quality measures.
Quality measures that are endorsed by a consensus-based entity.
Quality measures developed under section 1848(s) of the Act.
Quality measures submitted in response to the MIPS Call for Quality
Measures under section 1848(q)(2)(D)(ii) of the Act.
Any other quality measures that CMS determines to have an evidence-
based focus and be reliable and valid.
As we discussed in the Quality Payment Program final rule with
comment period, because the statute identifies outcome measures as a
priority measure type and we want to encourage the use of outcome
measures for quality performance assessment in APMs, we further
finalized in that rule that, in addition to the general quality measure
requirements, an Advanced APM must include at least one outcome measure
if an appropriate measure is available on the MIPS list of measures for
that specific QP Performance Period, determined at the time when the
APM is first established (81 FR 77418). Therefore, according to the
requirements finalized in the Quality Payment Program final rule with
comment period and the quality measures finalized in section III.E of
this final rule that are the proposed EPM quality measures with an
additional voluntary measure for the CABG model, the EPMs will meet the
second finalized criterion of the Advanced APM criteria.
Third, the Quality Payment Program final rule with comment period
requires that for an APM to meet the Advanced APM criteria, the APM
must either require that participating APM Entities bear risk for
monetary losses of a more than nominal amount under the APM or be a
Medical Home Model expanded under section 1115A(c) of the Act. For the
purposes of the EPM, the generally applicable nominal amount standard
for an Advanced APM in the Quality Payment Program final rule with
comment period (81 FR 77425) means the total amount an APM Entity
potentially owes CMS or foregoes under an APM must be at least equal to
3 percent of the expected expenditures for which an APM Entity is
responsible under the APM. The generally applicable financial risk
standard (81 FR 77422) means when an APM Entity's actual expenditures
for which the APM Entity is responsible under the APM exceed expected
expenditures during a specified QP Performance Period, the APM Entity
is required to owe payment(s) to CMS. We refer to the Quality Payment
Program final rule with comment period for a discussion regarding why
we did not finalize the specific level of marginal risk or minimum loss
rate (81 FR 77426). However, consistent with the commitments we made to
adhere to the proposed marginal risk and minimum loss rate requirements
in the Quality Payment Program proposed rule, we note that the
financial risk in this final rule when the EPMs involve downside risk
exceeds the proposed marginal risk and minimum loss rate requirements
proposed for the Quality Payment Program. As discussed in sections
III.D.7.b. and c. and displayed in Table 12 of this final rule, the
final total initial risk of expected expenditures for EPM participants
of 5 percent, and 3 percent for rural hospitals, SCHs, MDHs, RRCs,
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and EPM volume protection hospitals subject to separate stop-loss
protections, beginning in performance year 3 when downside risk for all
participants first applies, would meet the total potential risk element
of the nominal risk amount standard for Advanced APMs finalized in the
Quality Payment Program final rule with comment period (81 FR 77427)
because they are greater than or equal to the value of at least 3
percent of expected expenditures. Those EPM participants who elect
voluntary downside risk beginning in performance year 2 will be subject
to the same total risk of expected expenditures in performance year 2
and, therefore, will be in an EPM that meets the total potential risk
element of the nominal risk amount standard for Advanced APMs beginning
in performance year 2. Therefore, according to the requirements
finalized in the Quality Payment Program final rule with comment period
and the payment methodology for EPM participants finalized in section
III.D of this final rule, those EPM participants who voluntarily elect
downside risk for EPM episodes ending on or after January 1, 2018 will
be in an EPM that meets the third finalized criterion of the Advanced
APM criteria in performance year 2. All other EPM participants will be
in an EPM that meets the third finalized criterion of the Advanced APM
criteria in performance year 3.
Finally, we finalized in the Quality Payment Program final rule
with comment period (81 FR 77442) that for Advanced APMs, such as
episode payment models, in which there are some Advanced APM Entities
that include Eligible Clinicians on a Participation List and other
Advanced APM Entities that identify Eligible Clinicians only on an
Affiliated Practitioner List, we will identify Eligible Clinicians for
QP determinations based on the composition of the Advanced APM Entity.
In the scenario that applies to the EPM which includes only hospitals
as Advanced APM Entities on the Participation List, for those Advanced
APM Entities where there is an Affiliated Practitioner List that
identifies Eligible Clinicians, that Affiliated Practitioner List will
be used to identify the Eligible Clinicians for purposes of QP
determinations, and those Eligible Clinicians will be assessed
individually. Thus, to operationalize the EPM as an Advanced APM, our
proposal for the EPM to identify Eligible Clinicians on a clinician
financial arrangements list to construct the Affiliated Practitioner
list would identify those Eligible Clinicians for purposes of QP
determination, consistent with the policies finalized in the Quality
Payment Program final rule with comment period.
We received a number of public comments on our proposals for the
EPMs as Advanced APMs. A few commenters requested changes to the
policies proposed by CMS in the Quality Payment Program proposed rule
and not to specific proposals for the EPMs set forth in the EPM
proposed rule. These comments are out of scope for this rulemaking and
no responses are provided in this final rule. Nevertheless, we have
summarized this feedback related to the Quality Payment Program
proposed rule, as CMS will continue work to improve the Quality Payment
Program in part through future notice and comment rulemaking.
One commenter requested change to the definition of Affiliated
Practitioner to include rehabilitation therapists. Many commenters
requested changes to the definitions of the Affiliated Practitioner
List and/or Participation List to identify Eligible Clinicians for the
purposes of Advanced APMs, MIPS APMs, and the assignment by CMS of an
Improvement Activities score, which fulfills one of four categories for
MIPS assessment of cost and quality. Another commenter requested
changes to the performance period or the December 31 date by which an
Eligible Clinician could qualify for automatic credit for incentive
payment and/or clinical Improvement Activities performance. This
commenter reasoned that such changes would permit more Eligible
Clinicians to receive a QP determination, which may qualify them for an
APM incentive payment under MACRA. One commenter expressed uncertainty
regarding the process by which Eligible Clinicians could receive a QP
determination for the efforts of the EPM participant, and requested
that CMS clarify on the pathway for participating physicians to be in
an Advanced APM generally. Another commenter suggested CMS replace the
QP determination with the proposal that, for EPM providers who meet the
CEHRT use requirement and have 50 or more Medicare beneficiaries
attributed to these EPMs, the threshold for Advanced APMs would be met
automatically. A few commenters wanted CMS to use the Meaningful Use
program to gather attestation to CEHRT use from hospitals. A few
commenters strongly recommended CMS lower the patient count and payment
revenue thresholds used in the calculation of the Threshold Score to
meet QP Threshold Status as specified in the Quality Payment Program
proposed rule. Many commenters urged CMS to work closely with the
affected professional organizations and/or physician specialty
societies to design QP thresholds. One commenter requested changes to
the APM Entity such that the APM Entity lose the right to all or part
of otherwise guaranteed payment or payments as one of the options if
the APM Entity's actual aggregate expenditures exceed expected
aggregate expenditures. A few commenters requested changes to the
categorical exclusion that Medicare Advantage (MA) and other private
plans paid to act as insurers on the Medicare program's behalf are not
Advanced APMs, in light of the amount of risk taken by physicians in
MA. Finally, one commenter requested changes to the allow Independence
at Home participants who use CEHRT to qualify for Advanced APM
incentive payments.
The following is a summary of the comments received on our
proposals and our responses.
Comment: MedPAC commented that the EPM and CJR models should not be
considered Advanced APMs for the purposes of MACRA. MedPAC stated they
believe the following six principles should apply to Advanced APMs: the
Advanced APM entity should assume the financial risk and enroll
clinicians; be at financial risk for total Part A and Part B spending;
be responsible for a beneficiary population sufficiently large to
detect changes in spending and quality; have the ability to share
savings with beneficiaries; be provided certain regulatory relief by
CMS; and the enrolled clinicians should receive an incentive payment
only if the Advanced APM entity in which they participate is successful
in controlling cost, improving quality, or both. Under the proposed
EPMs, MedPAC believes the proposed rule contemplates large, loosely
connected groups of clinicians who may have very little involvement
with the beneficiaries in EPMs and hence have little reason to change
their practice patterns or reduce inappropriate episodes. If CMS
intends for clinicians to bear risk, MedPAC made the alternative
proposal that they could do so directly without having the hospital as
the intermediary.
Response: While we appreciate the principles for Advanced APMs
offered by MedPAC, we note that according to the Advanced APM
definition in the Quality Payment Program final rule with comment
period (81 FR 77008), the Track 1 EPMs that we proposed qualify as
Advanced EPMs as discussed previously in this section.
While we recognize EPM participants are the participating APM
Entities for
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the purposes of the Quality Payment Program, CMS will consider
participation of Eligible Clinicians in the Track 1 EPMs through
collection of identifying information from Track 1 EPM participants on
clinician financial arrangements lists as discussed in section
III.A.2.c. of this final rule who would then be included on the
Affiliated Practitioner List as defined in the Quality Payment Program
final rule with comment period at Sec. 414.1305 (81 FR 77537), in
order to determine who could be considered a QP. The requirements for
Eligible Clinicians to be reported on the clinician financial
arrangements lists help ensure that these clinicians have specific
involvement in caring for EPM beneficiaries and advancing the goals of
the EPMs to improve the quality and reduce the cost of care. Finally,
Eligible Clinicians can only be considered Qualifying Professionals or
Partial Qualifying Professionals and, therefore, potentially be exempt
from MIPS, if the Eligible Clinician meets the QP threshold or partial
QP threshold as described in the Quality Payment Program final rule
with comment period (81 FR 77433). Additionally, while we recognize the
concerns with EPM participants or CJR participant hospitals
intermediating the APM incentive payments, we believe that the QP
threshold incentivizes Eligible Clinicians to work with such
participants to improve health care delivery for Medicare
beneficiaries.
The qualification of the CJR model as an Advanced APM is discussed
in section V.O. of this final rule.
Comment: Many commenters expressed support for all organizations to
have the opportunities to participate as Advanced APMs and noted that
as proposed, rural hospitals, SCHs, MDHs, and RRCs that are EPM
participants would not potentially qualify for participation in an
Advanced APM until performance year 3 due to the proposed lower stop-
loss limits for these hospitals under the EPMs. Additionally, one
commenter recommended that a distinct CEHRT program be developed and
funding be allocated for non-physician and non-prescribing
professionals as soon as possible, as the cost of acquisition,
implementation, and maintenance of an EHR is a significant barrier to
adoption, particularly for small practices. One commenter observed this
proposal as an important illustration of why CMS must be flexible in
its definition of nominal risk, and how nominal will not mean the same
thing for every provider. As such, commenters supported retention of
the proposed stop-loss limits under the EPMs as the default rule for
these hospitals, thus enabling them to meet the nominal financial risk
standard for Track 1 EPMs (Advanced APMs) in performance year 3 rather
than performance year 2 when other EPM participants would be eligible
for Track 1 EPMs. However, commenters also believe CMS should also
explore options to allow these hospitals with additional stop-loss
protection under the EPMs to voluntarily elect a higher stop-loss limit
in order to participate in Track 1 EPMs in performance year 2.
Response: The Quality Payment Program final rule with comment
period (81 FR 77427) finalized the policy that an APM would meet the
nominal amount standard for an Advanced APM if, under the terms of the
APM, the total annual amount that an APM Entity potentially owes us or
foregoes is equal to at least 3 percent of the expected expenditures
for which an APM Entity is responsible under the APM. Therefore, rural
hospitals, SCHs, MDHs, RRCs, as well as EPM volume protection hospitals
as discussed in section III.D.7.c of this final rule, that are EPM
participants with special stop-loss limits could potentially qualify as
being in an Advanced APM as participants in a Track 1 EPM in
performance year 3, along the same timeframe as all other EPM
participants when downside risk for all participants is implemented, or
in performance year 2 when voluntary downside risk may be elected by
EPM participants (section III.D.2.c. of this final rule), based on the
stop-loss limits finalized in this rule for these hospitals as
discussed in section III.D.7.c. of this final rule.
Comment: Commenters proposed alternative processes by which a QP
determination could be made, including collective assessment of QP
status across both the AMI and CABG models, so as not to create siloed
EPMs. In cases where there is an overlap of beneficiaries in more than
one CMS model or program, other commenters proposed that beneficiaries
should be counted toward a physician's QP Threshold Score (a part of a
QP determination) if a beneficiary would have been assigned to a
particular model if it were not for the fact that a different model
that has required participation overlapped.
Response: The QP determination discussed in the Quality Payment
Program final rule with comment period depends on the level of payments
or patients furnished services through an Advanced APM based on the
calculations described in Sec. 414.1435 and Sec. 414.1440, as
applicable. Under certain Advanced APMs such as a Track 1 EPM, the
responsibility of cost and quality measurement and reporting is with
EPM participants that are hospitals rather than Eligible Clinicians.
However, we have specified that Eligible Clinicians who are on
Affiliated Practitioner Lists may also be assessed for a QP
determination based on their Affiliated Practitioner status if there
are no eligible clinicians on an Advanced APM's Participation List.
Therefore, as finalized in the Quality Payment Program final rule with
comment period (81 FR 77443), if an Eligible Clinician participates in
multiple Advanced APM Entities during a QP Performance Period, and is
not determined to be a QP based on participation in any of those
Advanced APM Entities, then we will assess the Eligible Clinician
individually using combined information for services associated with
that individual's NPI and furnished through all the Eligible
Clinician's Advanced APM Entities during the QP Performance Period.
This includes all Advanced APM Entities for which the Eligible
Clinician is represented on either a Participation List or Affiliated
Practitioner List that CMS uses for QP determinations. We will make
adjustments to ensure that patients and payments for services that may
be counted in the QP calculations for multiple Advanced APM Entities
(for example, payments for services furnished to a beneficiary
attributed to an ACO that are also part of an episode in an episode
payment model) are not double-counted for the individual. We believe
that this policy maintains the general principles behind Advanced APM
Entity-level QP determinations, while acknowledging the broader
commitment of individual Eligible Clinicians who are participating in
multiple Advanced APMs. We believe considering these Eligible
Clinicians individually is the most reasonable approach to capturing
the multiple potential permutations of participation in Advanced APMs
and providing Eligible Clinicians an equitable opportunity to become a
QP.
Thus, with respect to the commenters' concerns that CMS would only
make a model-specific QP determination for the Track 1 AMI model and
Track 1 CABG model and not a collective determination across the two
models, for Advanced APMs for which there is not a Participation List
that identifies eligible clinicians and there is an Affiliated
Practitioner List that identifies eligible clinicians, the Quality
Payment Program final rule with comment period (81 FR 77442) notes that
Affiliated Practitioner List will be
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used to identify the eligible clinicians for purposes of QP
determinations. Eligible clinicians on an Affiliated Practitioner List
will be assessed individually, unlike eligible clinicians on a
Participation List who are assessed as a group. Thus, we could make a
determination across the two models if an Eligible Clinician was not
determined to be a QP based on participation in any one of the Track 1
EPMs. Finally, as specified in the Quality Payment Program final rule
with comment period (81 FR 77013), QPs are Eligible Clinicians in an
Advanced APM who have a certain percentage of their patients or
payments through an Advanced APM. Thus, we will only count
beneficiaries attributed to an Advanced APM Entity toward a clinician's
QP Threshold Score and will not count those beneficiaries who would
have been attributed to an Advanced APM Entity if it were not for the
fact that a different model overlapped. Beneficiary attribution is
further discussed in the Quality Payment Program final rule with
comment period (81 FR 77436)
b. EPM Participant Tracks
To be considered an Advanced APM, the APM must require participants
to use CEHRT (as defined in section 1848(o)(4) of the Act), as
specified in section 1833(z)(3)(D)(i)(I) of the Act. We proposed that
all EPM participants must choose whether to meet the CEHRT use
requirement. EPM participants that do not choose to meet and attest to
the CEHRT use requirement would be in Track 2 of the EPMs. EPM
participants selecting to meet the CEHRT use requirement would be in
Track 1 of the EPMs and would be required to attest in a form and
manner specified by CMS to their use of CEHRT that meets the definition
in our regulation at Sec. 414.1305 (81 FR 77537) to document and
communicate clinical care with patients and other health professionals,
consistent with the proposal in the Quality Payment Program proposed
rule for the CEHRT requirement for Advanced APMs (81 FR 28299). EPM
participants choosing not to meet and attest to the CEHRT use
requirement would not be required to submit an attestation.
We believe that the voluntary selection by EPM participants to
elect downside risk for EPM episodes ending on or after January 1,
2018, and to meet and attest to the CEHRT use requirement would create
no significant additional administrative burden on EPM participants.
Moreover, the choice of whether to meet and attest to the CEHRT use
requirement would not otherwise change any EPM participant's
requirements or opportunity under the EPM. However, to the extent that
eligible clinicians who enter into financial arrangements related to
EPM participants in the Track 1 EPM are considered to furnish services
through an Advanced APM, those services could be considered for
purposes of determining whether the eligible clinicians are QPs.
The proposals for CEHRT use and attestation for EPM participants
were included in proposed Sec. 512.120(a). We sought comment on our
proposals for EPM participant CEHRT use requirements.
The following is a summary of the comments received and our
responses.
Comment: Commenters expressed appreciation for CMS' efforts to
expand the Advanced APM participation opportunities as they commented
that the 5 percent Advanced APM incentive payment is time-limited under
current law. They applauded the proposal to expand the list of eligible
Advanced APMs through Track 1 EPMs as it provides an incentive for
physicians to collaborate with hospital participants in the EPM and
could provide specialists, who otherwise may have limited avenues, to
participate in an Advanced APM. Other commenters requested specifically
that CMS clarify the steps necessary when a provider group wishes to
change from Track 2 to Track 1 in the EPMs.
Response: We appreciate the commenters' support for our proposal of
the Track 1 EPMs as Advanced APMs and agree that providing greater
opportunities for physician participation in Advanced APMs is an
important goal that can be advanced through our proposal. We remind
commenters that only the EPM participant can choose to participate in a
Track 1 EPM by using and attesting to use of CEHRT. If Eligible
Clinicians enter into a financial arrangement associated with a Track 1
EPM participant, then the EPM participant must submit a clinician
financial arrangements list that determines the Eligible Clinicians to
be included on the Affiliated Practitioner List for the purposes of the
Track 1 EPM that is an Advanced APM. Therefore, a provider group
interested in their members becoming Affiliated Practitioners with an
Advanced EPM Entity in an Advanced APM could work with a Track 1 EPM
participant to enter into a financial arrangement with that EPM
participant so that the members of the provider group could be included
in the clinician financial arrangements list submitted by the Track 1
EPM participant to CMS.
Comment: While commenters appreciated the proposal to include two
tracks for EPM participants and CJR participant hospitals, other
commenters made additional proposals to CMS to help operationalize
these tracks. A few commenters urged CMS to go further to align the
EPMs and the CJR model with the proposed Quality Payment Program and
configure Track 2 (the Non-Advanced APM) so that it could qualify as a
MIPS APM. In addition to the request that CMS reconfigure Track 2,
commenters also proposed that Track 2 EPM participants must also submit
a clinician financial arrangements list, so that Eligible Clinicians
could receive credit for Improvement Activities under MIPS and/or
satisfy criteria to be considered participants in MIPS APMs, for which
the Quality Payment Program applies unique scoring rules. One commenter
believes that the multiple options due to the proposed tracks increases
the level of complexity and administrative burden on the hospitals for
activities such as record keeping.
Response: We disagree that the presence of two EPM tracks increases
administrative burden as we continue to believe that the proposed
tracks allow flexibility for EPM participants to choose to participate
in an Advanced APM. While a Track 1 EPM participant needs to attest to
CEHRT and submit a clinician financial arrangements list to meet the
requirements for participation in an Advanced APM and allow us to
operationalize the Track 1 EPM as an Advanced APM, we do not believe
that these additional requirements create significantly increased
administrative burden on the Track 1 EPM participant versus a Track 2
EPM participant in view of the documentation and record access and
retention requirements for all EPM participants, which require EPM
participants to maintain a subset of that list that constitutes the
Eligible Clinicians, nor that the requirements to identify and maintain
related lists regarding collaboration agents and downstream
collaboration agents is a substantial burden. Beyond these additional
activities for Track 1 EPM participants, the policies of the EPMs are
the same for Track 1 and Track 2 EPM participants.
In addition, we disagree with the suggestion by commenters that we
add the requirement for Track 2 EPM participants to submit to CMS
clinician financial arrangements lists, information that we did not
propose to require Track 2 EPM participants to submit to us. Submission
of clinician financial arrangements lists is not necessary for
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implementation of the Track 2 EPMs, and Track 2 EPM participants do not
meet the definition of Advanced APM Entities in the Quality Payment
Program final rule with comment period at Sec. 414.1305 (81 FR 77537).
To require Track 2 EPM participants to submit such a list would create
unnecessary additional administrative burden on these participants.
Furthermore, a Track 2 EPM does not meet the criteria of a MIPS APM in
Sec. 414.1370(b) of the Quality Payment Program final rule with
comment period. Specifically, the MIPS APM criteria requires at least
one Eligible Clinician on a Participation List for the APM, while
currently all EPM and CJR participants are hospitals. Thus, the EPM and
CJR Participation Lists do not include Eligible Clinicians and,
therefore, a Track 2 EPM and the Track 2 CJR model are not MIPS APMs.
As a result, EPM or CJR collaborators, collaboration agents, and
downstream collaboration agents are not engaged with Track 2 EPM
participants or Track 2 CJR participant hospitals in a MIPS APM.
Therefore, we will not adopt a requirement in regulation for Track 2
EPM participants or Track 2 CJR participant hospitals to submit
clinician financial arrangements lists at this time.
We agree with commenters that we should continue to consider
whether there are opportunities for additional APMs, including episode
payment models, to become MIPS APMs. We will continue to consider the
balance in models between the most appropriate, streamlined model
design for the intended model participants to advance the goals of the
model and the requirements for models to be MIPS APMs or Advanced APMs
as we strive to create more opportunities for Eligible Clinicians to
participate in MIPS APMs and Advanced APMs.
Comment: Commenters urged CMS to consider reversing the proposed
Track 1 and Track 2 designations to represent an APM and Advanced APM,
respectively, or identifying an alternative naming convention as the
term ``tracks'' are already used in the Shared Savings Program.
Response: We appreciate the perspective of the commenters but
believe that our proposed designations of a Track 1 EPM as an Advanced
APM and a Track 2 EPM as a Non-Advanced APM under the EPMs are
straightforward and appropriate for the distinctions we make between
Advanced and Non-Advanced EPMs. The track designations for the EPMs are
relevant to the EPM participants in the specific track of the EPM and
the individuals and entities that have financial arrangements under the
EPMs. We never intend to refer solely to the term Track 1 or Track 2 in
the context of the EPMs but always in combination with the term EPM as
a Track 1 EPM or Track 2 EPM. Therefore, we do not believe that Track 1
EPMs or Track 2 EPMs will be confused with tracks in the Shared Savings
Program. We will be working closely with EPM participants and other
stakeholders during EPM implementation to explain the various
requirements of the EPMs in general and the tracks of the EPMs in
particular.
Comment: Additional proposals were submitted by commenters that
encouraged CMS to work further by creating additional tracks, including
a MIPS APM track and accommodating those that may wish to accept
financial risk sooner in order to qualify as an Advanced APM.
Commenters believe CMS should continue to develop pathways and provide
assistance to organizations who wish to develop or become participants
in Advanced APMs; and to expand beyond the current inpatient-based
episode payment model tracks to include not only a physician-focus but
also a focus that meaningfully incorporates additional roles and
activities, for example, specialty service providers, rehabilitation
therapy providers, BPCI early adopters, home health care, and
transitional care.
Response: We appreciate the suggestions of commenters. We respond
earlier in this section on requests for additional MIPs APMs and for
voluntary election of early increased downside risk to allow rural
hospitals, SCHs, MDHs, and RRCs with special stop-loss limits under the
EPMs to be in a Track 1 EPM at the same time as other EPM participants
without special stop-loss limits under the EPM. We will continue our
efforts to develop pathways and provide assistance to organizations who
wish to develop or become participants in Advanced APMs. We refer the
commenters to section III.A.3 of this final rule for additional
considerations for future EPMs.
Comment: Commenters expressed appreciation for the proposed
alignment resulting from use of the same definition of CEHRT across the
EPM and Quality Payment Program, and acknowledged that CMS' proposal to
permit those EPM participants who do not use CEHRT to be in a different
track of the EPM offers appropriate flexibility. A few commenters
requested that CMS consider using a process through the Medicare EHR
Incentive Program to gather the attestations from the hospitals.
Response: We appreciate the recognition from commenters of CMS'
efforts to utilize the flexibilities of the Quality Payment Program for
Eligible Clinicians to link quality to payments through meaningful
participation in an Advanced APM.
We also appreciate the suggestions by the commenters about existing
processes and information CMS might use to streamline CEHRT use
attestation for EPM participants in Track 1 EPMs. We reiterate that EPM
participants choose to attest to CEHRT use and submit a clinician
financial arrangements list beginning in performance year 3 and,
therefore, be a Track 1 EPM participant (or elect voluntary downside
risk in performance year 2, attest to CEHRT use, and submit a clinician
financial arrangements list, and therefore, be a Track 1 EPM
participant beginning in performance year 2), or choose not to attest
to CEHRT use and be a Track 2 EPM participant. We will consider the
feedback from commenters on CEHRT attestation methodologies as we
develop the operational information for EPM participants about EPM
processes and procedures. We further note that CMS and ONC also offer
continued support and guidance through educational resources to support
participating in and reporting CEHRT use to CMS models and programs,
such as the EHR Incentive Program. We will communicate closely with EPM
participants about the form and manner of attestation to CEHRT use for
Track 1 EPMs early in the process of EPM implementation.
Comment: Many commenters urged CMS to consider the significant
upfront investments in health IT infrastructure that providers must
make to participate and be successful in the Quality Payment Program
and EPMs or CJR model, given that, as one commenter stated, this
investment exists even in upside-only models. As a result, these
commenters recommended that CMS consider permitting EPM participants to
be Advanced APM Entities in performance year 1 and/or that entry into
Track 1 for EPM participants and CJR participant hospitals begin as
soon as possible. Other commenters pointed out the lack of resources/
support for Eligible Clinicians, such as therapists, to adopt EHRs. The
commenters believe that Eligible Clinicians participating in an
Advanced APM where the Advanced APM Entity is a hospital must also use
and attest to use of CEHRT, and further stated that such a requirement
would put these professionals at a significant disadvantage. To this
end, a few commenters requested that CMS clarify whether the CEHRT
requirement only applies to the hospitals that are EPM
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participants and whether Eligible Clinicians who have entered into
sharing arrangements as EPM collaborators will potentially meet the
requirements to attest to use of CEHRT for participating in an Advanced
APM under the Quality Payment Program.
Response: Like the commenters, we appreciate the important role
health IT may play in meeting the goals of Advanced APMs, including
Track 1 EPMs, to improve the quality and reduce the cost of care. As a
result of the Quality Payment Program final rule with comment period
(81 FR 28306), in order for an APM to be considered an Advanced APM,
the APM must either require that participating APM Entities bear risk
for monetary losses of a more than nominal amount under the APM or be a
Medical Home Model expanded under section 1115A(c) of the Act. As a
result of this final rule, a Track 1 CJR participant hospital will be
considered to be participating in an Advanced APM, and could qualify as
an Advanced APM Entity beginning in performance year 2 for episodes
ending on or after January 1, 2017, the time at which CJR participant
hospitals would begin to bear downside risk for excess actual CJR
episode spending above the quality-adjusted target price. Track 1 EPM
participants will be considered to be participating in an Advanced APM,
and could qualify as an Advanced APM Entity beginning in performance
year 2 for episodes ending on or after January 1, 2018, the time at
which EPM participants in performance year 2 would begin to bear
downside risk for excess actual episode spending above the quality-
adjusted target price.
The Advanced APM criteria established in the Quality Payment
Program final rule with comment period at Sec. 414.1415 (81 FR 77549)
require that for APMs in which hospitals are the APM Entities, such as
the EPMs, each hospital must use CEHRT to document and communicate
clinical care to their patients or other health care providers to meet
the CEHRT use requirement for Advanced APMs. Thus, there is no
requirement that Eligible Clinicians who would be included on an
Affiliated Practitioner List for Track 1 EPMs attest to CEHRT use and,
therefore, we will not develop CEHRT attestation processes for Eligible
Clinicians in Track 1 EPMs nor will we provide funds to support EHR
adoption. In addition, we encourage participants to consider utilizing
any shared savings obtained as part of the model to invest in health IT
infrastructure that can help EPM collaborators improve care
coordination for beneficiaries.
Final Decision: After consideration of the public comments
received, we are finalizing the proposal to include in Sec. 512.120(a)
the CEHRT use and attestation for EPM participants, with modification
to specify that the policy applies for performance year 2 if the EPM
participant elects downside risk, and to use the term ``specified'' for
consistency with CEHRT attestation in other CMS programs.
For performance year 2 if the EPM participant elects downside risk
and for performance years 3 through 5, EPM participants choose either
of the following:
CEHRT use. EPM participants attest in a form and manner
specified by CMS to their use of CEHRT as defined in Sec. 414.1305 of
this chapter to document and communicate clinical care with patients
and other health professionals.
No CEHRT use. EPM participants do not attest in a form and
manner specified by CMS to their use of CEHRT as defined in Sec.
414.1305 of this chapter to document and communicate clinical care with
patients and other health professionals.
c. Clinician Financial Arrangements Lists Under the EPMs
In order for CMS to make determinations as to eligible clinicians
who could be considered QPs based on services furnished under the EPMs
(to the extent the models are determined to be Advanced APMs), we
require accurate information about eligible clinicians who enter into
financial arrangements under the Track 1 EPMs under which the
Affiliated Practitioners support the participants' cost or quality
goals as discussed in section III.I. of this final rule. We note that
eligible clinicians could be EPM collaborators engaged in sharing
arrangements with an EPM participant; PGP members who are collaboration
agents engaged in distribution arrangements with a PGP that is an EPM
collaborator; or PGP members who are downstream collaboration agents
engaged in downstream distribution arrangements with a PGP that is also
an ACO participant in an ACO that is an EPM collaborator. These terms
as they apply to individuals and entities with financial arrangements
under the EPMs are discussed in section III.I. of this final rule. A
list of physicians and nonphysician practitioners in one of these three
types of arrangements could be considered an Affiliated Practitioner
List of eligible clinicians who are affiliated with and support the
Advanced APM Entity in its participation in the Advanced APM as
proposed in the Quality Payment Program proposed rule. Therefore, this
list could be used to make determinations of who would be considered
for a QP determination based on services furnished under the EPMs (81
FR 28320).
Thus, we proposed that each EPM participant that chooses to meet
and attest to the CEHRT use requirement must submit to CMS a clinician
financial arrangements list in a form and manner specified by CMS on a
no more than quarterly basis. The list must include the following
information for the period of the EPM performance year specified by
CMS:
For each EPM collaborator who is a physician, nonphysician
practitioner, or provider of outpatient therapy services during the
period of the EPM performance year specified by CMS:
++ The name, tax identification number (TIN), and national provider
identifier (NPI) of the EPM collaborator.
++ The start date and, if applicable, end date, for the sharing
arrangement between the EPM participant and the EPM collaborator.
For each collaboration agent who is a physician or
nonphysician practitioner of a PGP that is an EPM collaborator during
the period of the EPM performance year specified by CMS:
++ The TIN of the PGP that is the EPM collaborator, and the name
and NPI of the physician or nonphysician practitioner.
++ The start date and, if applicable, end date, for the
distribution arrangement between the EPM collaborator that is a PGP and
the physician or nonphysician practitioner who is a PGP member.
For each downstream collaboration agent who is a physician
or nonphysician practitioner member of a PGP that is also an ACO
participant in an ACO that is an EPM collaborator during the period of
the EPM performance year specified by CMS:
++ The TIN of the PGP that is the ACO participant, and the name and
NPI of the physician or nonphysician practitioner.
++ The start date and, if applicable, end date, for the downstream
distribution arrangement between the collaboration agent that is both
PGP and an ACO participant and the physician or nonphysician
practitioner who is a PGP member.
If there are no individuals that meet the requirements to
be reported as EPM collaborators, collaboration agents, or downstream
collaboration agents, the EPM participant must attest in a form and
manner required by CMS that there
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are no individuals to report on the clinician financial arrangements
list.
As discussed in the Quality Payment program proposed rule, those
physicians or nonphysician practitioners who are included on the
Affiliated Practitioner List as of December 31 of a performance period
would be assessed to determine whether they qualify for APM Incentive
Payments (81 FR 28320). The Quality Payment Program final rule with
comment period (81 FR 77444) modified this process to identify eligible
clinicians on the Affiliated Practitioner List for QP determinations at
any one of three snapshots. The first snapshot will be on March 31 of
the QP Performance Period, the second snapshot will be on June 30 of
the QP Performance Period, and the third snapshot will be on August 31,
which will be the last day of the QP Performance Period.
We noted that while the required submission of this information
might create some additional administrative requirements for certain
EPM participants, we expected that EPM participants in a Track 1 EPM
could modify their contractual relationships with their EPM
collaborators and, correspondingly, require those EPM collaborators to
include similar requirements in their contracts with collaboration
agents and in the contracts of collaboration agents with downstream
collaboration agents.
The proposal for the submission of a clinician financial
arrangements list by EPM participants that meet and attest to the CEHRT
use requirement for the EPM was included in Sec. 512.120(b). We sought
comments on the proposal for submission of this information. We were
especially interested in comments about approaches to information
submission, including the periodicity and method of submission to CMS
that would minimize the reporting burden on EPM participants while
providing CMS with sufficient information about eligible clinicians in
order to facilitate QP determinations to the extent EPMs are considered
Advanced APMs.
The following is a summary of the comments received and our
responses.
Comment: While some commenters supported CMS' plans to recognize
Eligible Clinicians who participate in APMs from an Affiliated
Practitioner List, others raised concerns about the means to identify
Eligible Clinicians as Affiliated Practitioners of Advanced APMs. A few
commenters disagreed with the development of an Affiliated Practitioner
List from a clinician financial arrangements list. Some commenters
believe that to assume risk-taking threatens the financial viability of
most physician-led entities. Other commenters expressed concern that
the definition of such an agreement suggests that risk must be shifted
to the clinicians to achieve QP status. These commenters agreed that
the clinicians must support the cost or quality goals of the Advanced
APM, but do not believe that to be included on the Affiliated
Practitioner List the clinician must take risk. Other commenters
assumed that Eligible Clinicians must assume risk under the EPM to
qualify for QP incentive payment under the Quality Payment Program, and
suggested that CMS base the risk requirements on physician practice or
APM organization revenues. One commenter noted that not all physicians
bound contractually to the requirements of the EPMs would be captured
on clinician financial arrangements lists, as hospitals may have
agreements with their employed physicians that cascade the programmatic
requirements of the EPMs, but do not necessarily alter their underlying
compensation or include gainsharing/risk-sharing/internal cost savings
parameters. Instead, commenters offered alternatives to the submission
of clinician financial arrangements lists, including such proposals as
modeling the EPM along the lines of the Medical Home Model standard and
using claims data to identify and attribute Eligible Clinicians to
populate the EPM Affiliated Practitioner List for the purposes of the
Quality Payment Program.
Response: Under Track 1 EPMs, the Advanced APM Entity is always a
hospital, and no physicians are EPM participants. As we discussed in
the Quality Payment Program final rule with comment period (81 FR
77442), for Advanced APMs, such as episode payment models, in which
there are some Advanced APM Entities that include Eligible Clinicians
on a Participation List and other Advanced APM Entities that identify
Eligible Clinicians only on an Affiliated Practitioner List, we will
identify Eligible Clinicians for QP determination based on the
composition of the Advanced APM Entity: (1) For Advanced APM Entities
that include and identify Eligible Clinicians on a Participation List,
that Participation List will be used to define the Advanced APM Entity
group, regardless of whether or not there is also an Affiliated
Practitioner List or other list of Eligible Clinicians, and those
Eligible Clinicians will be assessed as a group; (2) for Advanced APM
Entities that do not include and identify Eligible Clinicians on a
Participation List and there is an Affiliated Practitioner List that
identifies Eligible Clinicians, that Affiliated Practitioner List will
be used to identify the Eligible Clinicians for purposes of QP
determinations, and those Eligible Clinicians will be assessed
individually. Track 1 EPMs fall into the second category because the
EPMs do not include and identify Eligible Clinicians on a Participation
List so, therefore, we will use an Affiliated Practitioner List for
Track 1 EPMs to identify Eligible Clinicians for purposes of QP
determinations.
In the Quality Payment Program final rule with comment period in
Sec. 414.1305 (81 FR 77537), an Affiliated Practitioner is defined as
an Eligible Clinician identified by a unique APM participant identifier
on a CMS-maintained list who has a contractual relationship with the
Advanced APM Entity for the purposes of supporting the Advanced APM
Entity's quality or cost goals under the Advanced APM. Furthermore, in
the Quality Payment Program final rule with comment period (81 FR
77440), we provided the example that an Affiliated Practitioner List
comprised of gainsharers under an APM might include Eligible Clinicians
whereas a Participation List may only include hospitals. We believe
this example applies to the Track 1 EPMs.
We believe that constructing the Affiliated Practitioner List from
the list of clinicians with financial arrangements submitted by each
EPM participant that chooses to use and attest to use of CEHRT allows
us to appropriately identify clinicians for the Affiliated Practitioner
List under the EPMs. All of these clinicians have contractual
relationships under the EPMs, and because the determination of the
amount of gainsharing payment, distribution payment, or downstream
distribution payment under their arrangement is required to be
substantially based on quality of care and the provision of EPM
activities (activities related to promoting accountability for the
quality, cost, and overall care for EPM beneficiaries, including
managing and coordinating care; encouraging investment in
infrastructure, enabling technologies, and redesigned care processes
for high quality and efficient service delivery; the provision of items
and services during an EPM episode in a manner that reduces costs and
improves quality; or carrying out any other obligation or duty under
the EPM), we believe that their contractual relationship supports the
cost and quality goals of the Track 1 EPM participant and, therefore,
that they meet the definition of Affiliated Practitioner.
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Regarding those commenters who were concerned that constructing the
Affiliated Practitioner List in this way would shift the financial risk
of the APM Entity (Track 1 EPM participant) to the clinician in order
for the clinician to be eligible for a QP determination, we want to
emphasize that distribution arrangements and downstream distribution
arrangements allow only distribution of payments that may be comprised
of hospital internal cost savings and/or reconciliation payments for
savings beyond the quality-adjusted target price under the EPMs,
without allowing the collaboration agent or downstream collaboration
agents to assume any downside risk. Sharing arrangements may include
the sharing of upside and downside risk with EPM collaborators, but we
note that in our experience with other bundled payment models, sharing
with individual physicians has generally been upside risk only. We
understand that the Quality Payment Program final rule with comment
period does not require that an Affiliated Practitioner take on upside
or downside risk to be eligible for a QP determination, while our
proposed methodology to identify Eligible Clinicians for the EPM
Affiliated Practitioner List requires those clinicians to have a
financial arrangement under the EPM. However, we based our proposal on
the most streamlined approach to identifying Eligible Clinicians under
the Track 1 EPM who meet the definition of Affiliated Practitioner to
build off policies that apply across the EPMs in general, in order to
limit any additional administrative burden on EPM participants for
Track 1 participation. Under the EPMs, the only contractual
relationships for which we specify requirements as part of the model
design for all participants and which ensure the Eligible Clinicians
meet the Affiliated Practitioner definition are financial arrangements.
Therefore, under our proposal for identifying Eligible Clinicians for
each EPM participant that chooses to use and attest to use of CEHRT we
would use the clinician financial arrangements list submitted to us to
construct the EPM Affiliated Practitioner List.
In terms of constructing the Affiliated Practitioner List from
claims data based on those clinicians furnishing services to EPM
beneficiaries, we would not be able to know if such physicians,
nonphysician practitioners, or therapists had a contractual
relationship with the EPM participant to support the EPM participant's
cost or quality goals under the Track 1 EPM (the requirement for
Affiliated Practitioners), so we are unable to adopt this suggestion by
the commenters. Moreover, we believe we can only know the information
about contractual relationships between an EPM participant and an
Eligible Clinician if the EPM participant reports this to us as we do
not otherwise require such reporting under the EPMs.
We understand that there are circumstances where an EPM participant
might want to enter into a contract with a clinician to support the
cost or quality goals of the EPM. At this point, EPM participants that
choose to use and attest to use of CEHRT may not report these
clinicians to us through the clinician financial arrangements list for
inclusion on the Affiliated Practitioner List because we made no
specific proposals about what such contractual relationships would
entail. As discussed previously in this section, MedPAC expressed
concern that the EPMs contemplate large, loosely connected groups of
clinicians who may have very little involvement with the beneficiaries
in EPMs and hence have little reason to change their practice patterns
or reduce inappropriate episodes. Thus, in order to identify the
circumstances in which Eligible Clinicians without financial
arrangements under a Track 1 EPM participant could meet the definition
of Affiliated Practitioner, we will further consider the scenarios
raised by the commenters and intend to propose an additional
methodology for EPM participants to identify other Eligible Clinicians
who may be included on the Affiliated Practitioner List in future
rulemaking. This additional methodology would be targeted for
implementation in performance year 3 when downside risk for all
participants under the EPMs applies.
We are finalizing our proposal to construct the EPM's Affiliated
Practitioner List from the clinician financial arrangements lists
submitted by those EPM participants that attest to CEHRT use.
Comment: Several commenters urged CMS to identify Eligible
Clinicians through a streamlined reporting process, and ensure that a
minimum burden is applied to EPM participants when providing lists. To
this end, the commenters proposed alterations to the proposed contents
of the clinician financial arrangements list, including the
recommendation that CMS require EPM participants or CJR participant
hospitals to submit an electronic form listing all collaborators,
collaboration agents, and downstream collaboration agents and their tax
identification numbers (TIN) on a yearly basis. Finally, some
commenters requested that CMS enable more frequent updates to the list.
Response: We appreciate the interest of the commenters in creating
the minimal necessary reporting burden on EPM participants and CJR
participant hospitals. For those EPM participants that choose to use
and attest to use of CEHRT and are required to submit a clinician
financial arrangements list, we agree with the commenters that the most
streamlined process that provides us with the timely, necessary
information is desirable. We proposed that the submission must occur on
a no more than quarterly basis and we continue to believe that this
timing is the most appropriate. It establishes the maximum required
submission burden on EPM participants of quarterly in view of the three
planned ``snapshots'' of the Affiliated Practitioner List each year (81
FR 77444) to capture timely new Affiliated Practitioners that were not
previously identified for the EPM participant, while allowing us the
flexibility to determine a lower reporting periodicity for EPM
participants whose list does not change during the EPM performance
year. We also note that while under our proposal we could not require
submission of the list more than quarterly, the submission timing
requirement does not preclude us from accepting more frequent than
quarterly voluntary updates to the list if EPM participants have more
frequent changes to their list of clinicians with financial
arrangements under the EPM.
We proposed that Eligible Clinicians on the clinician financial
arrangements list that we would use to construct an Affiliated
Practitioner List would be EPM collaborators who are physicians,
nonphysician practitioners, and providers of outpatient therapy
services engaged in sharing arrangements with an EPM participant; PGP
members who are physicians and nonphysician practitioners who are
collaboration agents engaged in distribution arrangements with a PGP
that is an EPM collaborator; and PGP members who are physicians and
nonphysician practitioners who are downstream collaboration agents
engaged in downstream distribution arrangements with a PGP that is also
an ACO participant in an ACO that is an EPM collaborator. To reflect
our final policies for financial arrangements discussed in section
III.I. of this final rule, and taking into consideration the issues
discussed later in this section, we are revising the categories of
individuals who qualify as Eligible Clinicians and clarifying the
information to be reported on the clinician financial arrangements list
in this final rule. It was our intention in
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the proposed rule and our policy in this final rule that the full
complement of physicians, nonphysician practitioners, and therapists
who have financial arrangements under the EPMs be reported on the EPM
participant's clinician financial arrangements list. We see no reason
to treat physicians, nonphysician practitioners, or therapists
differently for purposes of being considered Eligible Clinicians based
on their specific type of financial arrangement under the EPM as the
requirements for each type of contractual relationship are aligned with
the cost and quality goals of the EPM.
We proposed that providers of outpatient therapy services that are
EPM collaborators be reported on the clinician financial arrangements
list, although the term provider of outpatient therapy services also
encompassed entities that were not individual therapists and that,
therefore, could not be Eligible Clinicians. However, as discussed in
section III.I.3. of this final rule we are adopting the specific term
therapist in private practice for those individual therapists who are
EPM collaborators. Thus, we are refining the reporting of EPM
collaborators on the clinician financial arrangements list to include
physicians, nonphysician practitioners, and therapists in private
practice to focus on individual therapists in private practice, who may
be Eligible Clinicians under the provisions of the Quality Payment
Program final rule with comment period, rather than all providers of
outpatient therapy services.
In addition, our proposal did not identify as Eligible Clinicians
therapists who are collaboration agents and downstream collaboration
agents as members of PGPs or ACO providers/suppliers who are
physicians, nonphysician practitioners, or therapists who are
collaboration agents. While we did not propose that therapists who are
collaboration agents or downstream collaboration agents as members of
PGPs be reported on the clinician financial arrangements list, we did
propose that a therapist could be a PGP member and we note that
therapists can also be Eligible Clinicians under the provisions of the
Quality Payment Program final rule with comment period. We also did not
identify in our proposal that physicians, nonphysician practitioners,
and therapists who are collaboration agents and ACO providers/suppliers
in an ACO that is an EPM collaborator would be Eligible Clinicians on
the clinician financial arrangements list. This was an oversight as we
intended to include all collaboration agents who are physicians,
nonphysician practitioners, and therapists on the clinician financial
arrangements list, regardless of the entity that is their associated
EPM collaborator. Moreover, our proposal did not take into account the
provisions of this final rule that allow NPPGPs and TGPs to be EPM
collaborators or collaboration agents and, therefore, we did not
propose that the nonphysician practitioners and therapists who have
financial arrangements with these entities would also be Eligible
Clinicians on the clinician financial arrangements list. Therefore, in
this final rule we are clarifying that all physicians, nonphysician
practitioners, and therapists who are collaboration agents or
downstream collaboration agents are reported on the clinician financial
arrangements list, without regard to the type of entity that is the
associated party with which the collaboration agent or downstream
collaboration agent has his or her distribution arrangement or
downstream distribution arrangement. We note that we proposed to
require that physicians and nonphysician practitioners who are members
of a PGP that is an EPM collaborator or members of a PGP that is also
an ACO participant in an ACO that is an EPM collaborator and that have
a distribution arrangement or downstream distribution arrangement,
respectively, with the PGP be reported on the list. Therefore, we
believe there is only a small additional burden on EPM participants to
report on the list all collaboration agents or downstream collaboration
agents that are physicians, nonphysician practitioners, or therapists
with distribution arrangements or downstream distribution arrangements,
in order to ensure that the clinician financial arrangements list
reports all Eligible Clinicians with financial arrangements under the
EPM.
We proposed that the information to be reported on the clinician
financial arrangements list would include the name and NPI and, in some
cases the TIN, of the Eligible Clinician with the financial arrangement
under the EPM. We also proposed to collect the TIN of the PGP that is
an EPM collaborator or collaboration agent and with which the physician
or nonphysician practitioner reported on the list has a financial
relationship, which would have provided us with information for
purposes of monitoring and compliance on some of the entities related
to the contracts of those physicians or nonphysician practitioners
under the EPM. While we did not propose to similarly require
information be submitted on the ACO that would be an EPM collaborator
for those Eligible Clinicians that are collaboration agents or
downstream collaboration agents, in this final rule, we are clarifying
that the name and NPI of the entity (that is, the PGP, NPPGP, TGP, or
ACO) that is an EPM collaborator and the entity (that is, the PGP,
NPPGP, or TGP) that is a collaboration agent, if applicable, must also
be reported on the clinician financial arrangements list for each
Eligible Clinician who is a collaboration agent or downstream
collaboration agent. Thus, the final requirements provide us with
sufficient information to monitor the full series of related financial
relationships under the EPM that result in the reporting of an Eligible
Clinician on the clinician financial arrangements list. Because we do
not expect that EPM participants will enter into sharing arrangements
with many ACOs, due to the limited number of ACOs to which
beneficiaries are typically assigned in a given geographic area, we do
not believe that requiring the reporting of the name and TIN of the ACO
that is an EPM collaborator is a significant additional burden on the
EPM participant submitting the list to CMS.
In summary, based on the previous discussion, for purposes of
clarity and consistency we are streamlining the requirements for
reporting information on the clinician financial arrangements list. For
each physician, nonphysician practitioner, or therapist that is an EPM
collaborator, collaboration agent, or downstream collaboration agent,
we require the name, TIN, and NPI to be reported, in addition to the
start date and, if applicable, end date, for the individual's sharing
arrangement, distribution arrangement, or downstream distribution
arrangement. We further require for a collaboration agent that the name
and TIN of the EPM collaborator be reported and that for a downstream
collaboration agent the name and TIN of the EPM collaborator and the
name and TIN of the collaboration agent be reported.
We will be working closely with EPM participants on the format and
process for submission of clinician financial arrangements lists,
including the potential for electronic submission of the required
information, during the early phases of EPM implementation, seeking to
ensure that the format and process is as streamlined as possible for
EPM participants that choose to use and attest to use of CEHRT, while
meeting CMS' need to maintain an EPM Affiliated Practitioner List that
can be used to identify Eligible Clinicians for a QP determination.
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Final Decision: After consideration of the public comments
received, we are finalizing the proposal in Sec. 512.120(b) for EPM
participants that use and attest to use of CEHRT to submit to CMS a
clinician financial arrangements list on a no more than quarterly
basis, with modification to include on that list information on all
physicians, nonphysician practitioners, and therapists with financial
arrangements under the EPM and, if applicable, identifying information
for the related parties with sharing arrangements, distribution
arrangements, and downstream distribution arrangements under the EPM as
finalized in section III.I. of this final rule.
Each EPM participant that chooses CEHRT use must submit to CMS a
clinician financial arrangements list in a form and manner specified by
CMS on a no more than quarterly basis. The list must include the
following information on individuals and entities for the period of the
EPM performance year specified by CMS:
EPM collaborators. For each physician, nonphysician
practitioner, or therapist in private practice who is an EPM
collaborator during the period of the EPM performance year specified by
CMS:
++ The name, TIN, and NPI of the EPM collaborator.
++ The start date and, if applicable, end date, for the sharing
arrangement between the EPM participant and the EPM collaborator.
Collaboration agents. For each physician, nonphysician
practitioner, or therapist who is a collaboration agent during the
period of the EPM performance year specified by CMS:
++ The name and TIN of the EPM collaborator and the name, TIN, and
NPI of the collaboration agent.
++ The start date and, if applicable, end date, for the
distribution arrangement between the EPM collaborator and the
collaboration agent.
Downstream collaboration agents. For each physician,
nonphysician practitioner, or therapist who is a downstream
collaboration agent during the period of the EPM performance year
specified by CMS:
++ The name and TIN of the EPM collaborator, the name and TIN of
the collaboration agent and the name, TIN, and NPI of the downstream
collaboration agent.
++ The start date and, if applicable, end date, for the downstream
distribution arrangement between the collaboration agent and the
downstream collaboration agent
Attestation to no individuals. If there are no individuals
that meet the requirements to be reported, as specified in paragraphs
(b)(1) through (3) of this section, the EPM participant must attest in
a form and manner required by CMS that there are no individuals to
report on the clinician financial arrangements list.
d. Documentation Requirements
For each EPM participant that chooses to meet and attest to CEHRT
use, we proposed that the EPM participant must maintain documentation
of their attestation to CEHRT use and clinician financial arrangements
lists submitted to CMS. These documents would be necessary to assess
the completeness and accuracy of materials submitted by an EPM
participant in the Track 1 EPM and to facilitate monitoring and audits.
For the same reason, we further proposed that the EPM participant must
retain and provide access to the required documentation in accordance
with Sec. 512.110.
The proposal for documentation of attestation to CEHRT use and
clinician financial arrangements lists submitted to CMS was included in
Sec. 512.120(c). We sought comment on this proposal for required
documentation.
Final Decision: We did not receive comments pertaining to Sec.
512.120(c). Therefore, we are finalizing the proposal, without
modification, for EPM participant documentation of attestation to CEHRT
use and clinician financial arrangements lists submitted to CMS.
The following documentation requirements apply to EPM participants
choosing to use and attest to use of CEHRT.
Each EPM participant that chooses CEHRT use must maintain
documentation of their attestation to CEHRT use and clinician financial
arrangements lists.
The EPM participant must retain and provide access to the
required documentation in accordance with Sec. 512.110.
3. Future Directions for Episode Payment Models
a. Refinements to the BPCI Initiative Models
The BPCI initiative Models 2, 3, and 4 would not currently qualify
as Advanced APMs based on two of the Advanced APM criteria in the
Quality Payment Program (QPP) final rule with comment period (81 FR
77008), payment based on quality measures and CEHRT use. Specifically,
BPCI participants are not currently required to use CEHRT, and although
CMS examines the quality of episode care in the BPCI evaluation, BPCI
episode payments are not specifically tied to quality performance.
Instead, BPCI episode payments are based solely on episode spending
performance, although we expect that reductions in spending would
generally be linked to improved quality through reductions in hospital
readmissions and complications. However, building on the BPCI
initiative, the Innovation Center intends to implement new bundled
payment model for CY 2018 where the model(s) would be designed to meet
the criteria to be an Advanced APM.
The following is a summary of the comments received and our
responses.
Comment: A number of commenters expressed support for a new
voluntary bundled payment model in CY 2018. Specifically, commenters
expected any new design to include the ability of the BPCI Initiative
to qualify as meeting the requirements for an advanced APM under the
QPP. Commenters also requested that data be provided by CMS on a
monthly basis with quarterly reconciliation reports to allow
participants to meaningfully engage in reforms to the delivery of
health care. Consistent with the existing BPCI model, CMS was
encouraged by commenters to continue assigning precedence to self-
selected model participants over participants in assigned models.
Additional recommended features included financial stop-gain and stop-
loss limits and the incorporation of composite quality score similar to
that used in the CJR model. Other specific features included
recommendations for additional post-acute care bundles and the
exclusion of ACOs.
More broadly, CMS received several recommendations calling for
increased stakeholder input in the design, implementation, and
evaluation of new voluntary bundled payment models. Commenters
requested that hospitals currently participating in BPCI should be
allowed to test additional episodes, and new hospitals should be
allowed to enter the program. While ranging in degree, most commenters
highlighted a need for input from external clinical experts in addition
to consumers, patients, and purchasers as well as institutional
stakeholders such as QIOs. To better align with other available EHR
incentive payments, several commenters stated a need for future bundled
payment models to include CEHRT measures.
Response: We appreciate these considerations as we design a new
voluntary bundled payment model.
Comment: A few commenters suggested that since post-acute care
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providers are the predominant care provider for LEJR patients, post-
acute care should play a more prominent role in the BPCI initiative.
Response: CMS thanks the commenters for this suggestion.
Comment: One commenter recommended CMS use a consistent policy to
address overlap of all Medicare bundled payment initiatives and
population-based payment models. The commenter raised concerns with
respect to overlap of beneficiaries in the EPMs, CJR model, and BPCI
initiative, and suggested that, in a future BPCI initiative,
beneficiaries should be excluded from bundled payments unless a
collaborative agreement exists between an ACO and a hospital that is
not a participant in that ACO. The commenter also had concerns for the
extent to which Medicare beneficiaries benefit from allowing private
for-profit awardee conveners to absorb the risk for providers.
Therefore, the commenter recommended also that CMS exclude for-profit
risk-taking conveners which do not provide patient care.
Response: We acknowledge and appreciate all comments, and
specifically recognize the shared interest in improving Medicare for
its beneficiaries.
Comment: A few commenters requested that CMS take into
consideration several additional pricing flexibilities and regulatory
waivers for a new voluntary bundled payment model. Specifically,
commenters believed that reducing costs and increasing shared savings
could be difficult, therefore, participants should have the flexibility
in a new voluntary bundled payment model to modify practice or
utilization patterns by reducing length of stay or intensity of
services. Commenters stated that the next iteration of BPCI should
feature program elements such as caps on total losses that gradually
increase over time, variable discounts based on quality scoring, and
elimination of financial responsibility for payments above a threshold.
Other commenters proposed that CMS adopt a method of population risk
stratification, as this could provide incentive to providers by
reimbursing more for greater comorbidities. Finally, in setting the
bundled payment amounts, commenters recommended that CMS incorporate
clinical practice guidelines and appropriate use criteria to ensure
that patients are not receiving inadequate care. One commenter
suggested that CMS provide patient navigators to Medicare beneficiaries
receiving items or services paid under an EPM. Additionally, the
regulatory waivers requested included the home health homebound
requirement, the IRF 60 percent rule, the IRF 3-hour therapy intensity
rule, and the LTCH 25 day average length of stay restriction. One
commenter suggested that occupational therapy be recognized as a
``qualifying service'' under the Medicare home health care benefit and
occupational therapists could, in future APMs be permitted to open
`therapy only' cases if occupational therapy is in the physician's
order.
Response: We recognize commenters' requests for consideration of
additional flexibilities in care redesign efforts as part of a new
voluntary bundled payment model.
Final Decision: As we did not propose changes to the BPCI
initiative in the proposed rule, we do not have any changes to finalize
in this final rule.
b. Potential Future Condition-Specific Episode Payment Models
In the context of our proposal for the AMI and CABG models that
include beneficiaries with CAD who experience an acute event or a major
surgical procedure, we sought comment on model design features for
potential future condition-specific episode payment models that could
focus on an acute event or procedure or longer-term care management,
including other models for beneficiaries with CAD that may differ from
the design of the EPMs proposed in the proposed rule (81 FR 50794). We
believe such future models may have the potential to be Advanced APMs
that emphasize outpatient care and, like the proposed AMI and CABG
models, could incentivize the alignment of physicians and other
eligible professionals participating in the Advanced APM through
accountability for the costs and quality of care. Such condition-
specific episode payment models may provide for a transition from
hospital-led EPMs to physician-led accountability for episode quality
and costs, especially given the importance of care management over long
periods of time for beneficiaries with many chronic conditions.
We requested that commenters provide specific information regarding
all relevant issues for potential future condition-specific episode
payment models, including identifying beneficiaries for the model;
including services in the episode definition; beginning and ending
episodes; pricing episodes, including risk-adjustment; designating the
accountable entity for the quality and cost of the episode, including
the role of physician-led opportunities; sharing of responsibility for
quality and spending between primary care providers, specialty
physicians, and other health care professionals; incentivizing the
engagement of physicians and other providers and suppliers in episode
care; measuring quality and including quality performance and
improvement in the payment methodology; interfacing with other CMS
models and programs responsible for population health and costs, such
as ACOs and Primary Care Medical Homes (PCMHs); other considerations
specific to identifying future models as Advanced APMs; and any other
issues of importance for the design of such an EPM.
The following is a summary of the comments received and our
responses.
Comment: A few commenters requested that in future condition-
specific EPMs, CMS should consider episodes beginning before a
hospitalization, as one commenter believed that this earlier future EPM
episode trigger would engage more meaningful shared care planning.
Other commenters stated that future condition-specific EPMs should be
based on episodes that are not necessarily tied to a hospital stay. One
commenter noted that there is a great degree of variation in cardiac
care beyond the two proposed EPM episodes. For example, the commenter
noted regional differences in ambulatory and hospital care for heart
failure, which the commenter did not believe are explained by disease
severity and therefore the commenter suggested such additional cardiac
care may become a favorable population-based payment model. Several
commenters provided recommendations and perspectives on future
condition-specific episode payment models based on MS-DRGs, including
examples such as sepsis. However, other commenters suggested the
alternative to use the Episode Grouper for Medicare (EGM) for future
condition-specific EPMs. The framework for the EGM involves organizing
administrative claims data into episodes-of-care, or simply episodes,
which are sets of services provided to care for an illness or injury
during a defined period of time. One commenter stated that the EGM
organizes Medicare beneficiary total cost around two constructs--
episodes for specific conditions and episodes for specific treatments.
For condition-specific episodes, each episode would be defined by one
or more diagnosis codes, however, treatment episodes would be defined
by a combination of procedure and diagnosis codes. A few commenters
provided specific diagnoses that could be attributable to organized
future EPMs, including but not limited to gastroesophageal reflux
disease and
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obesity. Another commenter disagreed, stating it is inappropriate to
expand the current EPM approach to future treatment of chronic
conditions because, the commenter suggested, a bigger opportunity for
improving quality and achieving savings is avoiding unnecessary
episodes and events. In turn, the costs of treatment episodes could be
packaged into the costs of managing underlying condition episodes.
Commenters stated further that the EGM should also examine utilization
patterns, perform comparative analyses for similar conditions, and
identify care-improvement opportunities. As such, commenters suggested
that the EGM would be better suited to pricing and resource allocation
while identifying chronic conditions.
Response: We thank the commenters for their suggestion.
Comment: Another commenter, referencing the Program of All-
Inclusive Care for the Elderly (PACE), recommended that CMS consider a
comprehensive episode payment model for services for medical care that
could be tied with private payment, enrollment in available community
services, or an arrangement with Medicaid. Beneficiaries requiring
daily help or supervision would serve as a qualifying condition, which
could extend for varying durations.
Response: We appreciate the commenter's support for PACE and will
work internally to incorporate lessons learned from existing programs
in the proposal of future condition-specific EPMs.
Comment: Highlighting the efforts of national medical specialty
societies, several commenters provided several condition-specific EPMs
which may be successful in reducing emergency department visits,
hospital admissions, and excessive testing. Specifically, several
commenters gave such examples as coronary artery disease, headache,
epilepsy, asthma, opioid use disorder, diabetes, and specialty medical
home. Of note, commenters stated that CMS should give additional
consideration to defined episode triggers. For example, some commenters
suggested that each new episode should be accompanied by time criteria
and have a unique but expected time course. These efforts, commenters
suggested, might further result in disease prevention, reduced
exacerbations, and improved care.
Response: We appreciate commenters' eagerness to participate in
this dialogue and to be a part of transforming care.
Comment: Commenters believed that CMS should view organized
provider models as qualifying for condition-specific EPMs. Other
commenters suggested that CMS simply include more types of
participants, including examples such as ACOs and PCMHs. Still, others
commented that participation in future condition-specific EPMs be
limited to those organizations that are fully committed to coordinated
care planning, shared decision-making, comparative quality information,
chronic disease management, transparent payments and care transition
support. As an alternative approach to considering future condition-
specific EPMs, MedPAC suggested that CMS consider allowing hospitals to
share savings with physicians as a way to focus doctors on reducing the
cost of the inpatient stay.
Response: We acknowledge and appreciate the suggestion to
incorporate more participant types in future condition-specific EPMs.
Comment: Additionally, MedPAC recommended that for conditions that
are not promising for bundled payments, CMS could focus on an array of
other strategies to support providers in lowering costs while improving
patient outcomes. For example, the Medicare spending per beneficiary
(MSPB) measure in the hospital value-based purchasing (VBP) program
encourages lower spending and improved care coordination. Alteration of
the ``weight'' of the MSPB could be increased to further incentivize
hospitals to reduce spending. Furthermore, MedPAC noted that the
hospital readmission policy already encourages hospitals to avoid
readmissions for AMIs and CABGs. To increase the pressure to reduce
readmissions, it was suggested that CMS move forward with readmission
policies in all sectors to increase the penalties for providers with
high risk- adjusted potentially avoidable readmission rates.
Response: We appreciate any recommendations MedPAC can provide and
will continue to collaborate with stakeholders to develop additional
means to improve patient outcome measures. Furthermore, we will work
internally to find additional alignment between Innovation Center
programs and Medicare payment policies.
Comment: One commenter recommended consideration of an episode that
should address behavioral health integration with primary care. The
commenter suggested that guidelines which embed behavioral health
measurements into any care setting would equip providers with
quantification necessary to impact both physical and mental health of
patients.
Response: We appreciate the commenter's proposal. We appreciate the
many comments received regarding the request for comment and while we
did not propose any changes to this section of the final rule, we
intend to continually seek to connect those interested to further
information on consideration of future condition-specific EPMs that
would result in improvement in care for Medicare beneficiaries.
c. Potential Future Event-Based Episode Payment Models for Procedures
and Medical Conditions
Given the proposed EPM methodology discussed in section III.C.4.a.
of this final rule for the three models that would begin the episodes
with initial hospitalizations, the proposed AMI, CABG, and SHFFT
episodes are similar to the LEJR episodes in the CJR model because they
reflect clinical conditions for which care is almost always begun
during an inpatient hospitalization, either on an emergency or elective
basis. In addition, the clinical conditions represented by these EPM
episodes generally result in straightforward assignment to MS-DRGs at
discharge that are specific to clinical conditions included in the
episodes. This contrasts with procedure-related clinical conditions for
which the site-of-service can be inpatient or outpatient (for example,
elective PCI for non-AMI beneficiaries) or hospitalization for medical
conditions for which the ultimate MS-DRG assigned is less clear at the
beginning of an episode (for example, hospitalization for respiratory
symptoms which may lead to discharge from heart failure, pneumonia, or
other MS-DRGs based on reporting of ICD-CM diagnosis codes on hospital
claims).
To address the issues related to the development of future episode
payment models for a broader range of clinical conditions, we sought
comment on model design features that would be important for episode
payment models targeting procedures that may be performed in both the
inpatient and outpatient setting, as well as models focused on
hospitalization for acute medical conditions which may overlap or
interact (for example, sepsis related to pneumonia or acute kidney
injury related to congestive heart failure exacerbation). In
particular, episode payment models must clearly define the beginning of
the episode as well as set an episode price that is appropriate for
beneficiaries included in the episode, which has commonly been based on
historical spending for such beneficiaries in both existing CMS models
and the three proposed EPMs. These parameters pose specific challenges
as the variety of clinical
[[Page 218]]
conditions targeted for episode payments expands beyond lower extremity
orthopedic procedures and acute cardiac conditions, and we expect that
such potential future models would need to be designed differently than
the CJR model or the EPMs in this rulemaking.
For example, because procedures such as PCI for non-AMI
beneficiaries or cardioverter defibrillator implantations can occur in
the inpatient or outpatient setting, an episode payment model would
need to include beneficiaries receiving such procedures at all sites-
of-service so as to not influence decisions on where procedures are
performed based on payment-related rather than clinical considerations.
Episode payment models that begin with the same procedure performed in
the inpatient or outpatient setting would require methodological
development beyond the approaches that have been used thus far in CMS'
other EPMs that rely upon the MS-DRG for a hospitalization to begin an
episode and identify historical episodes for setting episode prices.
Such models that involve episode payment for procedures furnished in
the inpatient or outpatient setting may allow for significant
physician-led opportunities that would allow the models to be
identified as Advanced APMs. We sought comment on how these types of
procedures could be included in future episode payment models,
including identifying the accountable entity, and the role of
physician-led opportunities; defining the episode beginning and end;
setting episode prices; applying risk-adjustment to account for
differences in expected episode spending for a heterogeneous population
of beneficiaries; and any other issues of importance for the design of
such an episode payment model.
We also sought comment on potential future episode payment models
that would include care for medical conditions that result in the
serious health event of an inpatient hospitalization, which often
represents, regardless of the specific reason for the hospitalization,
a common pathway that includes failure of outpatient care management
and care coordination for beneficiaries with chronic conditions. While
we include beneficiaries who solely receive medical treatment in the
proposed AMI model, we note that beneficiaries with AMI are almost
always hospitalized and their MS-DRGs at discharge are generally
predictable and consistent based on their AMI diagnoses. This is not
the case for a number of medical conditions for which grouping by MS-
DRGs is more complicated or less consistent. Many non-procedural
hospitalizations of Medicare beneficiaries are ultimately categorized
based on the principal ICD-CM diagnosis code reported on a claim, which
in turn is mapped to a Major Diagnostic Category (MDC) based on the
involved organ system, which then leads to the assignment of any of
various specific MS-DRGs based on the medical groups in the MDC. For
example, the medical groups for the Respiratory System MDC are
pulmonary embolism, infections, neoplasms, chest trauma, pleural
effusion, pulmonary edema and respiratory failure, chronic obstructive
pulmonary disease, simple pneumonia, RSV pneumonia and whooping cough,
interstitial lung disease, pneumothorax, bronchitis and asthma,
respiratory symptoms and other respiratory diagnoses.\36\ Unlike a
beneficiary who undergoes a surgical procedure or who is hospitalized
for a specific medical condition such as AMI, the ultimate MS-DRG at
discharge assigned to a beneficiary hospitalized for diagnosis and
management of respiratory symptoms may not be clear during the
hospitalization itself, or even afterward, until the inpatient claim is
submitted and paid by Medicare. This makes it challenging for providers
to engage in care delivery redesign targeted to a specific patient
population identified by MS-DRG. Additionally, it is possible that
beneficiaries hospitalized for certain medical conditions also may
follow common clinical pathways before and after discharge for which
similar care redesign strategies could be developed and used despite
those beneficiaries' assignments to different MS-DRGs for their anchor
hospitalizations. Thus, we believe that hospitalization for most
medical conditions would require special consideration in the
development of potential future episode payment models that goes beyond
CMS's current approach of relying upon the MS-DRG for the anchor
hospitalization to begin an episode and identify historical episodes
for setting episode prices. We sought comment on design features needed
to address these considerations, including defining the beginning and
end of episodes; setting episode prices, including risk-adjustment,
that would support the provision of appropriate and coordinated care
for beneficiaries following hospital discharge for a period of time
during the episode; and any other issues of importance for the design
of such an episode payment model.
---------------------------------------------------------------------------
\36\ Medical Severity Diagnosis Related Groups (MS-DRGs):
Definitions Manual. Version 33.0A. 3M Health Information Systems.
(October 1, 2015).
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The following is a summary of the comments received and our
responses.
Comment: Many commenters expressed support for the continued
commitment of the Agency to testing episode-based payment models under
a range of settings. One commenter suggested that CMS generally
consider both clinical and economic expertise as well as include large
databases as part of the development of future event-based EPM. While
recommendations included both specific surgical procedures, such as PCI
or spine surgery, chronic conditions, such as diabetes, and discrete
events including colonoscopy and an arm arthroplasty, several
commenters submitted more general suggestions that CMS take an
expansive approach in general for the consideration of future models
and not limit alternative payment models to episode payment approaches.
When considering future models to qualify as Advanced APMs, one
commenter suggested that CMS count capitated MA relationships in
MACRA's APM threshold calculation.
Some commenters preferred an emphasis on future EPMs that consider
the role of preventative efforts. For example, one commenter suggested
that conditions such as osteoporosis could include efforts to improve
bone health and functional level to achieve meaningful reduction in
falls and subsequent fracture. The commenter followed that concerns
such as fracture prevention be included in future models. To this end,
one commenter stated that CMS should take a ``bottom-up approach'' that
encourages providers to develop alternative payment models.
Response: We thank the commenters for their remarks, and will
continue to apply the bottom-up approach to improving the coordination
among providers in future EPMs.
Comment: Some commenters expressed concern about the continuation
of hospital-based models and recommended that future expansions should
include more types of participants, including physicians, and
participation should be voluntary. Physicians, one commenter suggested,
are best suited to ensure efficient utilization of resources while
preserving patient quality by virtue of their direct relationship with
the patient during an acute episode. One commenter suggested expansion
of physician-focused payment models beyond the Focused Payment Model
Technical Advisory Committee (PTAC). In a parallel thought process,
many other commenters expressed a desire for CMS to consider post-acute
care bundles, ACO based models, and shared
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accountability payment models for Inpatient Rehabilitation Facilities
(IRFs). One commenter strongly recommended CMS to allow manufacturers
to enter into voluntary agreements with CMS to link payment to
outcomes. One such outcome proposed by the commenter was the long-term
revision rates for total joint arthroplasty (TJA). Any shared savings
relative to the average rate of revision among Medicare patients, the
commenter suggested, could be shared between implanting surgeons,
hospitals and medical device manufacturers. Commenters stated that
these additional types of participants could provide a means to ensure
efficient utilization within a particular market. In addition, another
commenter noted that procedures performed in ambulatory surgical
centers may be better situated to serve as the financially accountable
entity in order to optimize care coordination to better achieve the
goals envisioned by episode-based payment models.
Response: We thank the commenters for their commitment to working
with CMS in developing future episode payment models.
Comment: Commenters commonly recommended that future bundles be
sensitive to considering risk adjustment, appropriate use criteria,
patient expectations, stage of disease progression, treatment options,
and appropriate quality measures regardless of setting. Commenters also
recommended that future measures in future condition-specific payment
models should be more directly related to the condition of the
beneficiaries within the EPM. To this end, one commenter recommended
that CMS include measures of patient engagement and shared care
planning. Another commenter suggested that those who participate in
geriatric fracture programs and/or obtain CORE Certification, be
incentivized to continue such progress. Even as CMS proposed to exclude
IPPS new technology add-on payments and OPPS transitional pass-through
payments for medical technologies from EPM episodes, one commenter
requested that future EPM episodes include additional innovative
technologies to qualify for a payment adjustment similar to the
Medicare New-Technology add-on payment.
Many commenters stressed the importance of shared decision-making
in the development of future models. One commenter, for example noted
the Clinical Practice Improvement Activities Category of the MIPS could
be an important first step to greater shared decision-making across
healthcare delivery and recommended CMS look to research conducted by
PCORI and others for future direction. Specifically, one commenter also
noted that shared decision-making and patient engagement tools could be
especially informative in situations not triggered by an acute care
hospitalization. Several other commenters further strongly encouraged
the participation of hospitals, physicians, patients, and other
stakeholders in the development, implementation, and testing of future
models. Additionally, in future EPM models, a few comments directed CMS
to consider directly extending the risk to the other providers,
including clinicians as physicians shape the spending during the
hospital stay and the selection of the initial post-acute care provider
but are not required to be at risk for the 90-day episode spending.
Similarly, some commenters noted that post-acute care providers can
influence how much spending for post-acute care services is used and
the rate of hospital readmissions but are not directly at risk for the
90-day episode spending. Therefore, these commenters suggested such
changes to future EPMs would ensure that the financial incentives of
the key actors shaping care are aligned.
In addition to model design, one commenter recommended that QIOs
serve in a technical assistance role for model participants to include
data analyses, convening providers in the area, structuring
implementation of improvement activities, and monitoring tests of
improvement.
Response: We thank the commenters for these suggestions and will
consider the recommendations as we consider future event-based
procedures and medical conditions to include in future rulemaking.
Comment: One commenter pointed to the Continuing Care Hospital
model, and suggested CMS pilot future event-based episode payment
models for procedures and medical conditions. The commenter stated that
the CCH would allow predictable and reduced costs to the Medicare
program.
Response: We thank the commenter for the reference.
Comment: One commenter suggested the implementation of an
evaluation EPM, whereby the episode initiates when a beneficiary enters
an inpatient setting with a set of symptoms that may be difficult to
attribute to one or more MS-DRGs. Such an evaluation EPM, stated the
commenter, would need to be limited to a specific set of symptoms, such
as the example CMS provided regarding respiratory symptoms.
Response: We thank the commenter for this specific suggestion.
Comment: One commenter recommended CMS to exclude other potentially
high cost drivers, such as psychiatric readmissions and high cost IV
therapy, from future EPM bundles.
Response: We acknowledge this suggestion and will consider if it is
applicable to specific future EPMs.
Comment: One commenter noted other considerations specific to
identifying future models, specifically that CMS update the claims
adjudication system and develop contracting tools. The commenter
suggested that such changes would encourage participant providers to
improve their care pathways and care coordination.
Response: We acknowledge these additional considerations and re-
affirm our commitment to continuously engage stakeholders as we
establish and operationalize future policies.
Comment: A few commenters requested a meeting with CMS to discuss
the specifics of a future innovation model.
Response: We appreciate the interest in meeting with CMS to discuss
future models. Commenters should note that ideas can also be submitted
through https://innovation.cms.gov/Share-Your-Ideas/Submit/.
Final Decision: After seeking comments on future directions for
episode payment models, we thank the public for these comments and will
evaluate the suggestions for future consideration.
d. Health Information Technology Readiness for Potential Future Episode
Payment Models
We are particularly interested in issues related to readiness of
providers and suppliers that are not hospitals to take on financial
responsibility for episode cost and quality in potential future episode
payment models. We have some experience in BPCI Models 2 and 3 with
non-hospital providers and suppliers, specifically post-acute care
providers and physician group practices (PGPs), who assume financial
responsibility for the cost of episode care. In BPCI Model 2, PGPs may
directly bear financial responsibility for episode cost for up to 48
clinical conditions for the anchor inpatient admission and up to 90
days post-hospital discharge. In BPCI Model 3, PGPs and post-acute care
providers, including skilled nursing facilities, home health agencies,
inpatient rehabilitation facilities, and long-term care hospitals, may
directly bear financial responsibility for episode cost for up to 48
clinical conditions for a duration that extends up to 90 days
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following initiation of post-acute care following discharge from an
inpatient hospitalization.
Under these circumstances, PGPs and post-acute care providers
typically need to use health IT to assist them in effectively
coordinating the care of BPCI beneficiaries across settings throughout
the episodes. The risk-bearing entities participating in BPCI have
expressed readiness to take on financial responsibility for episode
cost, and they commonly rely upon health IT for assistance in managing
the care for BPCI beneficiaries across settings for episodes that
extend for a substantial period of time. However, a recent national
survey of IT in nursing homes showed common use of IT for
administrative activities but less use for clinical care.\37\
Anecdotally, stakeholders have told us that accountable non-hospital
providers and suppliers, especially those that are not integrated with
health systems, may have less well-developed tools for following
patients throughout episodes, potentially resulting in greater
challenges in reducing the cost and improving the quality of episode
care under the BPCI models. Therefore, we understand that limitations
in the availability of health IT that can be used in beneficiary
management across care settings may pose a significant barrier to the
readiness of non-hospital providers and suppliers to assume financial
responsibility for episodes in potential future episode payment models.
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\37\ Alexander, Gregory L. ``An Analysis of Nursing Home Quality
Measures and Staffing.'' Quality management in health care 17.3
(2008): 242-251. PMC. Web. 16 July 2016.
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In the CJR model, acute care hospitals are financially responsible
for cost and quality during LEJR episodes-of-care. CJR model
participant hospitals may form partnerships with post-acute care
providers such as skilled nursing facilities and home health agencies,
as well as physicians and PGPs, to share financial risk and collaborate
on care redesign strategies, as in BPCI. Although hospitals are the
financially responsible entities under the CJR model, we recognize that
partnerships with post-acute care providers could be a crucial driver
of episode spending and quality, given that many beneficiaries in the
CJR model receive post-acute care services after discharge from the
hospital. We also recognize that tools such as health IT may be
critical for certain care management and quality strategies targeted
toward the goal of lower cost and higher quality episode care.
Limitations in the availability of health IT may pose a barrier to
effective post-acute care provider collaboration and sharing of
financial risk in episode payment models even when hospitals are the
financially responsible entities under such models, such as the CJR
model and the three new EPMs in this rule.
We recognize that there is wide variation in the readiness of other
providers and suppliers to bear financial responsibility for episodes,
either directly or indirectly through sharing arrangements with the
directly responsible entities where those arrangements may include
upside and downside risk. For instance, adoption of health IT among
providers in the post-acute care market, such as skilled nursing
facilities, continues to lag behind hospitals and providers of
ambulatory care services. In addition to facing significant resource
constraints, post-acute care providers were not included as an eligible
provider type under the Medicare and Medicaid Electronic Health Record
(EHR) Incentive Programs. The recent extension of Medicaid 90/10
funding offers new opportunities for states to include post-acute care
providers in projects focused on infrastructure development, but will
not address the cost of health IT adoption among post-acute care
providers.\38\
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\38\ https://www.medicaid.gov/federal-policy-guidance/downloads/SMD16003.pdf.
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To ensure that post-acute care providers and other types of
providers and suppliers can succeed under future episode payment
models, either as the directly financially responsible entity or as
collaborators with other directly financially responsible entities, we
are interested in opportunities to increase provider readiness as part
of the design of potential future episode payment models and the
potential refinement of current episode payment models. Specifically,
we would like to explore: Incentives to encourage post-acute care
providers, as well as other providers and suppliers that furnish
services to episode payment model beneficiaries, to make necessary
investments in health IT infrastructure; payment mechanisms that could
leverage savings achieved under episode payment models to contribute to
these investments; and any other strategies to enhance the adoption,
implementation, and upgrading of certified health IT. We sought comment
on these ideas, as well as the following questions:
What are key challenges associated with the inclusion of
post-acute care providers as the financially responsible entity or as
collaborators with other financially responsible entities in episode
payment models today?
What would be a sufficient financial incentive or bonus to
enhance the adoption, implementation, and upgrading of certified health
IT in post-acute care settings?
How else can episode payment models encourage the use of
certified health IT and information sharing among providers and
suppliers caring for episode payment model beneficiaries to improve
care coordination and patient outcomes?
Within the existing CJR model, are there additional
opportunities to encourage investment in adoption, implementation, and
upgrading of certified health IT among post-acute care providers to
support improvements in care coordination and patient outcomes? What
CJR model refinements could enable direct investments to support these
improvements, particularly among post-acute care providers who are
unaffiliated with CJR model participant hospitals but who provide
services to CJR model beneficiaries, including post-acute care
providers who may enter into financial arrangements with CJR model
participant hospitals as CJR collaborators?
The following is a summary of the comments received and our
responses.
Comment: Commenters recognized the importance that health IT plays
in the modern health care landscape, and overall supported the
implementation of a more robust health IT system, as such a system may
improve the ability to convey quick, accurate information from acute
care hospitals related to the discharge MS-DRG and identification of
patients who are under a bundled payment program. Many commenters
expressed a need for future episode payment models to align with EHR
incentive payments, and several commenters expressed concern that post-
acute care providers were largely disadvantaged for health IT readiness
relative to their inpatient counterparts. For example, commenters
stated that post-acute care providers and nonphysician clinicians were
marginalized by the Medicare and Medicaid EHR Incentive Programs. Some
commenters believe this population represents a significant portion of
the health care provider community without the technical and financial
support necessary to adopt and implement EHRs in a meaningful way. As
many of the measures used under meaningful use, such as e-prescribing,
are not applicable to nonphysician practitioners, commenters suggested
these and other clinicians have not had the benefit of experience with
EHRs at the same rate as their peers who work
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in hospitals. As a result, one commenter noted that small practices who
may face financial responsibility, such as physical therapists, would
face considerable challenges implementing health IT systems in their
practices.
Several commenters recommended that CMS to consider all possible
approaches to address this specific concern. One commenter, for
example, recommended an approach similar to the ACO Investment Model
program whereby participants could receive supplemental payments to
offset their upfront investment. Other commenters preferred not to
provide specific approaches as the sufficiency of financial incentives
or bonus payments may differ for example among Skilled Nursing
Facilities (SNFs), Home Health Agencies (HHAs), and institutional or
hospital-based post-acute care providers, but highlighted the need for
CMS to otherwise incentivize health IT adopters within future models.
To effectively implement any such expansion, one commenter further
stressed the need for health IT interoperability to be considered,
while another commenter stressed instead that CMS should specifically
cite the availability of the safe harbors of the Stark and Physician
Self-Referral rules, through which health care organizations could
choose to assist post-acute, or other providers, in making available
EHRs meeting certain requirements in any potential approach. One
commenter recommended that CMS continue to engage the long-term and
post-acute care community to explore in more detail potential
strategies to help overcome challenges providers face, such as the high
costs of participating in health information exchange or the
operational investment of an EHR system. Other comments on ways to
incentivize health IT investment by post-acute care providers included:
quicker or premium reimbursement for health IT adoption or upgrade,
returning savings to post-acute care providers to offset health IT
costs and incentive grants for training staff in health IT.
Response: We will consider these and other possible approaches to
address the concerns and challenges associated with implementing health
IT systems.
Final Decision: After consideration of the public comments
received, we believe we have a better understanding of the issues
related to readiness of providers and suppliers that are not hospitals
to take achieve interoperability through CEHRT in potential future
episode payment models.
B. Definition of the Episode Initiator and Selected Geographic Areas
1. Background
The new EPMs will complement the current CJR model and continue
efforts to move Medicare towards paying providers based on quality and
value. As discussed during rulemaking for the CJR model and in the EPMs
proposed rule, CMS is interested in testing and evaluating the impact
of an episode payment approach for a broad range of episodes in a
variety of other circumstances. In addition to including hospitals that
have not chosen to voluntarily participate in earlier models, we also
are interested in expanding the range of episodes included beyond
elective surgical procedures such that the impact on a broader range of
beneficiaries, hospitals, and circumstances may be tested. We also are
interested in evaluating the impact on hospitals when an increasing
percentage of care to Medicare beneficiaries is paid for through
alternative payment models.
As with CJR, we proposed in Sec. 512.105(c) that the hospital be
the accountable financial entity and that these episode payment models
be implemented in all IPPS hospitals in the geographic areas selected,
subject to exclusions as specified in Sec. Sec. 512.230 and 512.240 of
the proposed rule. While these are considered new episode payment
models and do not reflect an expansion or extension of any previous
models, they do intentionally build significantly upon the work of BPCI
and, most significantly, the framework established for CJR under 42 CFR
part 510 published on November 24, 2015 (80 FR 73274). Given the
extensive consideration given to many of these issues during the CJR
model planning and rulemaking periods, we believe this is important as
we seek to build a model that is scalable across all providers and
episode types. We also seek to limit the burden for hospitals and other
providers that may be participating across multiple episode types.
Therefore, to the extent applicable and appropriate, we have sought
consistency with rules established for the CJR model. We sought comment
on those areas where alternative options were proposed or should be
considered that would not add additional operational burden or
complexity. A summary of comments received and CMS' response to those
comments are included in the following sections.
2. Definition of Episode Initiator
Under the proposed EPMs, consistent with our episode initiator
definition under the CJR model, we proposed that episodes would begin
with the admission to an IPPS acute-care hospital that triggers an AMI,
CABG or SHFFT episode as specified in section III.C.4.a. of the
proposed rule (81 FR 50834). As with the CJR model, we proposed that
hospitals would be the only episode initiators in these episode payment
models. For purposes of these episodes payment models. The term
``hospital'' means a hospital as defined in section 1886(d)(1)(B) of
the Act. This statutory definition of hospital includes only acute care
hospitals paid under the IPPS. Under this proposal, all acute care
hospitals in Maryland would be excluded and payments to Maryland
hospitals would be excluded in the regional pricing calculations as
described in section III.D.4. of the proposed rule (81 FR 50847). This
is the same policy that is being followed with the CJR model. In
addition, we also proposed to exclude other all-payer state models
which may be implemented in the future. We welcomed comments on this
proposal and sought comment on potential approaches for including
Maryland acute-care hospitals or, potentially, other hospitals in
future all-payer state models in these episode payment models.
As implemented with the CJR model, we proposed to designate IPPS
hospitals as the episode initiators to ensure that all services covered
under FFS Medicare and furnished by EPM participant hospitals in
selected geographic areas to beneficiaries who do not meet the
exclusion criteria specified in section III.C.4. of the proposed rule
(81 FR 50834) are included. In addition, the episodes must not be BPCI
episodes that we are proposing to exclude as outlined in this section
and in section III.C.4. of the proposed rule. We believe that utilizing
the hospital admission as the episode initiator is a straightforward
approach for these models because patients covered under these DRGs and
diagnoses require hospital admission for these services, whether
provided on an emergent or planned basis. Under these new models
covering medical admissions and services that are not necessarily
elective, as stated in the proposed rule, we will be able to expand our
testing of a more generalized bundled payment model. Finally, as
described in section III.B.4. of the proposed rule (81 FR 50815) our
proposed geographic area selection approach relied upon our definition
of hospitals as the entities that initiate episodes.
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The following is a summary of the comments received on our proposed
episode definition and our responses.
Comment: We received many comments supporting our proposal to
initiate these EPM episodes of care with the inpatient hospital
admission. However, we also received multiple comments noting the
important role that physicians play in managing patient care throughout
the episode period including after discharge from the hospital. These
same commenters expressed support for more physician based payment
models so that physicians can have a more substantial role in managing
episodes.
Response: We appreciate the support commenters expressed for
initiating the EPM episodes with the inpatient hospital admission.
While we acknowledge and understand that inpatient initiated episodes
represent only one of many potential models for improving the quality
of care while restraining the growth in costs, we continue to believe
that the appropriate initiating point for the episodes in these EPMs is
the inpatient admission. Hospitals play a central role in coordinating
episode-related care and ensuring smooth transitions for beneficiaries
undergoing services related to these episodes and a large portion of a
beneficiary's recovery trajectory from an AMI or CABG or SHFFT begins
during the hospital stay which is why we are finalizing the inpatient
admission as the initiating event in the episode definition. We also
note that CMS has supported and is supporting other voluntary
demonstrations and models that focus on providing financial support for
care coordination services as recommended by these commenters. In
addition, in recent years, the range of services eligible for payment
under the Medicare physician fee schedule has expanded to include care
transition and chronic care management codes. For further discussion of
future models, we refer the reader to section III.A.3. of this final
rule, ``Future Directions for Episode Payment Models.''
We did not receive any comments related to our exclusion of
Maryland nor on the potential inclusion or exclusion of future all-
payer state models. Therefore we are finalizing our proposal to exclude
Maryland providers from this model.
Subsequent to the publication of this final rule CMS announced on
October 26, 2016 the implementation of the Vermont All Payer ACO Model
which will begin on January 1, 2017. Since this new Vermont model is an
all payer model and since we proposed to exclude all of the all payer
state models from the EPM we are also finalizing the exclusion of
Vermont providers from selection for participation in the EPMs. We note
that currently none of the MSAs in Vermont are participating in the CJR
model and would, therefore, not have been selected to participate in
the SHFFT EPM.
Final Decision: After consideration of the public comments
received, we are finalizing the proposed episode definition, without
modification, such that these EPM episodes will be initiated with the
admission to an IPPS acute-care hospital that triggers an AMI, CABG or
SHFFT episode as specified in section III.C.4.a. of this final rule. We
are also finalizing the exclusion of hospitals in Maryland and Vermont
from participation in the EPMs.
3. Financial Responsibility for the Episode of Care
As with the CJR model, and as discussed in the proposed rule, we
continue to believe it is most appropriate to identify a single type of
provider to bear financial responsibility for making repayment, if any,
to CMS under the model. Therefore, we proposed to make hospitals, as
the episode initiators, financially responsible for the episode of care
for the following several reasons:
Hospitals play a central role in coordinating episode-
related care and ensuring smooth transitions for beneficiaries
undergoing services related to SHFFT, AMI and CABG episodes. A large
portion of a beneficiary's recovery trajectory from an AMI, CABG, or
SHFFT begins during the hospital stay.
Most hospitals already have some infrastructure related to
health IT, patient and family education, and care management and
discharge planning. This includes post-acute care coordination
infrastructure and resources such as case managers, which hospitals can
build upon to achieve efficiencies under these EPMs.
By definition, these episodes always begin with an acute
care hospital stay. While often preceded by an emergency room visit and
possible transfer from another hospital's emergency room, or followed
by post-acute care, these parties are not necessarily always present
and would not be appropriate to target as the financially responsible
party for this purpose.
EPM episodes may be associated with multiple hospitalizations
through transfers. When multiple hospitalizations occur, we proposed
that the financial responsibility be given to the hospital to which the
episode is attributed, as described in section III.C.4 of the proposed
rule. We recognize that, particularly where the admission may be
preceded by an emergency room visit and subsequent transfer to a
tertiary or other regional hospital facility, patients often wish to
return home to their local area for post-acute care. Many hospitals
have recently heightened their focus on aligning their efforts with
those of community providers, both those in the immediate area as well
as more outlying areas from which they receive transfers and referrals,
to provide an improved continuum of care. In many cases, this is due to
the incentives under other CMS models and programs, including ACO
initiatives such as the Shared Savings Program, the Hospital
Readmissions Reduction Program (HRRP), and the CJR model. By focusing
on the hospital as the accountable or financially responsible entity,
we hope to continue encouraging this coordination across providers and
sought comment on ways we can best encourage these relationships within
the scope of these EPMs.
In support of our proposal that hospitals be the episode initiators
under these EPMs, we believe that hospitals are more likely than other
providers to have an adequate number of episode cases to justify an
investment in episode management for these EPMs. We also believe that
hospitals are most likely to have access to resources that would allow
them to appropriately manage and coordinate care throughout these
episodes. Finally, the hospital staff is already involved in discharge
planning and placement recommendations for Medicare beneficiaries, and
more efficient post-acute care service delivery provides substantial
opportunities for improving quality and reducing costs under EPMs. For
those hospitals that are already participating in CJR, we believe the
efforts that have been put in place to support patients receiving LEJR
will be supportive of the new EPMs proposed under this rule,
particularly for SHFFT episodes which we proposed to implement in the
same geographic areas as the CJR model.
Finally, as noted when planning for the CJR model, although the
BPCI initiative includes the possibility of a physician group practice
as a type of episode initiating participant, the physician groups
electing to participate in BPCI have done so because their practice
structure supports care redesign and other infrastructure necessary to
bear financial responsibility for episodes. These physician groups are
not necessarily representative of the typical group practice. As with
the CJR
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model, the infrastructure necessary to accept financial responsibility
for episodes is not present across all physician group practices, and
thus, as we stated in the proposed rule, we do not believe it would be
appropriate to designate physician group practices to bear the
financial responsibility for making repayments to CMS under the
proposed EPMs. We sought comment on our proposal to establish financial
responsibility and accountability under the AMI, CABG, and SHFFT EPMs
consistent with our implementation of the CJR model.
Currently, there are SHFFT, AMI, and CABG episodes being tested in
BPCI Models 2, 3 or 4. The last remaining BPCI Model 1 hospital will
end December 31, 2016 and will, therefore, not overlap with EPM. In
addition, under BPCI, there are episodes for PCI, which, if an AMI were
also involved, would fall under the AMI model proposed. We proposed
that IPPS hospitals located in an area selected for any one of the
episode payment models proposed in the proposed rule (81 FR 50834) that
also are episode initiators for episodes in the risk-bearing phase of
BPCI Models 2 or 4 be excluded from participating in the AMI, CABG, or
SHFFT EPMs if the applicable episode otherwise would qualify to be
covered under BPCI. This exclusion would be in effect only during the
time that the relevant qualifying episodes are included in one of the
BPCI models. Likewise, we proposed that if the EPM participant is not
an episode initiator for overlapping episodes under BPCI Models 2 or 4,
but these same episodes are initiated during the anchor hospitalization
by a physician group practice (PGP) under BPCI Model 2 (where the
services are provided at the episode initiating hospital) then the
episode also shall be covered under BPCI and be excluded from the EPMs
proposed under the proposed rule (81 FR 50834). Otherwise qualifying
EPM episodes (that is, those that are not part of an overlapping BPCI
AMI, CABG, PCI or SHFFT episode) at the participant hospital would be
included in these new EPMs. However, because BPCI participation is
voluntary and participating providers may select which episodes to
participate in, we proposed that a BPCI participating provider will
participate in any of the proposed AMI, CABG, or SHFFT EPMs for any
episodes not otherwise preempted under their BPCI participation. For
example, a BPCI Model 2 hospital in an AMI episode model geographic
area participating in BPCI only for CABGs will be an EPM participant in
the AMI model. Similarly, an acute care hospital participating in BPCI
for LEJR but not SHFFT episodes would be exempt from participation in
the CJR model in a CJR model geographic area but would participate in
the SHFFT model for SHFFT episodes. In addition, providers
participating in BPCI may also collaborate with an EPM participant for
episodes not covered under BPCI. It should be noted that due to
differences in how the AMI episode is defined under the AMI model
versus BPCI and the inclusion of PCI MS-DRGs under the latter, a
patient with the same discharge MS-DRG and diagnoses may qualify for a
PCI episode under BPCI and an AMI episode under the AMI model. As
stated in the proposed rule, our intent is to give precedence to BPCI
regardless of which episode a patient qualifies for if the patient
would be covered under BPCI.
In section III.D.6. of the proposed rule we discussed in more
detail how we proposed to handle situations when a beneficiary receives
services that would qualify for inclusion in more than one CMS payment
model during the same or overlapping periods of time. We welcomed input
on how these overlaps should be handled to best encourage ongoing care
coordination while minimizing the impact on other models and limiting
confusion and operational burden for providers.
While we proposed that the EPM participant be financially
responsible for the episode of care under these EPMs, we also stated
that we believe that effective care redesign requires meaningful
collaboration among acute care hospitals, post-acute care providers,
physicians, and other providers and suppliers within communities to
achieve the highest value care for Medicare beneficiaries. We continue
to believe it is essential for key providers to be aligned and engaged,
financially and otherwise, with the EPM participants, with the
potential to share financial responsibility with those EPM
participants. We noted that all relationships between and among
providers and suppliers must comply with all relevant laws and
regulations, including the fraud and abuse laws and all Medicare
payment and coverage requirements unless otherwise specified further in
this section and in sections III.I. and III.J. of the proposed rule.
Depending on a hospital's current degree of clinical integration, new
and different contractual relationships among hospitals and other
health care providers may be important, although not necessarily
required, for EPM success in a community. We acknowledge that financial
incentives for other providers may be important aspects of the model in
order for EPM participants to partner with these providers and
incentivize certain strategies to improve episode efficiency.
While we acknowledged the important role of conveners in the BPCI
model, and that AMI, CABG, and SHFFT model participants may wish to
enter into relationships with EPM collaborators and other entities in
order to manage the episode of care or distribute risk, we proposed
that the ultimate financial responsibility of the episode would remain
with the EPM participant. Exceptions to this general rule for
beneficiaries covered under certain risk bearing ACO arrangements are
outlined in section III.D.6. of this final rule. As with the CJR model,
we did not intend to restrict the ability of EPM participants to enter
into administrative or risk sharing arrangements related to these EPMs,
except to the extent that such arrangements are already restricted or
prohibited by existing law. We referred readers to section III.I. of
the final rule for further discussion of model design elements that may
outline financial arrangements between EPM participants and other
providers and suppliers.
The following is a summary of the comments received and our
responses.
Comment: We received numerous comments related to our proposal to
have the hospital be the single accountable entity for the EPM
episodes. Many commenters were supportive of this policy and, while not
ignoring the importance of other providers, agreed that hospitals were
best positioned to assume risk for these episodes. Other commenters
were less supportive of this proposal, noting that hospitals could be
disadvantaged if physicians and post-acute care providers were not also
at risk or if conflicting interests hindered their willingness to
collaborate. A few commenters expressed concern that while hospitals
would bear the risk, hospitals might be limited in their ability to
control that same risk. For example, one commenter referenced the
penalty that hospitals already face for readmissions which may not be
correlated to inpatient care. One commenter stated that post-acute care
providers would be more motivated if they were required to share in
even a small percentage of the incentives or risk directly. Another
commenter noted that the current per-diem payment system for SNFs put
SNF providers at particular risk. Although SNFs will invest resources
to reduce/shorten SNF stays, which can create significant savings for
the EPM participant, the
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commenter stated SNF providers will be disadvantaged/harmed as the
proposed regulations do not require proportional sharing of
reconciliation payments by the EPM participant with post-acute care
providers and requested that we amend the language to more clearly
outline how reconciliation payments should be shared proportionally
among all EPM collaborators, noting that this change would also likely
require these same providers to share in downside risk as well.
Other commenters objected to the hospital holding sole financial
accountability for the models as they believe that physicians,
including hospitalists, surgeons, and internal medicine subspecialists
are best positioned to impact the process of care. These commenters
stated that CMS should be giving priority to physician-centered
alternative payment models. One commenter believes that having the
hospital in charge of the bundle could give the hospital inappropriate
leverage over other participants and or lead to the exclusion of
providers if they failed to agree to the hospital's terms. Other
commenters wanted the flexibility for conveners to assume risk and
organize groups of providers, as is allowed under BPCI.
One commenter specifically stated that determination of the
accountable entity should be based not only on the ability to accept
risk but also the ability to change care delivery patterns. While one
commenter explicitly stated that ``only physicians can make the
determination as to what types of care could effectively address
patients' needs,'' that commenter also wanted payment to physicians to
be predictable and physician financial accountability limited to
``costs that are within their control.'' The perspective that
physicians were best positioned to manage the episode of care and
desire for them to have the opportunity to bear risk, particularly as
it might pertain to eligibility for advanced alternative payment model
status, was expressed by a number of commenters although the focus in
such comments was on voluntary models.
Response: We appreciate the support expressed by certain commenters
for our proposed policy to hold the initiating hospital as the
financially accountable entity for the EPM episodes. While we
acknowledge the critical importance of physicians and other providers,
in particular those providing post-acute care, in managing episodes
which extend 90 days beyond discharge from the anchor hospitalization,
we continue to believe the hospital should be the financially
accountable entity for these models. For hospitals to be successful in
managing EPMs, we firmly believe that they will need to actively
solicit the support of physicians, post-acute care providers, and other
clinical care providers in order to provide the best quality of care in
a cost effective manner. In many, if not most situations, this may
involve establishing collaborative agreements with a risk sharing
arrangement. We support other types of providers assuming risk where
they are financially able to do so and agree that providers that have a
share in the risk, both positive and negative, may be more motivated to
establish collaborative agreements. However, we do not believe that in
a model with required participation, any other provider group is
consistently as financially positioned to assume risk as is the
hospital to which the episode is attributed. We also do not want to
mandate a specific division of risk between providers or to direct the
specific terms of any collaborator agreements that may be established.
We disagree that the current proposal to make hospitals the financially
accountable entity undermines the role of the physician, and in
providing for a range of collaborator agreements, we hope that EPM
participants will actively engage in gainsharing with others. We refer
readers to section III.I of this final rule for a fuller discussion of
allowable collaborator relationships. We believe that in order to be
most successful, hospitals will reach out to other providers to
establish agreements with collaborators, although we acknowledge that
it may take time to negotiate and establish such arrangements. While
some physician groups and post-acute care providers are in a position
to take on risk, we continue to believe that many, particularly those
in smaller groups and those in more rural areas, are not and, in fact,
no commenter suggested that this was the case. Even where the focus of
a comment was on providing more opportunities for physicians to assume
risk, it was in the context of voluntary models such as BPCI. We
appreciate those comments and, in fact, will give precedence to BPCI
participants where there is such overlap. Readers are referred to
section III.D.6. of this final rule, ``Adjustments for Overlaps with
Other Innovation Center Models and CMS Programs,'' which addresses in
more detail how situations where there is an overlap between EPMs and
other episode based models will be handled. We address in section
III.D.6.b.(2). of this final rule, how patients attributed to other
physician-centric episode models will be attributed. We also note in
section III.A.3 of this final rule opportunities for future alternative
payment models which may be more physician-centric. We are committed to
testing a number of alternative payment models, many of which may be
voluntary and more appropriate for physicians or other providers to
assume risk.
Comment: We received a few comments that not only advocated for
more flexibility in which entity would be allowed to assume risk for
the episode but also suggested that CMS more actively encourage
collaboration by providing more specific operational guidance regarding
how risk should be shared among different providers. A few commenters
noted that financial agreements may not always be feasible. One
commenter noted that in markets where physicians, hospitals and post-
acute care providers already work well together, the foundation for
effective gainsharing arrangements are more likely to be in place.
Others noted that some organizations may be willing to share in any
savings but not be willing to accept downside risk.
One commenter recommended that CMS require that EPM participants
execute gainsharing arrangements with providers to establish a third
party entity to receive and distribute reconciliation payments in
accordance with the terms of such sharing agreements.
Response: We acknowledge the challenges that some EPM participants
may have in establishing effective collaborative agreements. Similarly,
we acknowledge the potential challenges that non-hospital providers
such as physicians and post-acute care providers may have in getting
EPM participants to share risk in a manner that is believed to be
equitable to all. However, we do not believe it is appropriate for CMS
to either require or establish specific criteria for the terms of such
agreements nor to specify how they should be operationalized. We
continue to believe, however, that the most successful EPMs will be
motivated to engage other providers so that interests and incentives
are aligned. We refer readers to section III.I. of this final rule,
``Financial Arrangements under EPM,'' for a full discussion of EPM
financial arrangements.
Final Decision: After consideration of the public comments
received, we are finalizing the proposal, without modification, to make
hospitals the episode initiators and financially responsible for the
episode of care.
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4. Geographic Unit of Selection and Exclusion of Selected Hospitals
In order to determine the geographic unit of selection for these
episode payment models, we conducted an analysis similar to that used
for the CJR model. For the CJR model, we considered using a stratified
random sampling methodology to select: (1) Certain counties based on
their Core-Based Statistical Area (CBSA) status; (2) certain zip codes
based on their Hospital Referral Regions (HRR) status or (3) certain
states. We concluded that selection based on MSAs provided the best
balance between choosing smaller geographic units while still capturing
the impact of market patterns reflecting the mobility of patients and
providers and limiting the potential risk for patient shifting and
steerage between MSAs. HRRs are based on where patients receive
selected tertiary care services, which do not include orthopedic
services. Therefore, HRRs may not be representative of where patients
receive specialty orthopedic care or more routine orthopedic services
such as hip and knee arthroplasty. Selection of states rather than MSAs
would have greatly reduced the number of independent geographic areas
subject to selection and, therefore, the statistical power of the
evaluation. For similar reasons and to maintain consistency with the
CJR model, we proposed implementation at the MSA level.
We also similarly considered whether these new models should be
limited to hospitals where a high volume of these episodes occur, which
would result in a more narrow test on the effects of an episode-based
payment, or whether to include all hospitals in particular geographic
areas, which would result in testing the effects of an episode-based
payment approach more broadly across an accountable care community
seeking to coordinate care longitudinally across settings. However, as
with the CJR model, if we were to limit participation based on volume,
there would be more potential for behavioral changes that could include
patient shifting and steering between hospitals in a given geographic
area that could impact the test. Additionally, this approach would
provide less information on testing payments for these episodes across
a wide variety of hospitals with different characteristics. Selecting
geographic areas and including all IPPS hospitals in those areas not
otherwise excluded due to BPCI overlap as previously described and in
section III.D.6. of the proposed rule as model participants would help
to minimize the risk of participant hospitals shifting higher cost
cases out of the EPM.
In determining where to implement these EPMs, we also considered
whether implementation of the CJR model in the same geographic area
should be a factor. We realize that there is likely to be considerable
overlap in the selection criteria between MSAs where the SHFFT EPM
might be appropriate and those MSAs where the CJR model is now being
implemented. While limiting burden on hospitals is an important
consideration, we also believe that the infrastructure being put in
place as a result of the CJR model presents significant advantages for
implementation of the SHFFT model. For similar reasons, and in order to
minimize patient steerage and/or transfer for reasons due solely to the
implementation of these new payment models, we believe that it is
appropriate to implement the AMI model and CABG model together in the
same geographic areas, albeit not necessarily in the same areas as the
CJR and SHFFT models.
Therefore, given the authority in section 1115A(a)(5) of the Act,
which allows the Secretary to elect to limit testing of a model to
certain geographic areas, we proposed that the SHFFT model be
implemented in those MSAs where the CJR model is being implemented.
We also proposed that the AMI and CABG models be implemented in
MSAs selected independently based on the criteria discussed in the
proposed rule (81 FR 50815). This would result in four separate
categories of MSAs: (1) MSAs where only the CJR and SHFFT model
episodes are being implemented; (2) MSAs where only the CABG model and
AMI model episodes are being implemented; (3) MSAs where the CJR as
well as the AMI, CABG, and SHFFT models are being implemented; and (4)
MSAs where neither CJR nor any of the new episode payment models are
being implemented. We believe this will provide an opportunity to test
the impact of implementing EPMs across not only a greater diversity of
episodes but also as an increasing percentage of hospital discharges.
We sought comment on our proposal to implement the SHFFT model in the
same geographic region as the CJR model and to implement both the AMI
model and the CABG model in the same MSAs, some of which may overlap
with MSAs where the CJR and SHFFT models also are being implemented.
The following is a summary of the comments received and our
responses.
Comment: While several commenters explicitly noted concurrence with
our proposed method for selecting the MSAs where these models will be
implemented, we did receive a few comments related to the selection of
areas based on MSAs vs. other geographic units such as CBSAs as well as
other recommended criteria upon which to base our selection. We address
some of the specific factors in the comments located in this section.
Independent of the selection methodology, several commenters requested
that CMS publish a list of the hospitals CMS believed were in the
selected MSAs and allow hospitals 60 days to comment. Other commenters
requested that CMS publish the list of MSAs selected as soon as
possible to allow those hospitals impacted additional preparatory time
prior to the initial effective date of EPMs. Other commenters
emphasized the importance of maintaining beneficiary freedom of choice
in selecting where and how to receive care regardless of the
beneficiary's geographic residence or the MSAs selected for EPMs.
Response: With regard to MSAs as the geographic unit of selection,
we continue to believe, consistent with CJR, that MSAs allow us to
observe the impact of the model in a variety of circumstances and
provide the best balance between choosing smaller geographic units
while still capturing the impact of market patterns reflecting the
mobility of patients and providers. We also believe that MSAs limit the
potential risk for patient shifting and steerage. As such, we see no
reason to change the unit of selection or to be inconsistent with what
has already been implemented with CJR. For an in depth discussion of
this, we refer the reader to the final CJR rule (42 CFR part 510, 80 FR
73288). We concur that it is important that all participants clearly
understand which hospitals will be impacted. Prior to implementation
and in conjunction with the publication of this final rule, CMS will
publish a list of hospitals that, based on the geographic location
associated with the hospital's CMS Certification Number (CCN), we
believe are located in the selected MSAs and will be subject to
participation in these EPMs. Hospitals identified using this method
will have the opportunity to correct any information CMS has on file
that may impact whether they are or are not in a selected MSA by
contacting epm@cms.hhs.gov within 45 days after the publication of the
Final Rule. Finally, we concur that beneficiaries continue to have the
freedom to choose where they will receive services, regardless of the
payment model in place in a particular geographic area. We refer
readers to
[[Page 226]]
section III.G. of this final rule, ``Monitoring and Beneficiary
Protection,'' for a discussion of these issues.
Comment: A number of commenters expressed concern about
implementing the SHFFT EPMs in those MSAs where the CJR model is being
implemented. Some commenters expressed concern that we were adding the
SHFFT model to the existing CJR model. Other commenters expressed
concern that sufficient time had not elapsed to allow hospitals or CMS
to learn from their experience. Many believe they needed more time to
be able to analyze the results from at least the first year of CJR as
well as incorporating findings from the BPCI experience before adding
the additional burden of implementing a new model with required
participation. While both CJR and SHFFT involve some of the same
providers and specialties, some commenters noted that the SHFFT patient
population was distinctly different requiring different care pathways
and resources. Because of the concern about additional burden on those
MSAs where the CJR model has been implemented, some commenters believe
that those same MSAs should, therefore, be exempt from implementing the
additional cardiac EPMs.
Response: To clarify for commenters, the SHFFT model is separate
and distinct from the CJR model although it is designed to run in the
same MSAs in which the CJR model is currently operational. We
acknowledge the challenges that hospitals implementing CJR may have in
order to implement the SHFFT EPM. While recognizing that the patients
covered under the SHFFT EPM may be frailer and potentially require
different and/or a more intensive level of care, we also continue to
believe that SHFFT is similar to CJR in that it involves many of the
same specialties and provider types. While there may be different care
pathways, we hope that much of the infrastructure and collaborator
agreements put in place will provide a solid base upon which to build
for SHFFT. As CMS seeks to move away from fee for service payment
systems to more value based purchasing, we believe that SHFFT
represents a reasonable next step in this transition.
We also acknowledge that in those MSAs where the cardiac EPMs will
be alongside CJR and now SHFFT, EPM participants will face additional
burdens and challenges. However, we do not believe that it is
appropriate to exclude those MSAs where CJR and SHFFT will be
implemented from eligibility for selection for the cardiac EPMs.
Exclusion of these MSAs would result in a comparative over
representation in the cardiac EPMs of lower cost and lower population
MSAs due to the manner in which the CJR MSAs were selected. For a full
discussion of the criteria for selecting cardiac EPMs, we refer readers
to section III.B.5. of this final rule, ``Overview and Options for
Geographic Area Selection for AMI and CABG Episodes''. As we move
towards more inpatient care being covered under these types of models,
we will monitor and evaluate the impact on different types of hospitals
implementing multiple EPMs so as to minimize operational burden and
improve outcomes.
Comment: Several commenters did not disagree with the use of MSAs
specifically, but did note the potential for negative impact on certain
hospitals in a model where all hospitals in the MSA providing the
covered services are required to participate. This included concern for
both high performing regional and national referral centers which may
already be providing high quality care at a lower cost as well as
hospitals with more limited numbers of eligible discharges and/or those
serving at risk populations which often have lower operating margins
and thus may be at greater financial risk. These commenters suggested
that demographic factors such as age, race, and poverty levels could be
used to limit which MSAs were selected.
Response: We acknowledge that some hospitals may face particular
challenges in implementing EPMs whether it be due to demographic
factors related to their patient base, a lower number of potential EPMs
each year, or other factors. A key reason for doing a model with
required participation is, in fact, to examine and better understand
the impact of a model on a broader range of facility types and
communities than are usually included in a voluntary model. Although we
do not believe that using specific demographic factors in MSA selection
is appropriate, in response to comments on other sections of this rule
around risk-adjustment, we are finalizing a timeframe for the
implementation of downside risk that allows us time to look carefully
at different approaches for recognizing and adjusting for risk in these
models which we will discuss via notice and comment rulemaking for FY
2019 and we believe that these actions will help to resolve concerns
expressed regarding greater financial risk for high performing regional
and national referral centers.
A key rationale for conducting a model with required participation
is the ability to examine variations in the impact of the model on a
broad range of hospitals in a variety of different market conditions in
order to better understand how the model operates in a variety of
circumstances. Although demographic factors are not proposed to be part
of the selection process for MSAs, we do consider, as noted in the
proposed and this final rule, these factors to be important to the
proper understanding of the impact of the models and where is more or
less successful. The evaluation will consider the suggested demographic
domains and other measures in determining which MSAs are appropriate
comparison markets as well as for possible subgroup analyses.
Comment: A few commenters suggested eliminating those MSAs that had
a higher penetration of Medicare Advantage plans or suggested that we
select MSAs that will minimize overlap with BPCI and ACO participating
hospitals.
Response: We note in this rule the reasons for aligning the MSAs
where the SHFFT EPM will be implemented with those MSAs where the CJR
model has already been implemented. In doing so, we accept the
exclusion of those MSAs that were excluded from the CJR model due to
the limited volume of LEJR procedures performed there.
In the proposed rule we similarly proposed elimination of some MSAs
from selection for the cardiac EPMs due to having lower numbers of
episodes and having a higher number of episodes covered under the BPCI
models. We refer readers to section III.B.5. of this final rule for a
full discussion of the selection criteria for MSAs where the cardiac
episodes will be implemented.
Final Decision: After consideration of the public comments
received, we are finalizing the proposal, without modification, to
implement the SHFFT EPM in those MSAs where the CJR model is being
implemented. Further, we are finalizing the proposal to implement the
cardiac EPMs in randomly selected MSAs from among all those in the
country meeting the criteria specified in section III.B.5. of this
final rule.
5. Overview and Options for Geographic Area Selection for AMI and CABG
Episodes
We proposed that the AMI and CABG EPMs be implemented together in
the same MSAs. These AMI/CABG-participating MSAs may or may not also be
CJR/SHFFT-EPM participating MSAs. The selection of MSAs for AMI/CABG
EPMs would occur through a random selection of eligible MSAs.
We proposed to require participation in the AMI and CABG models of
all hospitals, with limited exceptions as
[[Page 227]]
previously discussed in section III.B.4. of the proposed rule, paid
under the IPPS that are physically located in a county in an MSA
selected through the methodology outlined in section III.B.5.b. of the
proposed rule (81 FR 50815), to test and evaluate the effects of an
episode-based payment approach for the proposed EPMs. We proposed to
determine that a hospital is located in an area selected if the
hospital is physically located within the boundary of any of the
counties in that MSA as of the date the selection is made.
Although MSAs are revised periodically, with counties added or
removed from certain MSAs, we proposed to maintain the same cohort of
selected hospitals throughout the 5-year performance periods of the
EPMs with limited exceptions as described later in this section. Thus,
we proposed neither to add hospitals to an EPM if after the start of
such EPM new counties are added to one of the selected MSAs nor to
remove hospitals from an EPM if counties are removed from one of the
selected MSAs. We believe that this approach will best maintain the
consistency of the participants in the EPMs, which is crucial for our
ability to evaluate their respective results. However, we retain the
possibility of adding a hospital that is opened or incorporated within
one of the selected counties after the selection is made and during the
period of performance. (See section III.D. of this final rule for
discussion of how target prices will be determined for such hospitals.)
The manner in which CMS tracks and identifies hospitals is through
the CMS Certification Number (CCN). In keeping with this approach,
these EPMs will administer model related activities at the CCN level
including the determination of physical location. The physical location
associated with the CCN at the time of an EPM's start will be used to
determine whether that CCN is located in a selected MSA. For hospitals
that share a CCN across various locations, all hospitals under that CCN
would be required to participate in the applicable EPM if the physical
address associated with the CCN is in the MSA selected, unless
otherwise excluded. Similarly, all hospitals under the same CCN, even
if some are physically located in the MSA selected for participation,
would not participate in the applicable EPM if the physical address
associated with the CCN is not in the MSA.
We considered including hospitals in a given MSA based on whether
the hospitals were classified into the MSA for IPPS wage index
purposes. However, such a process would be more complicated, and we
could not find any compelling reasons favoring such approach. For
example, we could assign hospitals to metro divisions of MSAs when
those divisions exist. In addition, there is the IPPS process of
geographic reclassification by which a hospital's payments can be based
on a geographic area other than the one where the hospital is
physically located. For the purpose of the EPMs, it is simpler and more
straightforward to use a hospital's physical location as the basis of
its assignment to a geographic unit. This decision would have no impact
on a hospital's payment under the IPPS. We sought comment on our
proposal to include a hospital as an EPM participant based on the
physical location associated with the CCN of the hospital in one of the
counties included in a selected MSA.
The following is a summary of the comments received and our
responses.
Comment: One commenter expressed that implementing the two cardiac
EPMs, CABG and AMI, in the same geographic areas would overburden
participant hospitals. They stated that the two cardiac conditions are
characterized by clinically different populations and require distinct
care teams and the opportunities for common care redesign approaches
are limited.
Response: We understand the amount of effort required to redesign
care processes and that often these are specific to a condition and not
always immediately transferrable between conditions. In regards to
implementing two cardiac episodes there is an expectation that some
economies of scale will present themselves with the cardiac episode-
based approaches even though the care teams and patient populations are
distinct.
As discussed in section III.C. of this final rule, the AMI and CABG
model episodes primarily include beneficiaries with cardiovascular
disease, a chronic condition which likely contributed to the acute
events or procedures that initiate the episodes. Beneficiaries
experiencing an AMI can be treated by different clinical modalities
including medical management and surgical intervention such as PCI and
CABG. The decision as to which treatment is medically appropriate for a
given beneficiary is both complex and subject to evolving medical
knowledge and practice norms. Furthermore, approximately 30 percent of
CABGs are performed during the care of AMIs. Because of the close
connection between these two models, CMS believes that testing the AMI
and the CABG EPMs in the same markets decreases the probability that
clinical decision making regarding the course of treatments would be
unduly influenced by inclusion or exclusion in one of the two cardiac
EPMs. If the two cardiac EPMs were in different areas, the AMI EPM
would be structured in such a way as to include AMIs treated with CABG.
Thus, the separation of the two cardiac EPMs into different MSAs would
not reduce the burdens associated with hospitals who are simultaneously
needing to manage patients treated under a variety of modalities. It
would, on the other hand, conceivably increase the complexity of
management for participants who would be faced with the situation of
having only the 30 percent of CABGs done in conjunction with an AMI
included in a model.
Comment: One commenter requested that if a health system had member
hospitals within MSAs selected for inclusion in a cardiac EPM that they
be allowed to have their member hospitals in non-selected areas also be
included in the model. They stated that the ability to have all of
their member hospitals in one model would allow for care to be provided
under a unified system and would result in increased coordination.
Response: The cardiac EPMs are structured as required models. As
such, they will require hospitals within selected geographic areas to
participate (unless otherwise excluded as set forth in this final
rule). Hospitals who are not in a selected MSA but are part of a health
system that includes selected included hospitals will not subject to
the EPM rules and incentives structures. However, if a health system
wishes to implement certain care coordination activities across their
entire spectrum of hospitals they would not be precluded from doing so
as long as they comply with current regulations and law. The inclusion
of additional hospitals outside of these selected areas would
constitute a major change to the model that was not considered in the
proposed rule. CMS previously offered solicited participation in the
BPCI initiative, a bundled payment model. Please refer to section
III.A.3. of this final rule for a discussion of the possibility of
future bundled payment models.
Final Decision: After consideration of the public comments
received, we are finalizing the proposal, without modification, to
implement the CABG and the AMI EPMs in the same areas, and to
administer model-related activities at the CCN level including the
determination of physical location. The physical location associated
with the CCN at the time of an EPM's start will
[[Page 228]]
be used to determine whether that CCN is located in a selected MSA.
a. Exclusion of Certain MSAs
We considered whether certain MSAs should be exempt from the
possibility of selection for the AMI/CABG EPMs' implementation. We
considered exclusions based on the anticipated number of AMI episodes
and CABG episodes in the MSA. We also considered exclusions based on
the degree to which such EPMs' episodes would be impacted by overlaps
with other payment initiatives, including BPCI and ACOs.
First, we considered the advisability of MSA exclusions based on
the number of episodes in a year. We identified qualifying AMI and CABG
episodes that initiated between January 1, 2014, and December 31, 2014.
AMI and CABG episodes were attributed to an MSA based on the location
of the CCN associated with the initiating hospital using the Provider
of Service file. Due to the smaller number of relevant AMI and CABG
episodes occurring in some MSAs, an exclusion rule that required a
large number of episodes in each MSA would result in fewer MSAs
eligible for selection than was necessary given the desired number of
MSAs and the requirement to have 50 percent or more of MSAs remain in a
pool of possible comparison MSAs. From the perspective of evaluating
changes to utilization and spending under EPMs, there is no analytic
need to eliminate MSAs with small numbers. In fact, including smaller
MSAs has the analytic advantage of giving CMS more experience operating
EPMs in the smaller-MSA contexts that will help us generalize our EPM-
evaluation findings.
We have a strong interest in being able to observe how well EPMs
operate in areas with a lower volume of episodes, and, in particular,
the consequences of the models for AMI episodes where CABG is not
commonly performed or where standard practice is to refer all CABGs
outside of the MSA. Given our desire to assess the operation of the AMI
EPM in areas with little or no CABG episodes and the desire to have the
two cardiac EPMs be administered together in the same MSAs, we proposed
that the MSA exclusion rules be based on the number of AMI episodes
only. This will allow for the inclusion of MSAs with no CABGs.
There is no analytic requirement for a minimum number of cases and
there are advantages to including smaller cities. At the same time, we
acknowledge that areas with few AMI cases may believe that they will
face challenges under the EPMs. Therefore, we proposed an exclusion
rule that MSAs with fewer than 75 AMI episodes (determined as discussed
in section III.C. of this final rule) will be removed from the
possibility of selection. Cases in hospitals paid under either the CAH
methodology or the Maryland All-Payer Model are not included in the
count of eligible episodes. We examined a number of different minimum-
episode-number cutoffs. The use of the 75 AMIs in a year was a designed
to balance limiting the impact of outlier cases on the MSA average
episode spending and the desire to retain a non-negligible
representation of MSAs in the under 100,000 population and the 100,000
to 200,000 population ranges in our selection pool. The application of
Exclusion Rule 1: ``Less than 75 qualifying AMI episodes in the
reference year'' resulted in the removal of 49 MSAs from possible
selection.
Second, we assessed exclusion rules based on overlap with BPCI. We
proposed Exclusion Rule 2 such that MSAs are removed from possible
selection if there were fewer than 75 non-BPCI AMI episodes in the MSA
in the reference year. For the purposes of this exclusion, the number
of non-BPCI episodes was estimated by subtracting BPCI cases from the
total number of cases used in Exclusion Rule 1. BPCI cases for this
purpose are ones during the reference year associated with a hospital
or a PGP BPCI Model 2 or 4 episode initiator participating in an AMI,
PCI, or CABG episode as of January 1, 2016. Such criterion removed an
additional 26 MSAs from potential selection.
Third, we proposed to exclude MSAs from possible selection based on
whether the number of non-BPCI AMI episodes calculated under Exclusion
Rule 2 is less than 50 percent of the total number of AMI episodes
calculated under Exclusion Rule 1. We anticipate that some degree of
overlap in the BPCI and other EPMs will be mutually helpful. However,
we acknowledge that some providers may have concerns that a BPCI Model
2 AMI and PCI participation rate of more than 50 percent may impair the
ability of participants in either the EPMs or the BPCI models to
succeed in the objectives of their respective initiatives. As a result
of this third criterion, 13 additional MSAs were removed from possible
selection.
We considered whether there should be an exclusion rule based on
the anticipated degree of overlap between the AMI and CABG EPMs and
patients who are aligned prospectively to ACOs that are taking two-
sided risk, such as ACOs participating in the Next Generation ACO model
or Track 3 of the Shared Savings Program. We examined numbers
associated with ACOs meeting this status as of May 1, 2016, and this
examination did not result in any additional MSAs falling below the
threshold of 75 AMI episodes. Consequently, we did not propose any MSA
exclusion rule based on the presence of ACOs.
Please refer to Table 1 for the status of each MSA based on these
exclusion criteria, available at https://innovation.cms.gov/initiatives/epm. After applying these three exclusions, 294 MSAs out of 384 total
MSAs are eligible for selection using our proposed selection
methodology.
Table 1--MSA Exclusion Rule Status and Eligibility for Selection Status for Inclusion in AMI and CABG EPMs in the Proposed Rule
--------------------------------------------------------------------------------------------------------------------------------------------------------
Rule 2: 75+ non- BPCI Rule 3: <50% BPCI MSA eligible for
CBSA_OMB MSA name Rule 1: 75+ AMIs AMI AMI selection
--------------------------------------------------------------------------------------------------------------------------------------------------------
10180............................. Abilene, TX............... Pass................. Pass................. Pass................ Include.
10380............................. Aguadilla-Isabela, PR..... Fail................. Fail................. Pass................ Exclude.
10420............................. Akron, OH................. Pass................. Pass................. Pass................ Include.
10500............................. Albany, GA................ Pass................. Pass................. Pass................ Include.
10540............................. Albany, OR................ Fail................. Fail................. Pass................ Exclude.
10580............................. Albany-Schenectady-Troy, Pass................. Pass................. Fail................ Exclude.
NY.
10740............................. Albuquerque, NM........... Pass................. Pass................. Pass................ Include.
10780............................. Alexandria, LA............ Pass................. Pass................. Pass................ Include.
[[Page 229]]
10900............................. Allentown-Bethlehem- Pass................. Pass................. Pass................ Include.
Easton, PA-NJ.
11020............................. Altoona, PA............... Pass................. Pass................. Pass................ Include.
11100............................. Amarillo, TX.............. Pass................. Pass................. Pass................ Include.
11180............................. Ames, IA.................. Pass................. Pass................. Pass................ Include.
11260............................. Anchorage, AK............. Pass................. Pass................. Pass................ Include.
11460............................. Ann Arbor, MI............. Pass................. Pass................. Pass................ Include.
11500............................. Anniston-Oxford- Pass................. Pass................. Pass................ Include.
Jacksonville, AL.
11540............................. Appleton, WI.............. Pass................. Pass................. Pass................ Include.
11640............................. Arecibo, PR............... Fail................. Fail................. Pass................ Exclude.
11700............................. Asheville, NC............. Pass................. Pass................. Pass................ Include.
12020............................. Athens-Clarke County, GA.. Pass................. Pass................. Pass................ Include.
12060............................. Atlanta-Sandy Springs- Pass................. Pass................. Pass................ Include.
Roswell, GA.
12100............................. Atlantic City-Hammonton, Pass................. Pass................. Pass................ Include.
NJ.
12220............................. Auburn-Opelika, AL........ Pass................. Pass................. Pass................ Include.
12260............................. Augusta-Richmond County, Pass................. Pass................. Pass................ Include.
GA-SC.
12420............................. Austin-Round Rock, TX..... Pass................. Pass................. Pass................ Include.
12540............................. Bakersfield, CA........... Pass................. Pass................. Fail................ Exclude.
12620............................. Bangor, ME................ Pass................. Pass................. Pass................ Include.
12700............................. Barnstable Town, MA....... Pass................. Pass................. Pass................ Include.
12940............................. Baton Rouge, LA........... Pass................. Pass................. Pass................ Include.
12980............................. Battle Creek, MI.......... Fail................. Fail................. Pass................ Exclude.
13020............................. Bay City, MI.............. Pass................. Pass................. Pass................ Include.
13140............................. Beaumont-Port Arthur, TX.. Pass................. Pass................. Pass................ Include.
13220............................. Beckley, WV............... Pass................. Pass................. Pass................ Include.
13380............................. Bellingham, WA............ Pass................. Pass................. Pass................ Include.
13460............................. Bend-Redmond, OR.......... Pass................. Pass................. Pass................ Include.
13740............................. Billings, MT.............. Pass................. Pass................. Pass................ Include.
13780............................. Binghamton, NY............ Pass................. Fail................. Fail................ Exclude.
13820............................. Birmingham-Hoover, AL..... Pass................. Pass................. Pass................ Include.
13900............................. Bismarck, ND.............. Pass................. Pass................. Pass................ Include.
13980............................. Blacksburg-Christiansburg- Fail................. Fail................. Pass................ Exclude.
Radford, VA.
14010............................. Bloomington, IL........... Pass................. Pass................. Pass................ Include.
14020............................. Bloomington, IN........... Pass................. Pass................. Pass................ Include.
14100............................. Bloomsburg-Berwick, PA.... Pass................. Pass................. Pass................ Include.
14260............................. Boise City, ID............ Pass................. Pass................. Pass................ Include.
14460............................. Boston-Cambridge-Newton, Pass................. Pass................. Pass................ Include.
MA-NH.
14500............................. Boulder, CO............... Pass................. Fail................. Pass................ Exclude.
14540............................. Bowling Green, KY......... Pass................. Fail................. Fail................ Exclude.
14740............................. Bremerton-Silverdale, WA.. Pass................. Fail................. Fail................ Exclude.
14860............................. Bridgeport-Stamford- Pass................. Pass................. Pass................ Include.
Norwalk, CT.
15180............................. Brownsville-Harlingen, TX. Pass................. Pass................. Pass................ Include.
15260............................. Brunswick, GA............. Pass................. Pass................. Pass................ Include.
15380............................. Buffalo-Cheektowaga- Pass................. Pass................. Fail................ Exclude.
Niagara Falls, NY.
15500............................. Burlington, NC............ Fail................. Fail................. Pass................ Exclude.
15540............................. Burlington-South Pass................. Pass................. Pass................ Include.
Burlington, VT.
15940............................. Canton-Massillon, OH...... Pass................. Pass................. Pass................ Include.
15980............................. Cape Coral-Fort Myers, FL. Pass................. Pass................. Pass................ Include.
16020............................. Cape Girardeau, MO-IL..... Pass................. Pass................. Pass................ Include.
16060............................. Carbondale-Marion, IL..... Pass................. Pass................. Pass................ Include.
16180............................. Carson City, NV........... Pass................. Pass................. Pass................ Include.
16220............................. Casper, WY................ Pass................. Fail................. Pass................ Exclude.
16300............................. Cedar Rapids, IA.......... Pass................. Pass................. Pass................ Include.
16540............................. Chambersburg-Waynesboro, Pass................. Pass................. Pass................ Include.
PA.
16580............................. Champaign-Urbana, IL...... Pass................. Pass................. Pass................ Include.
16620............................. Charleston, WV............ Pass................. Pass................. Pass................ Include.
16700............................. Charleston-North Pass................. Pass................. Pass................ Include.
Charleston, SC.
16740............................. Charlotte-Concord- Pass................. Pass................. Pass................ Include.
Gastonia, NC-SC.
16820............................. Charlottesville, VA....... Pass................. Pass................. Pass................ Include.
16860............................. Chattanooga, TN-GA........ Pass................. Pass................. Pass................ Include.
16940............................. Cheyenne, WY.............. Pass................. Pass................. Pass................ Include.
16980............................. Chicago-Naperville-Elgin, Pass................. Pass................. Pass................ Include.
IL-IN-WI.
17020............................. Chico, CA................. Pass................. Pass................. Pass................ Include.
17140............................. Cincinnati, OH-KY-IN...... Pass................. Pass................. Pass................ Include.
17300............................. Clarksville, TN-KY........ Pass................. Pass................. Pass................ Include.
17420............................. Cleveland, TN............. Fail................. Fail................. Pass................ Exclude.
17460............................. Cleveland-Elyria, OH...... Pass................. Pass................. Pass................ Include.
17660............................. Coeur d'Alene, ID......... Pass................. Pass................. Pass................ Include.
17780............................. College Station-Bryan, TX. Pass................. Pass................. Pass................ Include.
[[Page 230]]
17820............................. Colorado Springs, CO...... Pass................. Pass................. Pass................ Include.
17860............................. Columbia, MO.............. Pass................. Pass................. Pass................ Include.
17900............................. Columbia, SC.............. Pass................. Pass................. Pass................ Include.
17980............................. Columbus, GA-AL........... Pass................. Pass................. Pass................ Include.
18020............................. Columbus, IN.............. Pass................. Pass................. Pass................ Include.
18140............................. Columbus, OH.............. Pass................. Pass................. Fail................ Exclude.
18580............................. Corpus Christi, TX........ Pass................. Pass................. Pass................ Include.
18700............................. Corvallis, OR............. Pass................. Pass................. Pass................ Include.
18880............................. Crestview-Fort Walton Pass................. Pass................. Pass................ Include.
Beach-Destin, FL.
19100............................. Dallas-Fort Worth- Pass................. Pass................. Pass................ Include.
Arlington, TX.
19140............................. Dalton, GA................ Pass................. Fail................. Fail................ Exclude.
19180............................. Danville, IL.............. Fail................. Fail................. Pass................ Exclude.
19300............................. Daphne-Fairhope-Foley, AL. Pass................. Pass................. Pass................ Include.
19340............................. Davenport-Moline-Rock Pass................. Pass................. Pass................ Include.
Island, IA-IL.
19380............................. Dayton, OH................ Pass................. Pass................. Pass................ Include.
19460............................. Decatur, AL............... Fail................. Fail................. Pass................ Exclude.
19500............................. Decatur, IL............... Pass................. Pass................. Pass................ Include.
19660............................. Deltona-Daytona Beach- Pass................. Pass................. Pass................ Include.
Ormond Beach, FL.
19740............................. Denver-Aurora-Lakewood, CO Pass................. Pass................. Pass................ Include.
19780............................. Des Moines-West Des Pass................. Pass................. Pass................ Include.
Moines, IA.
19820............................. Detroit-Warren-Dearborn, Pass................. Pass................. Pass................ Include.
MI.
20020............................. Dothan, AL................ Pass................. Pass................. Pass................ Include.
20100............................. Dover, DE................. Pass................. Pass................. Pass................ Include.
20220............................. Dubuque, IA............... Pass................. Fail................. Fail................ Exclude.
20260............................. Duluth, MN-WI............. Pass................. Pass................. Pass................ Include.
20500............................. Durham-Chapel Hill, NC.... Pass................. Pass................. Pass................ Include.
20700............................. East Stroudsburg, PA...... Pass................. Fail................. Pass................ Exclude.
20740............................. Eau Claire, WI............ Pass................. Pass................. Pass................ Include.
20940............................. El Centro, CA............. Fail................. Fail................. Fail................ Exclude.
21060............................. Elizabethtown-Fort Knox, Pass................. Pass................. Pass................ Include.
KY.
21140............................. Elkhart-Goshen, IN........ Pass................. Pass................. Pass................ Include.
21300............................. Elmira, NY................ Pass................. Pass................. Pass................ Include.
21340............................. El Paso, TX............... Pass................. Pass................. Pass................ Include.
21500............................. Erie, PA.................. Pass................. Pass................. Pass................ Include.
21660............................. Eugene, OR................ Pass................. Pass................. Pass................ Include.
21780............................. Evansville, IN-KY......... Pass................. Pass................. Pass................ Include.
21820............................. Fairbanks, AK............. Fail................. Fail................. Pass................ Exclude.
22020............................. Fargo, ND-MN.............. Pass................. Pass................. Pass................ Include.
22140............................. Farmington, NM............ Pass................. Pass................. Pass................ Include.
22180............................. Fayetteville, NC.......... Pass................. Pass................. Pass................ Include.
22220............................. Fayetteville-Springdale- Pass................. Pass................. Pass................ Include.
Rogers, AR-MO.
22380............................. Flagstaff, AZ............. Fail................. Fail................. Pass................ Exclude.
22420............................. Flint, MI................. Pass................. Pass................. Pass................ Include.
22500............................. Florence, SC.............. Pass................. Pass................. Pass................ Include.
22520............................. Florence-Muscle Shoals, AL Pass................. Pass................. Pass................ Include.
22540............................. Fond du Lac, WI........... Fail................. Fail................. Pass................ Exclude.
22660............................. Fort Collins, CO.......... Pass................. Pass................. Pass................ Include.
22900............................. Fort Smith, AR-OK......... Pass................. Pass................. Fail................ Exclude.
23060............................. Fort Wayne, IN............ Pass................. Pass................. Pass................ Include.
23420............................. Fresno, CA................ Pass................. Pass................. Pass................ Include.
23460............................. Gadsden, AL............... Pass................. Pass................. Pass................ Include.
23540............................. Gainesville, FL........... Pass................. Pass................. Pass................ Include.
23580............................. Gainesville, GA........... Pass................. Pass................. Pass................ Include.
23900............................. Gettysburg, PA............ Fail................. Fail................. Pass................ Exclude.
24020............................. Glens Falls, NY........... Fail................. Fail................. Pass................ Exclude.
24140............................. Goldsboro, NC............. Fail................. Fail................. Pass................ Exclude.
24220............................. Grand Forks, ND-MN........ Pass................. Pass................. Pass................ Include.
24260............................. Grand Island, NE.......... Fail................. Fail................. Pass................ Exclude.
24300............................. Grand Junction, CO........ Pass................. Pass................. Pass................ Include.
24340............................. Grand Rapids-Wyoming, MI.. Pass................. Pass................. Pass................ Include.
24420............................. Grants Pass, OR........... Fail................. Fail................. Pass................ Exclude.
24500............................. Great Falls, MT........... Fail................. Fail................. Pass................ Exclude.
24540............................. Greeley, CO............... Pass................. Pass................. Pass................ Include.
24580............................. Green Bay, WI............. Pass................. Pass................. Pass................ Include.
24660............................. Greensboro-High Point, NC. Pass................. Pass................. Pass................ Include.
24780............................. Greenville, NC............ Pass................. Pass................. Pass................ Include.
24860............................. Greenville-Anderson- Pass................. Pass................. Pass................ Include.
Mauldin, SC.
25020............................. Guayama, PR............... Fail................. Fail................. Pass................ Exclude.
[[Page 231]]
25060............................. Gulfport-Biloxi- Pass................. Pass................. Pass................ Include.
Pascagoula, MS.
25180............................. Hagerstown-Martinsburg, MD- Pass................. Fail................. Fail................ Exclude.
WV.
25220............................. Hammond, LA............... Fail................. Fail................. Pass................ Exclude.
25260............................. Hanford-Corcoran, CA...... Fail................. Fail................. Pass................ Exclude.
25420............................. Harrisburg-Carlisle, PA... Pass................. Pass................. Pass................ Include.
25500............................. Harrisonburg, VA.......... Pass................. Fail................. Fail................ Exclude.
25540............................. Hartford-West Hartford- Pass................. Pass................. Pass................ Include.
East Hartford, CT.
25620............................. Hattiesburg, MS........... Pass................. Pass................. Pass................ Include.
25860............................. Hickory-Lenoir-Morganton, Pass................. Pass................. Pass................ Include.
NC.
25940............................. Hilton Head Island- Pass................. Pass................. Pass................ Include.
Bluffton-Beaufort, SC.
26140............................. Homosassa Springs, FL..... Pass................. Pass................. Pass................ Include.
26300............................. Hot Springs, AR........... Pass................. Pass................. Pass................ Include.
26380............................. Houma-Thibodaux, LA....... Pass................. Pass................. Pass................ Include.
26420............................. Houston-The Woodlands- Pass................. Pass................. Pass................ Include.
Sugar Land, TX.
26580............................. Huntington-Ashland, WV-KY- Pass................. Pass................. Pass................ Include.
OH.
26620............................. Huntsville, AL............ Pass................. Pass................. Pass................ Include.
26820............................. Idaho Falls, ID........... Pass................. Pass................. Pass................ Include.
26900............................. Indianapolis-Carmel- Pass................. Pass................. Pass................ Include.
Anderson, IN.
26980............................. Iowa City, IA............. Pass................. Pass................. Pass................ Include.
27060............................. Ithaca, NY................ Fail................. Fail................. Pass................ Exclude.
27100............................. Jackson, MI............... Pass................. Pass................. Pass................ Include.
27140............................. Jackson, MS............... Pass................. Pass................. Pass................ Include.
27180............................. Jackson, TN............... Pass................. Fail................. Fail................ Exclude.
27260............................. Jacksonville, FL.......... Pass................. Pass................. Pass................ Include.
27340............................. Jacksonville, NC.......... Fail................. Fail................. Pass................ Exclude.
27500............................. Janesville-Beloit, WI..... Pass................. Pass................. Pass................ Include.
27620............................. Jefferson City, MO........ Pass................. Pass................. Pass................ Include.
27740............................. Johnson City, TN.......... Pass................. Fail................. Fail................ Exclude.
27780............................. Johnstown, PA............. Pass................. Pass................. Pass................ Include.
27860............................. Jonesboro, AR............. Pass................. Pass................. Pass................ Include.
27900............................. Joplin, MO................ Pass................. Pass................. Pass................ Include.
27980............................. Kahului-Wailuku-Lahaina, Fail................. Fail................. Pass................ Exclude.
HI.
28020............................. Kalamazoo-Portage, MI..... Pass................. Pass................. Pass................ Include.
28100............................. Kankakee, IL.............. Pass................. Pass................. Pass................ Include.
28140............................. Kansas City, MO-KS........ Pass................. Pass................. Pass................ Include.
28420............................. Kennewick-Richland, WA.... Pass................. Pass................. Pass................ Include.
28660............................. Killeen-Temple, TX........ Pass................. Pass................. Pass................ Include.
28700............................. Kingsport-Bristol-Bristol, Pass................. Pass................. Pass................ Include.
TN-VA.
28740............................. Kingston, NY.............. Fail................. Fail................. Pass................ Exclude.
28940............................. Knoxville, TN............. Pass................. Pass................. Pass................ Include.
29020............................. Kokomo, IN................ Fail................. Fail................. Pass................ Exclude.
29100............................. La Crosse-Onalaska, WI-MN. Pass................. Pass................. Pass................ Include.
29180............................. Lafayette, LA............. Pass................. Pass................. Pass................ Include.
29200............................. Lafayette-West Lafayette, Pass................. Pass................. Pass................ Include.
IN.
29340............................. Lake Charles, LA.......... Pass................. Pass................. Pass................ Include.
29420............................. Lake Havasu City-Kingman, Pass................. Pass................. Pass................ Include.
AZ.
29460............................. Lakeland-Winter Haven, FL. Pass................. Pass................. Pass................ Include.
29540............................. Lancaster, PA............. Pass................. Fail................. Fail................ Exclude.
29620............................. Lansing-East Lansing, MI.. Pass................. Pass................. Pass................ Include.
29700............................. Laredo, TX................ Pass................. Fail................. Pass................ Exclude.
29740............................. Las Cruces, NM............ Pass................. Pass................. Pass................ Include.
29820............................. Las Vegas-Henderson- Pass................. Pass................. Pass................ Include.
Paradise, NV.
29940............................. Lawrence, KS.............. Fail................. Fail................. Pass................ Exclude.
30020............................. Lawton, OK................ Pass................. Pass................. Pass................ Include.
30140............................. Lebanon, PA............... Pass................. Fail................. Pass................ Exclude.
30300............................. Lewiston, ID-WA........... Fail................. Fail................. Pass................ Exclude.
30340............................. Lewiston-Auburn, ME....... Pass................. Pass................. Pass................ Include.
30460............................. Lexington-Fayette, KY..... Pass................. Pass................. Pass................ Include.
30620............................. Lima, OH.................. Pass................. Pass................. Pass................ Include.
30700............................. Lincoln, NE............... Pass................. Pass................. Pass................ Include.
30780............................. Little Rock-North Little Pass................. Pass................. Pass................ Include.
Rock-Conway, AR.
30860............................. Logan, UT-ID.............. Fail................. Fail................. Pass................ Exclude.
30980............................. Longview, TX.............. Pass................. Pass................. Pass................ Include.
31020............................. Longview, WA.............. Fail................. Fail................. Pass................ Exclude.
31080............................. Los Angeles-Long Beach- Pass................. Pass................. Pass................ Include.
Anaheim, CA.
31140............................. Louisville/Jefferson Pass................. Pass................. Pass................ Include.
County, KY-IN.
31180............................. Lubbock, TX............... Pass................. Pass................. Pass................ Include.
31340............................. Lynchburg, VA............. Pass................. Pass................. Pass................ Include.
[[Page 232]]
31420............................. Macon, GA................. Pass................. Pass................. Pass................ Include.
31460............................. Madera, CA................ Fail................. Fail................. Pass................ Exclude.
31540............................. Madison, WI............... Pass................. Pass................. Pass................ Include.
31700............................. Manchester-Nashua, NH..... Pass................. Pass................. Pass................ Include.
31740............................. Manhattan, KS............. Fail................. Fail................. Pass................ Exclude.
31860............................. Mankato-North Mankato, MN. Fail................. Fail................. Pass................ Exclude.
31900............................. Mansfield, OH............. Pass................. Pass................. Pass................ Include.
32420............................. Mayag[uuml]ez, PR......... Fail................. Fail................. Pass................ Exclude.
32580............................. McAllen-Edinburg-Mission, Pass................. Pass................. Fail................ Exclude.
TX.
32780............................. Medford, OR............... Pass................. Pass................. Pass................ Include.
32820............................. Memphis, TN-MS-AR......... Pass................. Pass................. Pass................ Include.
32900............................. Merced, CA................ Fail................. Fail................. Pass................ Exclude.
33100............................. Miami-Fort Lauderdale-West Pass................. Pass................. Pass................ Include.
Palm Beach, FL.
33140............................. Michigan City-La Porte, IN Pass................. Pass................. Pass................ Include.
33220............................. Midland, MI............... Pass................. Pass................. Pass................ Include.
33260............................. Midland, TX............... Pass................. Fail................. Pass................ Exclude.
33340............................. Milwaukee-Waukesha-West Pass................. Pass................. Pass................ Include.
Allis, WI.
33460............................. Minneapolis-St. Paul- Pass................. Pass................. Pass................ Include.
Bloomington, MN-WI.
33540............................. Missoula, MT.............. Pass................. Pass................. Pass................ Include.
33660............................. Mobile, AL................ Pass................. Pass................. Pass................ Include.
33700............................. Modesto, CA............... Pass................. Pass................. Pass................ Include.
33740............................. Monroe, LA................ Pass................. Pass................. Pass................ Include.
33780............................. Monroe, MI................ Pass................. Pass................. Pass................ Include.
33860............................. Montgomery, AL............ Pass................. Pass................. Pass................ Include.
34060............................. Morgantown, WV............ Pass................. Pass................. Pass................ Include.
34100............................. Morristown, TN............ Fail................. Fail................. Pass................ Exclude.
34580............................. Mount Vernon-Anacortes, WA Pass................. Fail................. Pass................ Exclude.
34620............................. Muncie, IN................ Pass................. Pass................. Pass................ Include.
34740............................. Muskegon, MI.............. Pass................. Pass................. Pass................ Include.
34820............................. Myrtle Beach-Conway-North Pass................. Pass................. Pass................ Include.
Myrtle Beach, SC-NC.
34900............................. Napa, CA.................. Pass................. Fail................. Fail................ Exclude.
34940............................. Naples-Immokalee-Marco Pass................. Pass................. Pass................ Include.
Island, FL.
34980............................. Nashville-Davidson-- Pass................. Pass................. Pass................ Include.
Murfreesboro--Franklin,
TN.
35100............................. New Bern, NC.............. Pass................. Pass................. Pass................ Include.
35300............................. New Haven-Milford, CT..... Pass................. Pass................. Pass................ Include.
35380............................. New Orleans-Metairie, LA.. Pass................. Pass................. Pass................ Include.
35620............................. New York-Newark-Jersey Pass................. Pass................. Pass................ Include.
City, NY-NJ-PA.
35660............................. Niles-Benton Harbor, MI... Pass................. Pass................. Pass................ Include.
35840............................. North Port-Sarasota- Pass................. Pass................. Pass................ Include.
Bradenton, FL.
35980............................. Norwich-New London, CT.... Pass................. Pass................. Pass................ Include.
36100............................. Ocala, FL................. Pass................. Pass................. Fail................ Exclude.
36140............................. Ocean City, NJ............ Fail................. Fail................. Pass................ Exclude.
36220............................. Odessa, TX................ Pass................. Pass................. Pass................ Include.
36260............................. Ogden-Clearfield, UT...... Pass................. Pass................. Pass................ Include.
36420............................. Oklahoma City, OK......... Pass................. Pass................. Pass................ Include.
36500............................. Olympia-Tumwater, WA...... Pass................. Pass................. Pass................ Include.
36540............................. Omaha-Council Bluffs, NE- Pass................. Pass................. Pass................ Include.
IA.
36740............................. Orlando-Kissimmee-Sanford, Pass................. Pass................. Fail................ Exclude.
FL.
36780............................. Oshkosh-Neenah, WI........ Fail................. Fail................. Pass................ Exclude.
36980............................. Owensboro, KY............. Pass................. Pass................. Pass................ Include.
37100............................. Oxnard-Thousand Oaks- Pass................. Pass................. Fail................ Exclude.
Ventura, CA.
37340............................. Palm Bay-Melbourne- Pass................. Pass................. Pass................ Include.
Titusville, FL.
37460............................. Panama City, FL........... Pass................. Pass................. Pass................ Include.
37620............................. Parkersburg-Vienna, WV.... Pass................. Pass................. Pass................ Include.
37860............................. Pensacola-Ferry Pass- Pass................. Pass................. Pass................ Include.
Brent, FL.
37900............................. Peoria, IL................ Pass................. Pass................. Pass................ Include.
37980............................. Philadelphia-Camden- Pass................. Pass................. Pass................ Include.
Wilmington, PA-NJ-DE-MD.
38060............................. Phoenix-Mesa-Scottsdale, Pass................. Pass................. Pass................ Include.
AZ.
38220............................. Pine Bluff, AR............ Fail................. Fail................. Pass................ Exclude.
38300............................. Pittsburgh, PA............ Pass................. Pass................. Pass................ Include.
38340............................. Pittsfield, MA............ Pass................. Fail................. Pass................ Exclude.
38540............................. Pocatello, ID............. Fail................. Fail................. Pass................ Exclude.
38660............................. Ponce, PR................. Fail................. Fail................. Pass................ Exclude.
38860............................. Portland-South Portland, Pass................. Pass................. Pass................ Include.
ME.
38900............................. Portland-Vancouver- Pass................. Pass................. Pass................ Include.
Hillsboro, OR-WA.
38940............................. Port St. Lucie, FL........ Pass................. Pass................. Pass................ Include.
39140............................. Prescott, AZ.............. Pass................. Pass................. Pass................ Include.
39300............................. Providence-Warwick, RI-MA. Pass................. Pass................. Pass................ Include.
[[Page 233]]
39340............................. Provo-Orem, UT............ Pass................. Pass................. Pass................ Include.
39380............................. Pueblo, CO................ Pass................. Pass................. Pass................ Include.
39460............................. Punta Gorda, FL........... Pass................. Pass................. Pass................ Include.
39540............................. Racine, WI................ Fail................. Fail................. Pass................ Exclude.
39580............................. Raleigh, NC............... Pass................. Pass................. Pass................ Include.
39660............................. Rapid City, SD............ Pass................. Pass................. Pass................ Include.
39740............................. Reading, PA............... Pass................. Pass................. Pass................ Include.
39820............................. Redding, CA............... Pass................. Pass................. Pass................ Include.
39900............................. Reno, NV.................. Pass................. Pass................. Pass................ Include.
40060............................. Richmond, VA.............. Pass................. Pass................. Pass................ Include.
40140............................. Riverside-San Bernardino- Pass................. Pass................. Pass................ Include.
Ontario, CA.
40220............................. Roanoke, VA............... Pass................. Pass................. Pass................ Include.
40340............................. Rochester, MN............. Pass................. Pass................. Pass................ Include.
40380............................. Rochester, NY............. Pass................. Pass................. Pass................ Include.
40420............................. Rockford, IL.............. Pass................. Pass................. Pass................ Include.
40580............................. Rocky Mount, NC........... Pass................. Pass................. Pass................ Include.
40660............................. Rome, GA.................. Pass................. Pass................. Pass................ Include.
40900............................. Sacramento--Roseville--Ard Pass................. Pass................. Pass................ Include.
en-Arcade, CA.
40980............................. Saginaw, MI............... Pass................. Pass................. Pass................ Include.
41060............................. St. Cloud, MN............. Pass................. Pass................. Pass................ Include.
41100............................. St. George, UT............ Pass................. Pass................. Pass................ Include.
41140............................. St. Joseph, MO-KS......... Pass................. Pass................. Pass................ Include.
41180............................. St. Louis, MO-IL.......... Pass................. Pass................. Pass................ Include.
41420............................. Salem, OR................. Pass................. Pass................. Pass................ Include.
41500............................. Salinas, CA............... Pass................. Pass................. Pass................ Include.
41540............................. Salisbury, MD-DE.......... Pass................. Pass................. Pass................ Include.
41620............................. Salt Lake City, UT........ Pass................. Pass................. Pass................ Include.
41660............................. San Angelo, TX............ Pass................. Pass................. Pass................ Include.
41700............................. San Antonio-New Braunfels, Pass................. Pass................. Fail................ Exclude.
TX.
41740............................. San Diego-Carlsbad, CA.... Pass................. Pass................. Pass................ Include.
41860............................. San Francisco-Oakland- Pass................. Pass................. Pass................ Include.
Hayward, CA.
41900............................. San Germ[aacute]n, PR..... Fail................. Fail................. Pass................ Exclude.
41940............................. San Jose-Sunnyvale-Santa Pass................. Pass................. Pass................ Include.
Clara, CA.
41980............................. San Juan-Carolina-Caguas, Fail................. Fail................. Pass................ Exclude.
PR.
42020............................. San Luis Obispo-Paso Pass................. Pass................. Pass................ Include.
Robles-Arroyo Grande, CA.
42100............................. Santa Cruz-Watsonville, CA Pass................. Fail................. Fail................ Exclude.
42140............................. Santa Fe, NM.............. Pass................. Pass................. Pass................ Include.
42200............................. Santa Maria-Santa Barbara, Pass................. Pass................. Pass................ Include.
CA.
42220............................. Santa Rosa, CA............ Pass................. Pass................. Pass................ Include.
42340............................. Savannah, GA.............. Pass................. Pass................. Pass................ Include.
42540............................. Scranton--Wilkes-Barre-- Pass................. Pass................. Pass................ Include.
Hazleton, PA.
42660............................. Seattle-Tacoma-Bellevue, Pass................. Pass................. Pass................ Include.
WA.
42680............................. Sebastian-Vero Beach, FL.. Pass................. Pass................. Pass................ Include.
42700............................. Sebring, FL............... Pass................. Pass................. Pass................ Include.
43100............................. Sheboygan, WI............. Fail................. Fail................. Pass................ Exclude.
43300............................. Sherman-Denison, TX....... Pass................. Pass................. Pass................ Include.
43340............................. Shreveport-Bossier City, Pass................. Pass................. Pass................ Include.
LA.
43420............................. Sierra Vista-Douglas, AZ.. Pass................. Fail................. Fail................ Exclude.
43580............................. Sioux City, IA-NE-SD...... Pass................. Pass................. Pass................ Include.
43620............................. Sioux Falls, SD........... Pass................. Pass................. Pass................ Include.
43780............................. South Bend-Mishawaka, IN- Pass................. Fail................. Fail................ Exclude.
MI.
43900............................. Spartanburg, SC........... Pass................. Pass................. Pass................ Include.
44060............................. Spokane-Spokane Valley, WA Pass................. Pass................. Pass................ Include.
44100............................. Springfield, IL........... Pass................. Pass................. Pass................ Include.
44140............................. Springfield, MA........... Pass................. Pass................. Fail................ Exclude.
44180............................. Springfield, MO........... Pass................. Pass................. Pass................ Include.
44220............................. Springfield, OH........... Fail................. Fail................. Pass................ Exclude.
44300............................. State College, PA......... Fail................. Fail................. Pass................ Exclude.
44420............................. Staunton-Waynesboro, VA... Pass................. Pass................. Pass................ Include.
44700............................. Stockton-Lodi, CA......... Pass................. Pass................. Pass................ Include.
44940............................. Sumter, SC................ Fail................. Fail................. Fail................ Exclude.
45060............................. Syracuse, NY.............. Pass................. Pass................. Pass................ Include.
45220............................. Tallahassee, FL........... Pass................. Pass................. Pass................ Include.
45300............................. Tampa-St. Petersburg- Pass................. Pass................. Pass................ Include.
Clearwater, FL.
45460............................. Terre Haute, IN........... Pass................. Pass................. Pass................ Include.
45500............................. Texarkana, TX-AR.......... Pass................. Pass................. Fail................ Exclude.
45540............................. The Villages, FL.......... Pass................. Pass................. Pass................ Include.
45780............................. Toledo, OH................ Pass................. Pass................. Pass................ Include.
[[Page 234]]
45820............................. Topeka, KS................ Pass................. Pass................. Pass................ Include.
45940............................. Trenton, NJ............... Pass................. Pass................. Pass................ Include.
46060............................. Tucson, AZ................ Pass................. Pass................. Pass................ Include.
46140............................. Tulsa, OK................. Pass................. Pass................. Pass................ Include.
46220............................. Tuscaloosa, AL............ Pass................. Pass................. Pass................ Include.
46340............................. Tyler, TX................. Pass................. Pass................. Pass................ Include.
46520............................. Urban Honolulu, HI........ Pass................. Pass................. Pass................ Include.
46540............................. Utica-Rome, NY............ Pass................. Pass................. Pass................ Include.
46660............................. Valdosta, GA.............. Pass................. Fail................. Pass................ Exclude.
46700............................. Vallejo-Fairfield, CA..... Pass................. Fail................. Fail................ Exclude.
47020............................. Victoria, TX.............. Pass................. Pass................. Pass................ Include.
47220............................. Vineland-Bridgeton, NJ.... Pass................. Fail................. Pass................ Exclude.
47260............................. Virginia Beach-Norfolk- Pass................. Pass................. Fail................ Exclude.
Newport News, VA-NC.
47300............................. Visalia-Porterville, CA... Pass................. Pass................. Pass................ Include.
47380............................. Waco, TX.................. Pass................. Pass................. Pass................ Include.
47460............................. Walla Walla, WA........... Fail................. Fail................. Pass................ Exclude.
47580............................. Warner Robins, GA......... Pass................. Pass................. Pass................ Include.
47900............................. Washington-Arlington- Pass................. Pass................. Pass................ Include.
Alexandria, DC-VA-MD-WV.
47940............................. Waterloo-Cedar Falls, IA.. Pass................. Pass................. Pass................ Include.
48060............................. Watertown-Fort Drum, NY... Fail................. Fail................. Pass................ Exclude.
48140............................. Wausau, WI................ Pass................. Pass................. Pass................ Include.
48260............................. Weirton-Steubenville, WV- Pass................. Pass................. Pass................ Include.
OH.
48300............................. Wenatchee, WA............. Pass................. Pass................. Pass................ Include.
48540............................. Wheeling, WV-OH........... Pass................. Pass................. Pass................ Include.
48620............................. Wichita, KS............... Pass................. Pass................. Pass................ Include.
48660............................. Wichita Falls, TX......... Pass................. Fail................. Fail................ Exclude.
48700............................. Williamsport, PA.......... Pass................. Pass................. Pass................ Include.
48900............................. Wilmington, NC............ Pass................. Pass................. Pass................ Include.
49020............................. Winchester, VA-WV......... Pass................. Pass................. Pass................ Include.
49180............................. Winston-Salem, NC......... Pass................. Pass................. Pass................ Include.
49340............................. Worcester, MA-CT.......... Pass................. Pass................. Pass................ Include.
49420............................. Yakima, WA................ Pass................. Pass................. Pass................ Include.
49620............................. York-Hanover, PA.......... Pass................. Pass................. Pass................ Include.
49660............................. Youngstown-Warren- Pass................. Pass................. Pass................ Include.
Boardman, OH-PA.
49700............................. Yuba City, CA............. Pass................. Pass................. Pass................ Include.
49740............................. Yuma, AZ.................. Pass................. Pass................. Pass................ Include.
--------------------------------------------------------------------------------------------------------------------------------------------------------
The following is a summary of the comments received and our
responses.
Comment: The issue of MSA exclusions was a subject raised by a
variety of commenters. Commenters expressed concerns with the
possibility of the same MSAs being selected for inclusion in both the
cardiac EPMs and in the CJR model. Commenters stated that the
introduction of 3 new required models simultaneously in MSAs where CJR
is still in the early stages of implementation would divert
participants' focus from being able to successfully implement CJR and
would pose resource allocation challenges. Commenters stated that
hospitals have a limited capacity to successfully take on new models
and that hospitals could best achieve success when they are allowed to
focus on specific projects. Commenters stated that adding too many
required models will result in diluted resources given to each model
and increased administrative costs to the hospital. One commenter
expressed concern that implementing too many models can compromise both
the success of the models and patient care. Commenters requested that
CMS add an exclusion rule that removes the CJR MSAs from the
possibility of selection as a cardiac EPM area.
Response: We acknowledges the concern of CJR participant hospitals
with respect to having the capacity and ability to take on the new
cardiac and SHFFT episodes in addition to their current model
participation. While recognizing the logistical and resource challenges
of implementing multiple models simultaneously, CMS believes that there
are commonalities between the models that would result in some
efficiencies. For example, experiences in CJR with creating gainsharing
approaches, analyzing claims feeds, and understanding reconciliation
methodologies will be directly transferable to managing the cardiac
episodes.
CMS considered the exclusion of CJR MSAs from the possibility of
selection as a cardiac EPM. The effect of removing the CJR MSAs was
considered relative to a variety of other considerations including the
impact of this removal on the remaining MSAs and whether it would
create a biased pool due to the disproportionate removal of areas with
high episode payments as well as areas with a larger population.
In determining which areas were eligible for selection for CJR,
MSAs were required to have at least 400 LEJRs in the reference year. In
contrast, the equivalent exclusion rule for the cardiac EPMs requires
at least 75 AMI episodes. These two different rules means that the pool
of MSAs eligible for selection as a cardiac EPM contains many smaller
MSAs who were not eligible for selection in CJR. Removing the CJR MSA
would disproportionately remove larger cities from the selection pool
and the pool would be artificially weighted towards MSAs with lower
numbers of
[[Page 235]]
cases. The resulting random selection in this pool would similarly be
over-weighted to select smaller areas with lower numbers of episodes.
MSAs were selected for inclusion in CJR by dividing MSAs into
quartiles based on the MSA average LEJR episode spending. The
likelihood of being selected as a CJR area differed between the
quartiles such that MSAs in the least expensive quartile had a 30%
chance of selection and MSAs in the most expensive quartile had a 45%
chance of selection. Thus, the removal of the CJR MSAs from the cardiac
EPM selection pool would disproportionately leave relatively more
efficient MSAs eligible for selection and remove relatively inefficient
areas. In order to quantify the extent of this potential bias, the
impact of removing the CJR areas was examined relative to the average
MSA spending for AMI episodes. CJR MSAs represented just 12% of MSAs in
the least expensive quartile (9 of 74) but represented 26% of the MSAs
in the most expensive quartile (19 of 74).
In summary, because the CJR MSAs were proportionately underweighted
for more efficient MSAs, and over weighted for more expensive MSAs with
higher LEJR episode payments, their removal resulted in introducing
bias which would result in the selection of more small cities as well
as more efficient cities. This bias to disproportionally select
relatively more efficient MSAs is counter to the overall orientation
that these models are most likely to result in cost savings in
inefficient areas. Furthermore, CMS anticipates that an increase in the
probability of selection in smaller cities may also be problematic to
commenters, many of whom expressed concern with the ability of
hospitals with few cases to succeed under the model.
CMS further notes that a variety of models and efforts are
currently underway with the goal of controlling health care costs.
While this presents an operationally challenging situation, CMS hopes
to be able to assess the extent to which these different models
interact and complement (or compete with) one another. The evaluation
of CJR and the EPMs will include a systematic look at hospital
experiences in regard to model uptake given their range of prior
experience, capabilities, and circumstances.
Comment: One commenter recommended the exclusion of MSAs with less
than 20 CABG episodes per quarter rather than basing the exclusionary
criteria only on AMI volume episode volume.
Response: We continue to have a strong interest in being able to
observe how well EPMs operate in areas with a lower volume of episodes,
and, in particular, the consequences of the model for AMI episodes
where CABG is not commonly performed or where standard practice is to
refer all CABGs outside of the MSA, and consequently, does not find it
appropriate to exclude MSAs on the basis of CABG volume.
Comment: One commenter suggested that MSAs with significant
penetration of Medicare Advantage Plans and considerable ACO activity
be excluded from the possibility of selection. They stated that the
models should be implemented in markets with more limited alternative
payment and/or managed care activity. They suggested that the selection
of MSAs believed to be fully invested in care design efforts would make
it challenging to evaluate whether improvements in efficiency were
related to the EPMs or associated with these other efforts. The
commenter stated that restricting to MSAs with minimal involvement with
other APM would ease both administrative burden and allow for better
results and more accurate reconciliation.
Response: While including MSAs with experience in APMs may pose
challenges to the evaluation in its effort to assess causation, CMS
believes that the exclusion of MSAs who may be relatively more
experienced in care redesign and thus more likely to be able to achieve
success in the models would be undesirable. It would be considered a
positive if participant hospitals are able to leverage the knowledge
and experience of experts in their areas in order to successfully
reduce episode spending in eligible patients. Experience with care
management under managed care or within APMs might be one source of
expertise from which participant hospitals may wish to draw. The
evaluation of EPMs will include an examination of market
characteristics and model activity, so as to explore how the
overlapping nature of these two factors impacts performance.
Comment: One commenter expressed the concern that some hospitals
act as regional referral centers or may otherwise have a large
proportion of the beneficiaries they treat who reside outside of the
MSA where the hospital is located. They expressed concern that it would
be difficult to manage care for these beneficiaries in the post
hospital episode period due to this distance. They requested that MSAs
with a significant percent of cases coming from out of the state be
excluded from the possibility of selection.
Response: We recognize that many hospitals treat patients from a
wide catchment area and that this catchment area may possibly extend
beyond the MSA. This situation is particularly relevant to the CABG
EPM. The management of the beneficiary's recovery in the post hospital
period may be a challenge for some providers. Multiple patient
characteristics, including the physical distance between the
beneficiary and the hospital, will influence both what type of care
redesign approach will be most appropriate and the likelihood that the
approach taken will result in improved efficiency and quality. While
distance may pose a challenge to improving patient coordination, it is
one that many providers have successfully undertaken. Many providers,
including regional referral centers, have been able to form and
maintain relationships with providers outside their communities.
CMS holds that regional referral centers are a critical component
of how CAGB episodes are treated and, as such, are an important part of
the cardiac EPM and to gaining an understanding of the ability of such
participants to manage patient episodes.
Comment: Commenters expressed concern that low-volume hospitals are
included in the models and requested that thresholds be added to remove
low-volume providers from the model. Commenters stated that lower
volume providers are subject to issues of random variation and that the
cost and quality experiences observed in these hospitals may not be due
to efficiencies and care coordination. They stated that smaller
hospitals will be at a disadvantage due to the inability to achieve
stability or predictability due to this variation.
Finally, a commenter noted that they believed that minimum number
of applicable cases is necessary for a hospitals to perform internal
analyses to determine the appropriate strategies to use to successfully
re-engineer care. They stated that having a minimum number of cases is
a key factor in whether or not a facility can be ready for undertaking
bundled payments. Minimal numbers are necessary for generating adequate
levels of involvement in potential partners such as physicians and
post-acute care providers. The commenter proposed that the definitions
of minimal volume used in the payment methodology be used instead as
minimal requirements for hospitals to be required to participate in the
cardiac EPMs.
Response: We acknowledge the fact that hospitals, particularly low-
volume hospitals, may have limited resources to fully engage in care
re-design efforts and, due to the low volume, they are
[[Page 236]]
much more susceptible to wider episode cost fluctuations. We refer
readers to the following sections of this final rule III.D.4.b.(9). of
this final rule for a discussion of how target prices for hospitals
with low volume are determined and to III.D.7.c.(1). of this final rule
for a discussion of low volume hospital protections under the cardiac
EPMs.
The inclusion of low-volume hospitals in the EPMs is consistent
with the goal of evaluating the impact of bundled payment and care
redesign across a broad spectrum of hospitals with varying levels of
infrastructure, care redesign experience, market position, and other
considerations, and circumstances. We are interested in evaluating the
experience of these hospitals in the models as part of our overall
desire to see the impact of an episode payment model in providers who
would not otherwise choose to participate in a model. We would be
concerned that setting a threshold for low volume could result in
hospital gaming in order to be below that threshold and thus be
excluded from the models.
Similar to the CJR model, the design of the EPMs and the inclusion
of low-volume providers within the models reflects our interest in
testing and evaluating the impact of a bundled payment approach for
these procedures in a variety of circumstances, especially among those
hospitals that may not otherwise participate in such a test. The
inclusion of these providers allows CMS to better appreciate and
understand how the models operate as a general payment approach and its
impact across a wide range of hospitals. The impact of EPMs on low-
volume hospitals is of great interest to the evaluation of these
models.
We acknowledge that providers with low volumes of AMI, CABG, or CJR
cases may not find it advantageous to engage in an active way with the
EPMs. We expect that low volume providers may decide that their
resources are better targeted to other efforts because they do not find
the financial incentive present in the EPMs sufficiently strong to
cause them to shift their practice patterns. We believe this choice is
similar in nature to that made as hospitals decide their overall
business strategies and where to focus their attentions.
Final Decision: After consideration of the public comments
received, we are finalizing the proposal, without modification, to
exclude MSAs that fail one or more of the following rules:
Exclusion Rule 1: Exclude MSAs with fewer than 75 AMI episodes
(determined as discussed in section III.C. of this final rule).
Exclusion Rule 2: Exclude MSAs with fewer than 75 non-BPCI AMI
episodes in the MSA in the reference year.
Exclusion Rule 3: Exclude MSAs if the number of non-BPCI AMI
episodes calculated under Exclusion Rule 2 is less than 50 percent of
the total number of AMI episodes calculated under Exclusion Rule 1.
As discussed in section III.B.2. of this final rule, the Burlington
Vermont MSA was found to no longer be eligible for possible selection
because of the Vermont All-Payer ACO Model. Thus, 293 MSAs out of 384
total MSAs are eligible for the possibility of selection as a cardiac
EPM area.
b. Selection Approach
We proposed the selection of 98 MSAs for the cardiac EPMs through
the use of simple random selection from the 294 (now 293) eligible
MSAs.
Simple random selection is often considered to be an appropriate
default approach to experimental design unless there is a compelling
reason to depart from it. One common alternative approach is to perform
random selection separately within subgroups. Selection within
subgroups can be a useful approach to limiting differences between
intervention and control groups to improve statistical power or for
facilitating over or under sampling to allow the evaluation to examine
effects of the intervention on particular types of MSAs or because
those types of MSAs are of particular interest for policy reasons.
In CJR, we used a stratified random assignment approach in which we
organized MSAs into strata based on MSA population size and historic
LEJR episode payments. Under the CJR model, we believed a stratified
approach was appropriate due to wide regional variation in prices,
primarily associated with the use of post-acute services. The
stratified approach served as a means to oversample in higher-expense
MSAs as these areas have both the most need for and the most
opportunity under the CJR model.
In assessing whether stratification would be proposed for the EPMs,
we assessed a variety of factors described later in this section.
Absent stratification, the rate at which a particular type of MSA will
appear in the sample will be proportional to how often in appears among
eligible MSAs. If a particular type of MSA is relatively common, it is
likely to occur often enough that we do not need to deliberately over-
sample for it. In the end, our analyses did not provide sufficient
evidence that it is necessary to create selection subgroups of MSAs to
guide the selection approach. As a result, we are proposing to use
simple random selection from the entire pool of eligible MSAs.
(1) Factors Considered but Not Used
We considered a variety of possible MSA characteristics for
possible use in classifying sub-groups. Though we did consider many of
these variables important, we believe that a simple random selection,
where warranted, is preferable.
Some of the factors we considered that we are not proposing to use
in the selection methodology include the following:
Measures associated with AMI-episode and CABG episode
wage-adjusted spending, respectively. In considering how to
operationalize such measures, we considered a number of alternatives
including average total episode spending payments in an MSA, average
episode spending associated with the initial hospital stay(s) and
average episode spending occurring in the period after discharge from
the initial hospital.
Measures associated with variation in practice patterns
associated with AMI and CABG episodes. In considering how to
operationalize this measure, we considered a number of alternatives
including the extent to which both an AMI and a CABG episode are
associated with having a transfer hospital stay at the beginning of the
episode, and the extent to which CABG hospitalizations occur following
a hospital transfer from either within or from outside the same MSA.
Measures associated with relative market share of
providers with respect to AMI and/or CABG episodes, including the
presence or absence of regional referral centers and the number of
providers with the capacity to perform CABGs or otherwise treat complex
cardiac patients.
Health care supply measures of providers in the MSA
including acute or post-acute bed counts, and number of relevant
physician specialties such as cardiologists and cardiothoracic
surgeons.
MSA-level demographic measures such as: (1) Average
income; (2) distributions of population by age, gender or race; (3)
percent dually eligible; and (4) percent with specific health
conditions or other demographic composition measures.
Measures associated with the degree to which a market
might be more capable or ready to implement care-redesign activities.
Examples of market-
[[Page 237]]
level characteristics that might be associated with anticipated ease of
implementation include the MSA-level EHR meaningful-use levels,
managed-care penetration, ACO penetration, and experience with other
bundling efforts.
Though these measures were not proposed to be part of the selection
process, we acknowledge that these and other market-level factors may
be important to the proper understanding of the evaluation of the
impact of EPMs. We intend to consider these and other measures in
determining which MSAs are appropriate comparison markets for the
evaluation and for possible subgroup analysis or risk-adjustment
purposes. The evaluations will include beneficiary-, provider-, and
market-level characteristics in how they will examine the performance
of the proposed EPMs.
The following is a summary of the comments received and our
responses.
Comment: A few commenters expressed general support for the
selection approach. Several commenters identified considerations that
they believed would increase the likelihood of success in these models
and believed that those factors should influence the likelihood of
selection.
One commenter believed that the selection methodology used should
instead select MSAs where there is unwanted clinical or fiscal
variation in care. They stated that the implementation of the cardiac
EPMs in these MSAs would be most likely to target patients who would
benefit from novel care delivery initiatives. In contrast, another
commenter noted that the implementation of the cardiac EPMs in a
variety of markets, including those who are relatively more efficient,
could help with improving care management/coordination overall.
One commenter mentioned that CMS did not incorporate any MSA-level
demographic measures in its selection process, such as distributions of
population by age, gender, or race; percent of population dually
eligible for Medicare and Medicaid; percent of population with specific
health conditions; and other demographic composition measures. They
believed these factors vary not only between MSAs, but also by
hospitals within an MSA, and could affect a hospital's chances of
success in the proposed EPMs.
Response: We appreciate the suggestions of alternative MSA
selection criteria and note that we considered whether to
disproportionately select higher cost areas. As discussed above, the
range of average episode costs between MSAs was relatively narrow and
even relatively efficient MSAs would have opportunity for care redesign
and increased efficiency under these models. The examination of the
distribution of expenses did not seem to indicate that there are
substantial pattern of care differences between MSAs that needed to be
recognized in the selection methodology.
We acknowledge that demographic factors may indeed influence the
ability of hospitals to succeed under the models. However, in creating
the EPMs, we are seeking to understand how the models impact costs and
quality under a variety of circumstances. We seek to understand if the
models work in both more and less challenging circumstances in order to
be able to gain an understanding of successes and failures of the
episodic payment approach in all types of initiating participants. We
did not choose to incorporate MSA level demographics in our selection
methodology but instead we are relying on random selection to include
MSAs with a variety of circumstances. We did not believe it was
necessary to preemptively over-sample areas with a larger percent of
vulnerable patients.
Final Decision: After consideration of the public comments
received, we are finalizing the proposal, without modification, to
select MSAs for inclusion in the cardiac EPMs by simple random
selection.
(2) Sample-Size Calculations and the Number of Selected MSAs
Our analyses of the necessary sample size led us to propose the
selection of 98 MSAs, to participate in both the AMI and CABG EPMs. At
the time of the proposed rule 294 MSAs were eligible for selection out
of a total of 384 MSAs. In this section, we discuss the assumptions and
modeling that went into our proposal to test these EPMs in 98 MSAs. The
discussion of the method of selection of these 98 MSAs is addressed in
the following section. In coming to the decision to target 98 MSAs, we
are proposing an approach that limits the size of the intervention to
the greatest degree possible, while still ensuring that we have
sufficient statistical power to reliably evaluate the effects of the
EPMs. Going below this threshold would jeopardize our ability to be
confident in our results and to be able to generalize from the EPMs to
the larger national context.
In calculating the necessary size of the AMI and CABG EPMs, a key
consideration was to have sufficient power to be able to detect the
desired size impact. The larger the anticipated size of the impact, the
fewer MSAs we would have to sample in order to observe it. However, a
model sized to be able to only detect large impacts runs the risk of
not being able to draw conclusions if the size of the change is less
than anticipated. The measure of interest used in estimating sample
size requirements for the both the AMI and the CABG EPMs was wage-
adjusted total episode spending. The data used for the wage-adjusted
total episode spending is the 3-year data pull previously described
that covers AMI and CABG episodes with admission dates from July 1,
2012, through December 31, 2014. For the purposes of the sample-size
calculation, we aim to be able to reliably identify between a 2-percent
and 3-percent reduction in wage-adjusted episode spending after 1 year
of experience. We chose this range because those numbers represent the
anticipated amount of the discount proposed to apply under various
conditions of the AMI and CABG EPMs' implementation.
The next consideration in calculating the necessary sample size is
the degree of certainty we will need for the statistical tests that
will be performed. In selecting the right sample size, there are two
types of errors that need to be considered: ``false positives'' and
``false negatives.'' A false positive occurs if a statistical test
concludes that a model was successful (that is, saved money) when it in
fact was not. A false negative occurs if a statistical test fails to
find statistically-significant evidence that the model was successful,
when it in fact was successful. In considering the minimum sample size
needs of the AMI and CABG EPMs, a standard guideline in the statistical
literature suggests calibrating statistical tests to generate no more
than a 5-percent chance of a false positive and selecting the sample
size to ensure no more than a 20-percent chance of a false negative. In
contrast, the proposed sample size for this project was based on a 10-
percent chance of a false positive and no more than a 30-percent chance
of a false negative in order to minimize reduce sample size
requirements to the greatest degree possible.
A third consideration in the sample-size calculation was the
appropriate unit of selection and whether it is necessary to base the
calculation on the number of MSAs, the number of hospitals, or the
number of episodes. We proposed to base the sample size calculation at
the MSA level. The proposed EPMs are an example of what is known as a
``nested comparative study.'' Under a nested comparative study,
assignment to an intervention or comparison arms of the study is based
on membership in a pre-existing, identifiable group where the groups
are
[[Page 238]]
not formed at random, but rather through some physical, social,
geographic, or other connection among their members. Because these
groups are not formed at random, individual members of each group are
likely to share important commonalities. In the context of the proposed
EPMs, spending and outcomes for patients cared for within a given MSA
are relatively similar to one another due to such factors as the
existence of common practice or referral patterns, the underlying
health in the population, and the availability of providers in an area.
In statistical terms, these commonalities create a positive
correlation (called an intra-class correlation) among hospitals or
beneficiaries in the same MSA. Due to that intra-class correlation, the
variability of any aggregate statistic--such as the estimated
difference in outcomes between the intervention and comparison arms of
the study--has two components--(1) variability attributable to
variation among hospitals or beneficiaries in a given MSA; and (2)
variability attributable to differences between MSAs. An accurate power
analysis must account for both components of variability.
In determining the necessary sample size, we take into
consideration the degree to which commonalities within MSAs exist and
the number of independent beneficiaries and hospitals expected to be
included in the EPMs within each MSA. As part of this process, we
empirically examined the number of beneficiaries, the number of
hospitals, and the number of MSAs, as well as the level of correlation
in episode payments between each level. Based on this empirical
examination, we determined that the correlation was high enough that
the degree of variability would be primarily driven by the number of
MSAs in the model, indicating that the MSA is the appropriate unit of
analysis for the power calculations.
Using the previously mentioned assumptions, a power calculation for
AMI was run which indicated that at 98 MSAs we would be able to
reliably detect a 3-percent reduction in wage-adjusted episode spending
after 1 year with a false-positive rate of 10 percent and a false-
negative rate of between 20 percent and 40 percent. We are targeting a
false-negative rate of 30 percent. The extent to which this rate can be
lowered will depend on the ability of evaluation models to
substantially reduce variation through risk adjustment and modeling. We
believe it is prudent to choose a sample size where the targeted amount
is in the middle of this expected band.
We separately assessed the sample-size needs associated with CABG
episodes. At 98 MSAs, we anticipate being able to detect a 2.25-percent
reduction in wage-adjusted episode expenditures after 1 year with a
false-positive rate of 10 percent and a false-negative rate of between
20-40 percent. The effective number of MSAs where the CABG EPM will be
tested will be reduced because approximately 6 percent of eligible MSAs
had no CABG episodes in the reference year. However, our power
calculations do not lead us to believe we need to increase the sample
size based on this fact. The number of CABG MSAs can experience this
reduction and maintain equivalent levels of power to the AMI episodes.
The following is a summary of the comments received and our
responses.
Comment: One commenter expressed the opinion that the models should
be tested in 5 to 10 MSAs rather than be done as a large scale test.
Response: As stated in the proposed rule, we believe that the
evidence base related to episode payments is sufficient enough to
justify a large scale test and we believe that it is appropriate to
size the models so as to be able to generate statistically reliable
estimates of the impact as well as to be able to understand how well
the models operate in a variety of circumstances.
Final Decision: After consideration of the public comments
received, we are finalizing the proposal, without modification, to
select 98 MSAs to participate in the cardiac EPMs.
(3) Method of Selecting MSAs
As previously discussed, we are sought to choose 98 MSAs from our
pool of eligible MSAs through simple random selection. We proposed to
make the selection in the proposed rule using SAS Enterprise Guide 7.1
software to run a computer algorithm SAS Enterprise Guide 7.1 and the
computer algorithm used to conduct selection represents an industry-
standard for generating advanced analytics and provides a rigorous,
standardized tool by which to satisfy the requirements of randomized
selection. The key SAS commands employed include a ``PROC
SURVEYSELECT'' statement coupled with the ``METHOD=SRS'' option used to
specify simple random sampling as the sample selection method. A random
number seed will be generated using the birthdate of the person
executing the program.\39\
---------------------------------------------------------------------------
\39\ For more information on this procedure and the underlying
statistical methodology, please reference SAS support documentation
at: https://support.sas.com/documentation/cdl/en/statug/63033/HTML/default/viewer.htm#statug_surveyselect_sect003.htm/.
---------------------------------------------------------------------------
We sought comment on our proposal to implement the AMI and CABG
models in the selected MSAs, some of which may overlap with MSAs where
the CJR and SHFFT models also are being implemented.
The following is a summary of the comments received and our
responses.
Comment: Comments were received from multiple sources that
expressed that the list of selected MSAs be published as soon as
possible to allow for better preparation for the start of the models.
One commenter requested that the list of hospitals in the selected
areas also be published and that hospitals be given 60 days to comment
on its accuracy. Commenters expressed a preference that, in future rule
making of a similar nature, the list of selected MSAs be displayed in
the proposed rule rather than the final rule to allow for comment by
the impacted MSAs and additional preparation time.
Response: We appreciate the suggestion that MSAs and affected
providers be published at the time of rulemaking, and will take it
under advisement in any future rule. One of the reasons for not
selecting MSAs at the time of the proposed rule was to encourage all
potentially impacted providers to comment. In addition, we wished to be
able to maintain flexibility that would allow for the creation of new
exclusion rules to be suggested in the comment period without
necessitating the need to re-select MSAs between the proposed and final
rules. In order to accommodate the later announcement of impacted MSAs,
we proposed a July 1, 2017 model start. This represents a similar
amount of time between the CJR MSA announcement and the start of that
model as for the announcement of the cardiac EPM MSAs and the
finalization of the SHFFT MSAs and the start of those models.
The list of MSAs selected for the cardiac EPM is included in TABLE
2. The list of hospitals identified as in the MSAs selected for the
cardiac EPMs can be found at https://innovation.cms.gov/initiatives/epm/. Hospitals believing that they have erroneously been identified as
being in a selected area should send an email to epm@cms.hhs.gov within
45 days of the publication of the final rule. Hospitals should include
identifying information including the hospital CCN. CMS will
periodically review and revise the list of hospitals that meet the
requirements for participation in the cardiac EPMs and
[[Page 239]]
will update this information on https://innovation.cms.gov/initiatives/epm/.
Final Decision: After consideration of the public comments
received, we are finalizing the proposal, without modification. We
selected the participating MSAs for the CABG and AMI EPMs through
simple random selection. SAS for Windows Version 9.4 software was used
to run a computer algorithm designed to randomly select MSAs. SAS for
Windows Version 9.4 and the computer algorithm used to conduct
selection represents an industry standard for generating advanced
analytics and provides a rigorous, standardized tool by which to
satisfy the requirements of randomized selection. The key SAS commands
employed include a ``PROC SURVEYSELECT'' statement coupled with the
``METHOD=SRS'' option used to specify simple random sampling as the
sample selection method. The random number seed utilized was 19730609.
The MSAs selected for inclusion are shown in TABLE 2.
Table 2--MSAS Selected To Participate in the Cardiac EPMS
----------------------------------------------------------------------------------------------------------------
CBSA_OMB MSA name CJR selected MSA?
----------------------------------------------------------------------------------------------------------------
10180.......................... Abilene, TX........................................
10420.......................... Akron, OH.......................................... yes.
10780.......................... Alexandria, LA.....................................
10900.......................... Allentown-Bethlehem-Easton, PA-NJ..................
11260.......................... Anchorage, AK......................................
12100.......................... Atlantic City-Hammonton, NJ........................
12220.......................... Auburn-Opelika, AL.................................
12420.......................... Austin-Round Rock, TX.............................. yes.
13380.......................... Bellingham, WA.....................................
13460.......................... Bend-Redmond, OR...................................
14020.......................... Bloomington, IN....................................
14260.......................... Boise City, ID.....................................
14460.......................... Boston-Cambridge-Newton, MA-NH.....................
15940.......................... Canton-Massillon, OH...............................
15980.......................... Cape Coral-Fort Myers, FL..........................
16020.......................... Cape Girardeau, MO-IL.............................. yes.
16300.......................... Cedar Rapids, IA...................................
16700.......................... Charleston-North Charleston, SC....................
16860.......................... Chattanooga, TN-GA.................................
16980.......................... Chicago-Naperville-Elgin, IL-IN-WI.................
17020.......................... Chico, CA..........................................
17660.......................... Coeur d'Alene, ID..................................
17860.......................... Columbia, MO....................................... yes.
17900.......................... Columbia, SC.......................................
17980.......................... Columbus, GA-AL....................................
18880.......................... Crestview-Fort Walton Beach-Destin, FL.............
19100.......................... Dallas-Fort Worth-Arlington, TX....................
19300.......................... Daphne-Fairhope-Foley, AL..........................
19740.......................... Denver-Aurora-Lakewood, CO......................... yes.
19780.......................... Des Moines-West Des Moines, IA.....................
20100.......................... Dover, DE..........................................
20500.......................... Durham-Chapel Hill, NC............................. yes.
21060.......................... Elizabethtown-Fort Knox, KY........................
21500.......................... Erie, PA...........................................
21660.......................... Eugene, OR.........................................
22520.......................... Florence-Muscle Shoals, AL.........................
22660.......................... Fort Collins, CO...................................
23060.......................... Fort Wayne, IN.....................................
23580.......................... Gainesville, GA.................................... yes.
24300.......................... Grand Junction, CO.................................
24860.......................... Greenville-Anderson-Mauldin, SC....................
25940.......................... Hilton Head Island-Bluffton-Beaufort, SC...........
26580.......................... Huntington-Ashland, WV-KY-OH.......................
26820.......................... Idaho Falls, ID....................................
26900.......................... Indianapolis-Carmel-Anderson, IN................... yes.
26980.......................... Iowa City, IA......................................
27620.......................... Jefferson City, MO.................................
27860.......................... Jonesboro, AR......................................
27900.......................... Joplin, MO.........................................
28020.......................... Kalamazoo-Portage, MI..............................
28140.......................... Kansas City, MO-KS................................. yes.
28420.......................... Kennewick-Richland, WA.............................
29100.......................... La Crosse-Onalaska, WI-MN..........................
29420.......................... Lake Havasu City-Kingman, AZ.......................
29460.......................... Lakeland-Winter Haven, FL..........................
29620.......................... Lansing-East Lansing, MI...........................
30460.......................... Lexington-Fayette, KY..............................
30620.......................... Lima, OH...........................................
30780.......................... Little Rock-North Little Rock-Conway, AR...........
[[Page 240]]
31540.......................... Madison, WI........................................ yes.
31700.......................... Manchester-Nashua, NH..............................
32780.......................... Medford, OR........................................
32820.......................... Memphis, TN-MS-AR.................................. yes.
33340.......................... Milwaukee-Waukesha-West Allis, WI.................. yes.
33540.......................... Missoula, MT.......................................
34820.......................... Myrtle Beach-Conway-North Myrtle Beach, SC-NC......
34980.......................... Nashville-Davidson-Murfreesboro-Franklin, TN....... yes.
35100.......................... New Bern, NC.......................................
35660.......................... Niles-Benton Harbor, MI............................
36420.......................... Oklahoma City, OK.................................. yes.
36540.......................... Omaha-Council Bluffs, NE-IA........................
39140.......................... Prescott, AZ.......................................
39380.......................... Pueblo, CO.........................................
39580.......................... Raleigh, NC........................................
39660.......................... Rapid City, SD.....................................
39740.......................... Reading, PA........................................ yes.
39900.......................... Reno, NV...........................................
40060.......................... Richmond, VA.......................................
40220.......................... Roanoke, VA........................................
41100.......................... St. George, UT.....................................
41140.......................... St. Joseph, MO-KS..................................
41420.......................... Salem, OR..........................................
41500.......................... Salinas, CA........................................
42340.......................... Savannah, GA.......................................
43300.......................... Sherman-Denison, TX................................
44060.......................... Spokane-Spokane Valley, WA.........................
44100.......................... Springfield, IL....................................
46060.......................... Tucson, AZ.........................................
46140.......................... Tulsa, OK..........................................
46220.......................... Tuscaloosa, AL..................................... yes.
46540.......................... Utica-Rome, NY.....................................
47940.......................... Waterloo-Cedar Falls, IA...........................
48300.......................... Wenatchee, WA......................................
48620.......................... Wichita, KS........................................ yes.
48900.......................... Wilmington, NC.....................................
49180.......................... Winston-Salem, NC..................................
49660.......................... Youngstown-Warren-Boardman, OH-PA..................
49740.......................... Yuma, AZ...........................................
----------------------------------------------------------------------------------------------------------------
C. Episode Definition for the EPMs
1. Background
Episode payment models incentivize improvement in the coordination
and quality of care experienced by a Medicare beneficiary, as well as
episode efficiency, by bundling payment for services furnished to the
beneficiary for specific clinical conditions over a defined period of
time. A key model design feature is the definition of the episodes
included in the model. The definition of episodes has two significant
dimensions--(1) a clinical dimension that describes which clinical
conditions and associated services are included in the episode; and (2)
a time dimension that describes the beginning, middle, and end of the
episode.
2. Overview of Three Episode Payment Models
We proposed three new EPMs--AMI, CABG, and SHFFT--that each begin
with a hospitalization and extend 90 days after hospital discharge. The
proposed AMI model includes beneficiaries discharged under an AMI MS-
DRG (280-282), representing admission to an IPPS hospital for AMI that
is treated with medical management, or an IPPS admission for a PCI MS-
DRG (246-251) with an International Classification of Diseases (ICD)--
Clinical Modification (CM) AMI diagnosis code describing an initial AMI
diagnosis in the principal or a secondary diagnosis code position.
The proposed CABG model includes beneficiaries discharged under a
CABG MS-DRG (231-236), representing an IPPS admission for this coronary
revascularization procedure irrespective of AMI diagnosis.
The proposed SHFFT model includes beneficiaries discharged under
hip and femur procedures except major joint MS-DRG (480-482),
representing an IPPS admission for a hip fixation procedure in the
setting of a hip fracture.
One reason these particular episodes were chosen for the proposed
EPMs is that the initiation of treatment for each of the three clinical
conditions included in an episode occurs almost exclusively during a
hospitalization, which we believe would minimize the possibility of
shifting beneficiaries in or out of the EPM based on the site-of-
service where treatment is initiated. The majority of evaluation and
treatment for AMI is performed in the inpatient hospital setting,
commonly beginning when beneficiaries present with symptoms to the
emergency department of a hospital. Patients experiencing an AMI are
almost uniformly admitted to the hospital for further evaluation and
management.\40\ Although PCIs can be performed and
[[Page 241]]
may be paid by Medicare in the hospital outpatient setting in addition
to being performed during a hospitalization, the majority of patients
experiencing an AMI who are candidates for procedural revascularization
receive PCI procedures during the initial hospitalization for AMI where
evaluation also occurs.\41\ CABG procedures are furnished exclusively
in the inpatient hospital setting. We note that all of the Current
Procedural Terminology (CPT) codes that physicians report for CABG are
listed on the hospital Outpatient Prospective Payment System (OPPS)
inpatient-only list in Addendum E of the 2017 OPPS final rule with
comment period that is posted on the CMS Web site.\42\ The hip fixation
procedures performed in the SHFFT model also are predominantly
furnished in the inpatient hospital setting, and we further note that
almost all of the CPT codes that describe these procedures also are on
the OPPS inpatient-only list.
---------------------------------------------------------------------------
\40\ Amsterdam et al. 2014 AHA/ACC Guideline for the Management
of Patients with Non-ST-Elevation Acute Coronary Syndromes.
Circulation. 2014; 130:e344-e426.
\41\ Episodes for beneficiaries with AMI initiated by all U.S.
IPPS hospitals not in Maryland and constructed using standardized
Medicare FFS Parts A and B claims, as proposed in the proposed rule,
that end in CY 2014.
\42\ https://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/HospitalOutpatientPPS/Hospital-Outpatient-Regulations-and-Notices-Items/CMS-1656-FC.html.
---------------------------------------------------------------------------
Hospitals' ability to identify EPM beneficiaries during the
hospitalization that begins the episode (hereinafter the anchor
hospitalization) also is an important consideration in developing
episode payment models that, like the CJR model, rely upon MS-DRG
assignment for IPPS claims following their submission in order to
identify beneficiaries for model inclusion. This is especially
important for medical management of conditions for which the
predictability of the ultimate MS-DRG for the hospitalization is less
certain than for surgical or procedural MS-DRGs. AMI represents a
relative exception among medical conditions as it is associated with
specific clinical and laboratory features that enable hospitals to
identify beneficiaries with AMI during the anchor hospitalization whom
would likely be included in an AMI episode through their ultimate
discharge under an AMI MS-DRG. We note that ICD-CM coding rules allow
AMI diagnosis codes in both the primary and secondary position to map
to AMI MS-DRGs.\43\ In the case of procedural episodes such as CABG,
SHFFT, and AMI episodes for beneficiaries treated with PCI, the MS-DRG
for the procedure performed would determine the ultimate MS-DRG
assignment for the hospitalization unless additional surgeries higher
in the MS-DRG hierarchy also are reported.\44\ Therefore, we proposed
these three EPMs for clinical conditions where MS-DRG assignment is
likely to be certain and known during the anchor hospitalization, even
though treatment for AMI may involve only medical management. We
believe hospitals participating in the proposed EPMs would be able to
identify beneficiaries in EPM episodes through their AMI, CABG, and
SHFFT episode MS-DRGs during the anchor hospitalization, allowing
active coordination of EPM beneficiary care during and after
hospitalization.
---------------------------------------------------------------------------
\43\ Medical Severity Diagnosis Related Groups (MS-DRGs):
Definitions Manual. Version 33.0A. 3M Health Information Systems.
(October 1, 2015). https://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/AcuteInpatientPPS/FY2016-IPPS-Final-Rule-Home-Page-Items/FY2016-IPPS-Final-Rule-Data-Files.html.
\44\ Medical Severity Diagnosis Related Groups (MS-DRGs):
Definitions Manual. Version 33.0A. 3M Health Information Systems.
(October 1, 2015). https://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/AcuteInpatientPPS/FY2016-IPPS-Final-Rule-Home-Page-Items/FY2016-IPPS-Final-Rule-Data-Files.html.
---------------------------------------------------------------------------
3. Clinical Dimensions of AMI, CABG, and SHFFT Episodes
As we stated in the CJR Final Rule, we believe that a
straightforward approach for hospitals and other providers to identify
Medicare beneficiaries in these episode payment models would be
important for the care redesign that is required for EPM success, as
well as for operationalization of the proposed payment and other EPM
policies (80 FR 73299). Therefore, as in the CJR model, we proposed
that an EPM episode would be initiated by an admission to an acute care
hospital for an anchor hospitalization paid under EPM-specific MS-DRGs
under the IPPS (80 FR 73300).
The following is a summary of the comments received and our
responses:
Comment: Many commenters expressed support for CMS' proposal to use
many of the BPCI Model 2 and CJR episode parameters to define EPM
episodes because of the provider experience to date with these design
features and their applicability to the clinical conditions that are
the basis of the EPMs. Several commenters specifically recommended that
CMS begin EPM episodes with emergency department care because including
beneficiaries with emergency department care and observation status
would include all beneficiaries with the clinical conditions that were
included in the proposed EPMs. While the commenters acknowledged that
many beneficiaries with the clinical conditions in the EPMs would be
admitted to the hospital, they believe there is a subset of
beneficiaries for whom care could solely be furnished through emergency
department and observation care. Other commenters requested
clarification on how a beneficiary treated in observation status and
then transferred to another hospital would be handled under the EPMs
because the beneficiary would never be assigned to an MS-DRG at the
initial treating hospital. The commenters believe that a hospital could
use this strategy to avoid including high-cost beneficiaries in the
EPMs. The commenters stated that patient stabilization is critical and
the resources needed to care for the beneficiary should not dictate
observation status versus inpatient status due to a hospital
participation in an EPM. Several commenters encouraged CMS to provide
additional guidance on instances when the beneficiary is never admitted
at the initial hospital, but rather transferred from the emergency
department or observation status to another hospital for AMI or CABG.
One commenter recommended that CMS modify the Episode Grouper for
Medicare (EGM) which, to date, has only been considered for resource-
use measurement, to implement advanced APMs designed around EPMs to
correct problems the commenter believes would be present in the
proposed EPMs that would rely on MS-DRGs, including limited severity
adjustment, the limits on who can bear risk, and the inadequate
incentives against complications. The commenter claimed that an acute
care bundle in the hospital setting is important, but so is managing
chronic conditions in an outpatient setting (which often lead to acute
inpatient episodes). While contracting for condition episodes and
procedure episodes separately is feasible and creates a different level
of accountability, the commenter stated that it is even more desirable
to consider contracting for the whole patient; that is, procedure
episodes should be considered downstream events deeply tied to the
effective management of condition episodes. The commenter stated that
the nested construction logic of the EGM was designed with this in
mind.
A commenter contended that the proposed structure for the new EPM
episodes would continue to reward providers for complications. Payments
would be based on the beneficiary's assigned MS-DRG, so a complication
of care could move a low risk patient from a lower paying MS-DRG to a
higher paying MS-DRG that could result in a
[[Page 242]]
significant increase in revenue. The commenter believes the problem is
further compounded because it penalizes providers who invest in quality
improvement. Providers that invest time and resources into care
redesign that successfully reduces complications that influence MS-DRG
assignment do not share in the savings that they generate through their
efforts. The commenter stated that the MS-DRG payment categorization
creates a substantial financial incentive to avoid quality improvement
in favor of focusing on improving the management of adverse events
after they occur. The commenters stated that the benefit of using MS-
DRG assignment in the EPMs could be preserved without the perverse
incentive if the payment group for the episode were assigned based on
an MS-DRG assignment that depended only on diagnosis codes that were
present on admission.
Another commenter claimed that MS-DRGs do not map well to care
delivered in post-acute care settings, especially for chronically ill
beneficiaries. MS-DRGs, in identifying diagnoses and procedures
delivered in the acute care hospital setting, often do not relate to
the skilled nursing needs, functional limitations, or therapy/
rehabilitation focused on in post-acute care settings after hospital
discharge. Additionally, the commenter pointed out that MS-DRGs do not
take into account a patient's functional status, which is an important
indicator for determining a patient's post-acute care needs. The
commenter recommended CMS to develop a more robust risk adjustment
methodology under the EPMs, because MS-DRGs alone are not sufficient
for medically complex patients. For those providers caring for the
sickest beneficiaries, the commenter recommended that CMS create
separate bundled payments for seriously ill beneficiaries, as defined
by something other than MS-DRG.
Response: We appreciate the support that many commenters expressed
for our proposal to identify Medicare beneficiaries included in the
proposed EPMs by their admission to an acute care hospital for a
hospitalization paid under EPM-specific MS-DRGs under the IPPS. We and
many stakeholders have gained substantial experience with bundled
payment models of a similar design under BPCI Model 2 and the CJR
model. We agree with the many commenters who stressed the importance of
EPM participants being able to identify EPM beneficiaries on a timely
basis as early as possible during the episodes in order to maximize the
opportunities for care redesign to improve EPM episode quality and
reduce costs. As we discussed in the proposed rule (81 FR 50813), we
believe that a straightforward approach to EPM model design that would
allow hospitals and other providers to identify Medicare beneficiaries
in these episode payment models would be important for the care
redesign that is required for EPM success, as well as for
operationalization of the proposed payment and other EPM policies, and
agree with many commenters that our proposed design of the EPMs meets
these objectives.
While we acknowledge the perspective of some commenters that a
small number of beneficiaries with clinical conditions that are the
focus of the EPMs, especially AMI, may be appropriately treated in the
emergency department with observation status without hospital
admission, we believe it is infeasible to include these beneficiaries
in the EPMs due to complex operational challenges for CMS and EPM
participants and model design parameters, such as appropriate pricing
in the context of varied hospital cardiac care capabilities. We refer
to section III.C.4.a.(1) of this final rule for further discussion of
comments on outpatient treatment scenarios and our responses. We refer
to section III.C.4.a.(5) of this final rule for discussion of
outpatient-to-inpatient (o-i) transfer scenarios for beneficiaries with
AMI, including when AMI episodes would begin and to which hospital the
episode would be attributed. We agree with the commenters that patient
stabilization of serious conditions such as AMI in the emergency
department of a hospital is critical and the resources needed to care
for the beneficiary should not dictate observation status versus
inpatient status due to a hospital participation in an EPM. We believe
our final EPM policies, including our AMI model transfer policies,
reflect our commitment to ensuring that the initial care of
beneficiaries with urgent conditions such as those targeted by the EPMs
is not influenced by hospital participation in an EPM. We also refer to
sections III.G.4. through 6. of this final rule for discussion of our
monitoring plans to detect changing patterns of care under the EPMs,
including practices that could indicate that medically complex
beneficiaries who otherwise would be expected to be in high-cost EPM
episodes do not initiate EPM episodes.
While we have an interest in future condition-specific episode
payment models and sought public comment on this topic in the proposed
rule (81 FR 50810 through 50811), we have not identified long-term
management of beneficiaries with chronic disease as the focus of these
EPMs, which are proposed to extend 90 days post-hospital discharge from
an anchor hospitalization for beneficiaries who have cardiac or
orthopedic surgery or a cardiac event.
As one commenter pointed out, MS-DRGs currently provide higher
payments for beneficiaries who experience complications during the
inpatient hospitalization and we appreciate the interest of the
commenter in EPMs that encourage improvement in quality of care during
the anchor hospitalization for which hospitals would be rewarded.
However, given the operational challenges that EPMs that require
participation present for EPM participants and CMS, it would be
infeasible in models like the EPMs to regroup beneficiaries to
different MS-DRGs for setting EPM episode prices based only on their
diagnoses that were present on admission to address underlying payment
incentives under the IPPS. Instead, the EPMs focus EPM participants on
care redesign to improve the quality of care for EPM beneficiaries that
may achieve internal hospital cost savings for the anchor
hospitalization and/or savings to Medicare in the post-hospital
discharge period. We expect that some of those care redesign strategies
that improve care coordination for EPM beneficiaries may have spill-
over effects that result in reduced in-hospital complications as well.
Finally, we refer to section III.D.4.b.(2) of this final rule for a
discussion of risk adjustment under the EPMs. Because all EPM
participants care for some seriously ill beneficiaries, some hospitals
may disproportionately care for such beneficiaries due to their service
area, referral patterns, and/or specialized hospital capacity. We
believe appropriate risk adjustment of EPM episode prices, particularly
by performance year 3 when the pricing blend shifts to reflect
predominantly regional pricing, addresses the commenter's concern that
led them to recommend that CMS create separate bundled payments for
seriously ill beneficiaries as defined by something other than MS-DRG
for those providers caring for the sickest patients. While we agree
with the commenter that MS-DRGs only reflect the resources for the
anchor hospitalization and, therefore, do not necessarily reflect the
post-acute care resources required by a beneficiary, we note that the
IPPS payment for the anchor hospitalization is included in the EPM
episode and constitutes, on average, a significant percentage of the
EPM episode spending, specifically 33
[[Page 243]]
percent of AMI episode spending for episodes anchored by AMI MS-DRGs;
58 percent of AMI episode spending for episodes anchored by PCI MS-
DRGs; 63 percent of CABG episode spending; and 27 percent of SHFFT
episode spending.\45\ Thus, we do not believe it is necessary or
appropriate to create separate bundled payments for seriously ill
beneficiaries defined by a grouping other than MS-DRG, because the
specific MS-DRG of the anchor hospitalization determines a significant
percentage of spending for the episode for EPM beneficiaries, including
seriously ill beneficiaries.
---------------------------------------------------------------------------
\45\ Episodes for AMI, CABG, and SHFFT beneficiaries initiated
by all U.S. IPPS hospitals not in Maryland and constructed using
standardized Medicare FFS Parts A and B claims, as proposed in the
proposed rule that began in CYs 2012-2014.
---------------------------------------------------------------------------
Comment: Several commenters expressed concern about EPM
participants' ability to identify EPM beneficiaries on a timely basis.
The commenters explained that the final MS-DRGs assigned to the
beneficiary's hospitalization is not generated until several days post-
discharge, thus impacting the EPM participant's ability to predict
whether a beneficiary is in or out of an EPM episode at the time the
beneficiary is in the hospital. One commenter added that because the
MS-DRG is assigned to a patient's case upon discharge, it may not be
predictable during a patient's treatment prior to discharge, making it
difficult for providers to implement care redesign targeted to a
patient population identified by MS-DRGs. This commenter believes that
the MS-DRGs assigned to a patient's stay are often inaccurate or
otherwise inappropriate for the patient's diagnosis, making the
classification an inappropriate basis for episode triggers, budgets,
quality measurement and adjusting for underlying patient illnesses.
Another commenter reported on their BPCI Model 2 experience where 70
percent of model beneficiaries were elective admissions, and 30 percent
presented to the hospital through the emergency department. Given that
the proposed EPMs would be more similar to the commenter's experience
with emergency department admissions, the commenter expressed concern
that the EPMs would limit an EPM participant's ability to intervene
with the beneficiary prior to admission and skepticism that the
participant could even identify the beneficiary as being eligible for
the EPM prior to hospital discharge. The commenter added that with very
sick patients, hospitals often must wait for the appropriate coding to
confirm which MS-DRG the patient ultimately is assigned to prior to
billing.
Several commenters further stated that precedence rules among
different models and programs can touch the same beneficiary, and
stated that hospital case managers, nurses, and administrators cannot
know at admission or even before discharge which model the beneficiary
may already be enrolled in or attributed to based on prior utilization.
Response: We appreciate the interest of the commenters in the
timely identification of EPM beneficiaries that would allow EPM
participants the most significant opportunity to influence the care of
these beneficiaries to improve the quality and reduce the cost of EPM
episodes. While we appreciate that many EPM beneficiaries would be
admitted to the hospital on an emergency basis for treatment of hip
fracture, AMI, or CABG surgery under circumstances that would not allow
EPM participants to engage these beneficiaries prior to hospital
admission, we believe that our proposals for the clinical conditions in
the EPMs make identification of most EPM beneficiaries unambiguous
while they are still in the hospital, without a need for hospitals to
wait for coding following discharge to confirm which MS-DRG the patient
ultimately is assigned to for the hospitalization.
As we stated in the proposed rule (81 FR 50829), we agree with the
commenters that hospitals' ability to identify EPM beneficiaries during
the anchor hospitalization is an important consideration in developing
episode payment models that rely upon MS-DRG assignment for IPPS claims
following their submission in order to identify beneficiaries for model
inclusion. We believe the identification of SHFFT and CABG model
beneficiaries should be straightforward for EPM participants because
the relevant MS-DRG assignments directly result from the surgical
procedure performed during the hospitalization and would, therefore, be
accurate. However, identification of beneficiaries for a model focused
on medical management of conditions may be more challenging because the
predictability of the ultimate MS-DRG for the hospitalization is less
certain than for surgical or procedural MS-DRGs. We believe that AMI
represents a relative exception among medical conditions as it is
associated with specific clinical and laboratory features that should
enable hospitals to identify beneficiaries with AMI during the anchor
hospitalization who are treated medically or with PCI and who would
likely be included in an AMI episode through their ultimate discharge
under an AMI MS-DRG. Therefore, we proposed these three EPMs for
clinical conditions where MS-DRG assignment is likely to be certain and
known during the anchor hospitalization, even though treatment for AMI
may involve only medical management. We believe hospitals participating
in the proposed EPMs would generally be able to identify beneficiaries
in EPM episodes through their AMI, CABG, and SHFFT episode MS-DRGs
during the anchor hospitalization, allowing active coordination of EPM
beneficiary care during and after hospitalization.
We refer to section III.D.6.c. of this final rule for discussion of
issues related to beneficiaries whose care could be included in the
EPMs as well as other CMS models and programs.
Comment: One commenter expressed appreciation for CMS' intent to
not have overlap between the same care for a beneficiary in episodes
under more than one EPM. The commenter sought clarification about how
CMS would attribute episodes that originate with one EPM and then cross
over into another EPM. The commenter provided an example of a
beneficiary with a surgical hip fracture who has an AMI during the
hospitalization that is coded in a secondary position, yet the
precipitating event for the hip fracture was through syncope and a
fall.
Response: When an IPPS claim is submitted to Medicare for payment
of a beneficiary's hospitalization, the claim is grouped to an MS-DRG
using the MS-DRG grouper, a software that uses ICD-10-CM diagnosis and
procedures codes submitted on the hospital claim to assign an acute
hospital stay to a particular MS-DRG. Claims are assigned to an MS-DRG
using the grouper effective for the discharge date of the claim. Under
the EPMs, regardless of the chronology and causality of events that led
to the diagnoses and treatment during the hospitalization, we would
rely upon the MS-DRG (and the presence of an ICD-10-CM AMI diagnosis
code on the claim in the case of a PCI MS-DRG) assigned to the claim
following hospital discharge to initiate an EPM episode and define the
EPM to which the beneficiary's care would be attributed. In the
commenter's example in which a patient is admitted to a hospital for
surgical hip fracture fixation and has an AMI during the
hospitalization, the MS-DRG grouper would assign a SHFFT MS-DRG to that
hospitalization. Therefore, the beneficiary would initiate a SHFFT
episode if the hospital is a SHFFT model participant. Regardless of
[[Page 244]]
whether or not the hospital is an AMI model participant, no AMI episode
would be initiated.
Final Decision: After consideration of the public comments
received, we are finalizing the proposal to initiate EPM episodes by an
admission to an acute care hospital for an anchor hospitalization paid
under EPM-specific MS-DRGs under the IPPS, without modification. We
refer to section III.D.4.a.(5) of this final rule for a discussion of
outpatient-to-inpatient and inpatient-to-inpatient transfers between
hospitals under the AMI model. We refer to section III.D.6.c of this
final rule for further discussion of issues related to overlap of
beneficiaries in other Innovation Center models and CMS programs.
a. Definition of the Clinical Conditions Included in AMI, CABG, and
SHFFT Episodes
(1) AMI (Medical Management and PCI) Model
We proposed the AMI model to incentivize improvements in the
coordination and quality of care, as well as episode efficiency, for
beneficiaries treated for AMI with either medical management or
coronary artery revascularization with PCI. We proposed to define
beneficiary inclusion in the AMI model by discharge under an AMI MS-DRG
(280-282), representing those individuals admitted with AMI who receive
medical therapy but no revascularization, and discharge under a PCI MS-
DRG (246-251) with an ICD-10-CM diagnosis code of AMI on the IPPS claim
for the anchor hospitalization in the principal or secondary diagnosis
code position. We note that we would use AMI International
Classification of Diseases, 9th revision clinical modification (ICD-9-
CM) diagnosis codes to identify historical episodes for setting AMI
model-episode benchmark prices in the early performance years of the
AMI model. The Uniform Hospital Discharge Data Set (UHDDS) defines the
principal diagnosis for hospitalization as ``that condition established
after study to be chiefly responsible for occasioning the admission of
the patient to the hospital for care'' and other (secondary) diagnoses
as ``all conditions that coexist at the time of admission, that develop
subsequently, or that affect the treatment received and/or the length
of stay. Diagnoses that relate to an earlier episode which have no
bearing on the current hospital stay are to be excluded.'' \46\ We
proposed to include those beneficiaries discharged under PCI MS-DRGs
with an AMI ICD-10-CM diagnosis code in the principal or secondary
diagnosis code position to ensure that beneficiaries with an AMI that
is not chiefly responsible for occasioning the hospitalization are
included in the AMI model because the AMI itself is likely to
substantially influence the hospitalization and post-discharge recovery
(and be responsible for leading to the PCI) even if an AMI ICD-10-CM
diagnosis code is reported in a secondary diagnosis code position. For
example, a beneficiary receiving a PCI with an ICD-10-CM diagnosis code
of pneumonia in the principal position and an AMI ICD-10-CM diagnosis
code in a secondary position would be included in the AMI model, which
would be appropriate because the course of the beneficiary's recovery
and management during the AMI episode would be primarily associated
with the AMI and PCI. While pneumonia is typically an acute illness
that may sometimes result in hospitalization, underlying chronic
conditions may increase the likelihood that a beneficiary would be
hospitalized for pneumonia, a condition that is more commonly treated
on an outpatient basis. AMI in association with a hospitalization for
pneumonia would represent a sentinel event for the beneficiary
resulting from underlying CAD that signals a need for a heightened
focus on medical management of CAD and other beneficiary risk factors
for future cardiac events that may themselves have increased the
beneficiary's risk for pneumonia. Thus, care coordination and
management in the 90 days post-hospital discharge for these
beneficiaries would be focused on managing CAD and the beneficiary's
cardiac function after the AMI.
---------------------------------------------------------------------------
\46\ https://www.cdc.gov/nchs/data/icd/icd10cm_guidelines_2014.pdf.
---------------------------------------------------------------------------
In the proposed rule (81 FR 50830), we acknowledged that this
proposal to identify beneficiaries included in the AMI model through a
combination of MS-DRGs and AMI ICD-CM diagnosis codes represented a
modification of the CJR episode definition methodology. The CJR model
defined episodes based on MS-DRGs alone, specifically MS-DRG 469 (Major
joint replacement or reattachment of lower extremity with Major
Complications or Comorbidities (MCC)) and MS-DRG 470 (Major joint
replacement or reattachment of lower extremity without MCC), because
the anchor hospitalization for the CJR model was defined by admission
for a surgical procedure alone (80 FR 73280). However, the proposed AMI
episodes would be defined by admission for a medical condition that
includes a range of treatment options, including medical treatment and
PCI. Therefore, to identify beneficiaries admitted for AMI and treated
with PCI requires ICD-CM diagnosis codes paired with MS-DRGs to
identify the subset of PCI MS-DRG cases associated with AMI that would
otherwise be excluded from an AMI model based solely on AMI MS-DRGs.
For the purposes of defining historical AMI episodes, we proposed
to exclude beneficiaries discharged under PCI MS-DRGs with an AMI ICD-
9-CM diagnosis code in the principal or secondary position if there was
an intracardiac ICD-9-CM procedure code in any procedure code field.
Intracardiac procedure codes do not represent PCI procedures indicated
for the treatment of the coronary artery obstruction that results in
AMI, but instead represent a group of procedures indicated for treating
congenital cardiac malformations, cardiac valve disease, and cardiac
arrhythmias. These intracardiac procedures are performed within the
heart chambers rather than PCI procedures for AMI that are performed
within the coronary blood vessels. To reflect this clinical
distinction, the FY 2016 IPPS update removed intracardiac procedures
from MS-DRGs 246-251 and assigned them to new MS-DRGs 273 and 274 (80
FR 49367). Therefore, to be consistent with our proposed definition of
AMI episodes that initiate with PCI MS-DRGs 246-251 (not with MS-DRGs
273 and 274) and an AMI ICD-9-CM diagnosis code in the principal or
secondary position, we proposed to define historical AMI episodes for
beneficiaries discharged under PCI MS-DRGS 246-251 as those that do not
include the ICD-9-CM procedure codes in Table 3. These codes were also
posted on the CMS Web site at https://innovation.cms.gov/initiatives/epm.
[[Page 245]]
Table 3--Proposed ICD-9-CM Procedure Codes in any Position on the IPPS
Claim for PCI MS-DRGS (246-251) That Do Not Define Historical AMI
Episodes
------------------------------------------------------------------------
ICD-9-CM procedure code ICD-9-CM procedure code description
------------------------------------------------------------------------
35.52............................. Repair of atrial septal defect with
prosthesis, closed technique.
35.96............................. Percutaneous balloon valvuloplasty.
35.97............................. Percutaneous mitral valve repair
with implant.
37.26............................. Catheter based invasive
electrophysiologic testing.
37.27............................. Cardiac mapping.
37.34............................. Excision or destruction of other
lesion or tissue of heart,
endovascular approach.
37.36............................. Excision, destruction, or exclusion
of left atrial appendage.
37.90............................. Insertion of left atrial appendage
device.
------------------------------------------------------------------------
In FY 2014, there were approximately 395,000 beneficiaries
discharged from a short-term acute care hospitalization (excluding
Maryland) with an AMI ICD-9-CM diagnosis code in the principal or
secondary position on the IPPS claim. Of these beneficiaries, 58
percent were discharged under MS-DRGs that would initiate an AMI
episode, specifically an AMI MS-DRG (33 percent) and PCI MS-DRG (25
percent). Five percent of beneficiaries were discharged from CABG MS-
DRGs and 3 percent were discharged from AMI MS-DRGs representing death
during the hospitalization. The remaining 34 percent of beneficiaries
with an AMI ICD-CM diagnosis code in the principal or secondary
position were distributed across over approximately 300 other MS-DRGs,
with the septicemia MS-DRGs accounting for 8 percent and the remainder
accounting for 3 percent or less of beneficiaries with an AMI ICD-CM
diagnosis code on the IPPS claim.\47\ We note that the AMI ICD-9-CM
diagnosis code was most commonly in a secondary position for discharges
from these other MS-DRGs, likely representing beneficiaries
hospitalized for another condition who experienced an AMI during that
hospitalization. We further note that CMS' AMI quality measures used in
the Hospital Inpatient Quality Reporting (HIQR) Program are based on
all beneficiaries discharged under any MS-DRG who have an AMI ICD-CM
diagnosis code only in the principal position, reflecting the measures'
focus on the most homogeneous beneficiary population with AMI as the
condition responsible for occasioning the hospital admission. This is
in contrast with our proposed use of an AMI ICD-10-CM diagnosis code in
the principal or a secondary position for the AMI model in order to
identify those beneficiaries receiving a PCI whose hospitalization and
post-discharge recovery and management would primarily be associated
with the PCI and AMI.
---------------------------------------------------------------------------
\47\ Inpatient claims from all U.S. IPPS hospitals not in
Maryland were derived from the October 2013--September 2014
Inpatient Claims File located in the Chronic Conditions Warehouse.
---------------------------------------------------------------------------
The proposed specifications for AMI episodes, including ICD-9-CM
AMI diagnosis codes for historical episodes used to set the initial AMI
model-episode benchmark prices and ICD-10-CM AMI diagnosis codes for
the performance years of the model, are displayed in Table 5. The
proposed ICD-9-CM intracardiac procedure codes used to exclude
inpatient claims with PCI MS-DRGs 246-251 from anchoring AMI model
historical episodes used to set initial AMI model-episode benchmark
prices are displayed in Table 3.
Based on Medicare claims data for historical AMI episodes ending in
CYs 2012-2014, the annual number of potentially eligible beneficiary
discharges for the AMI model nationally was approximately 168,000.\48\
This number was less than the approximately 229,000 discharges for
beneficiaries with AMI discharged from AMI MS-DRGs 280-282 and PCI MS-
DRGs 246-251 that could be expected to be included in the AMI model for
several reasons. Discharges did not result in historical episodes when
a beneficiary did not meet the beneficiary care inclusion criteria
discussed in section III.C.4.a.(1) of the proposed rule (81 FR 50834);
was not discharged alive from PCI MS-DRGs 246-251; was discharged from
a transfer hospital during a chained anchor hospitalization; or was
discharged from a readmission during an AMI episode that did not
initiate new model episodes.
---------------------------------------------------------------------------
\48\ Episodes for AMI beneficiaries initiated by all U.S. IPPS
hospitals not in Maryland and constructed using standardized
Medicare FFS Parts A and B claims, as proposed in the proposed rule
that began in CYs 2012-2014.
---------------------------------------------------------------------------
The list of ICD-9-CM and ICD-10-CM AMI diagnosis codes used to
identify beneficiaries discharged under a PCI MS-DRG (MS-DRGs 246-251)
in historical episodes and during the performance years of the model
that would be included in the AMI episodes were discussed in section
III.C.4.a.(2) of the proposed rule (81 FR 50834 through 50835). To make
changes to this list as necessary based on annual ICD-10-CM coding
changes or to address issues raised by the public throughout the EPM
performance years, we proposed implementing the following sub-
regulatory process, which mirrors the sub-regulatory process as
described in the CJR Final Rule for updating hip fracture ICD-9-CM and
ICD-10-CM diagnosis codes (80 FR 73340) and for updating the exclusion
list (80 FR 73305 and 73315). We proposed to use this process on an
annual, or more frequent, basis to update the AMI ICD-10-CM diagnosis
code list and to address issues raised by the public. As part of this
process, we proposed the following standard when revising the list of
ICD-10-CM diagnosis codes representing AMI: The ICD-10-CM diagnosis
code is sufficiently specific that it represents an AMI. We proposed to
then post a list of potential AMI ICD-10-CM diagnosis codes to the CMS
Web site at https://innovation.cms.gov/initiatives/epm to allow for
public input on our planned application of these standards, and then
adopt the AMI ICD-10-CM diagnosis code list with posting to the CMS Web
site of the final AMI ICD-CM diagnosis code list after our
consideration of the public input. We would provide sufficient time for
public input based on the complexity of potential revisions under
consideration, typically at least 30 days, and, while we would not
respond to individual comments as would be required in a regulatory
process, we could discuss the reasons for our decisions about changes
in response to public input with interested stakeholders.
The proposals for identifying the beneficiaries included in the AMI
model and the sub-regulatory process for updating the AMI ICD-10-CM
diagnosis code list were included in proposed Sec. 512.100(c)(1) and
(d), respectively. We sought comment on our proposals to identify
beneficiaries included in the AMI model and the sub-regulatory process
for updating the AMI ICD-10-
[[Page 246]]
CM diagnosis code list. The proposal to exclude inpatient claims with
PCI MS-DRGS 246-251 from anchoring AMI model historical episodes used
to set initial AMI model-episode benchmark prices when there was an
ICD-9-CM intracardiac procedure code on the claim was included in
proposed Sec. 512.100(d)(4). We sought comment on our proposal to
exclude inpatient claims with PCI MS-DRGS 246-251 from anchoring AMI
model historical episodes used to set initial AMI model-episode
benchmark prices when there was an ICD-9-CM intracardiac procedure code
on the claim.
We received no comments on the proposed sub-regulatory process for
updating the AMI ICD-10-CM diagnosis code list. The following is a
summary of the comments received on the other AMI model proposals to
define the included clinical conditions and our responses.
Comment: Several commenters expressed concern that the AMI model
would be so heavily reliant upon coding that creates an artificial
clinical population which is so heterogeneous as to make clinical care
redesign efforts nonspecific and likely ineffective. They contended
that while EPMs based on surgical MS-DRGs streamline patient
identification and inclusion, the AMI model would depend on multiple
levels of coding, both ICD-10-CM and MS-DRGs. One commenter explained
that an important distinction between medical diagnosis and procedural-
based episode-of-care models is that medical diagnosis models tend to
involve a patient population of greater complexity, often with life-
threating conditions. The commenter believes that, where appropriate,
this awareness should be reflected in the design of the EPMs. The
commenters were concerned that the proposed AMI model would put a
greater emphasis on coding methodologies and increase the chance of
disparities between cases identified by each responsible hospital for
inclusion in the AMI model versus cases identified by CMS from
historical claims data upon which quality-adjusted target prices would
be based. The commenters stressed the need for CMS to establish
clinical homogeneity in the AMI model, limiting ambiguity as much as
possible.
Several commenters recommended CMS to use ICD-10-CM coding
strategies to limit inclusion of AMI model beneficiaries to the most
clinically similar subset of beneficiaries in order to allow for
meaningful comparisons and ultimately provide CMS the opportunity to
clearly evaluate the impact of the AMI model on patient care and
outcomes. The commenters stated that with the move from ICD-9-CM to
ICD-10-CM, the coding stages associated with AMI have changed,
warranting additional considerations. Specifically, a number of
commenters recommended that CMS limit the AMI model to beneficiaries
with ST-elevation myocardial infarction (STEMI) discharged under AMI
MS-DRGs and PCI MS-DRGs with an AMI ICD-10-CM code only in the
principal diagnosis code position on the inpatient claim. The
commenters claimed that while STEMIs occur due to an acute coronary
artery occlusion, many non-ST elevation (NSTEMI) beneficiaries with AMI
experience open coronary arteries but there is an imbalance between the
oxygen demands of the heart and the coronary arteries' ability to meet
them. The commenters added that due to these substantial differences in
the underlying pathophysiology of STEMI and NSTEMI AMI patients that
lead to more variation in clinical presentation in NSTEMI patients, in
addition to the different approaches to their evaluation and
management, the AMI model should only include STEMI beneficiaries
which, when risk adjustment is applied, represent a more homogenous
population compared to NSTEMI patients.
These commenters presented the most current consensus driven
definition of AMI, the third universal definition, as: ``Evidence of
myocardial necrosis consistent with acute myocardial ischemia. Under
these conditions, any one of the following criteria meets the diagnosis
for MI:
Detection of a rise and/or fall of cardiac biomarker
values, preferably cardiac troponin with at least one value above the
99th percentile upper reference limit; and at least one of the
following:
Symptoms of new ischemia;
New or presumed new significant ST-segment-T wave (ST-T)
changes or new left bundled branch block (LBBB);
Development of pathological Q waves in the ECG;
Imaging evidence of new loss of viable myocardium or new
regional wall motion abnormality; and
Identification of an intracoronary thrombus by angiography
or autopsy.'' \49\
---------------------------------------------------------------------------
\49\ Thygesen K., Alpert J.S., Jaffe A.S., et al and the Writing
Group on behalf of the Joint ESC/ACCF/AHA/WHF Task Force for the
Universal Definition of Myocardial Infarction. Circulation.
2012;126:2020-2035.
---------------------------------------------------------------------------
The commenters recommended CMS to clearly define AMI for the EPM
because they claimed that currently what is coded as AMI often only
meets this definition in part and may be limited to abnormal biomarkers
that can be detected without an acute occlusion of a coronary artery.
Aligning coding with clinical reality is necessary for establishing
clinical homogeneity in the AMI model. The commenters believe that
including in the AMI model beneficiaries not only with a principal but
a secondary diagnosis of AMI would make it difficult to establish a
clearly defined clinically homogeneous population for the following
reasons:
Critically ill patients often receive a secondary
diagnosis of AMI for what is more correctly characterized as supply-
demand ischemia due to the routine and inaccurate coding of any
troponin leak or elevation as an AMI, despite the absence of a clinical
event suggestive of infarction. The commenters provided examples such
as a beneficiary with metastatic breast cancer and internal bleeding
who exhibits a slight cardiac troponin leak or a beneficiary with
multi-organ failure, stating that the root cause of small elevation of
troponin in these cases would be the underlying condition, not CAD.
They also claimed that elderly patients with heart failure or rapid
atrial fibrillation may have a secondary AMI ICD-CM diagnosis, yet the
heart failure or atrial fibrillation would drive decisions about care,
not the AMI.
Outcomes and cost-of-care for critically ill patients with
a secondary AMI diagnosis are likely driven more by the primary
condition than by AMI resulting from possible CAD.
Patterns of care are very different for patients with a
secondary, as compared to a principal, diagnosis of AMI; and
Including patients with a secondary diagnosis of AMI
increases the variability within the AMI model, limiting opportunity to
draw clear conclusions when testing the model.
One commenter requested that CMS account for beneficiaries with AMI
who do not have a traditional AMI but coding results in discharge under
an AMI MS-DRG by specifying a concrete list of ICD-10-CM codes that, if
included on a claim for a beneficiary discharged under an AMI MS-DRG
from an AMI model participant, would exclude the beneficiary from the
AMI model.
Response: We appreciate the suggestions of the commenters that we
include a more homogeneous group of beneficiaries in the AMI model by
limiting the model to those beneficiaries with a STEMI ICD-CM diagnosis
code in the principal position on the claim for the anchor
hospitalization. Under our proposal to include all beneficiaries
[[Page 247]]
in the AMI model discharged from AMI MS-DRGs and beneficiaries
discharged from PCI MS-DRGs with an AMI ICD-CM diagnosis code listed in
Table 3 (the codes we are finalizing are listed in Table 4) in the
principal or a secondary position on the inpatient claim for the anchor
hospitalization, all of the diagnosis codes except 410.71
(Subendocardial infarction, initial episode of care) in ICD-9-CM and
121.4 (Non-ST elevation (NSTEMI) myocardial infarction) and 122.2
(Subsequent non-ST elevation (NSTEMI) myocardial infarction) are for
STEMI diagnoses. We analyzed historical AMI episodes from 2012-2014 and
found that about 78 percent of episodes were for NSTEMI, while 22
percent were for STEMI.\50\ There are well-established clinical
guidelines for the management of beneficiaries with both NSTEMI and
STEMI, and the clinical care pathways generally differ for these
beneficiaries.51 52 However, to limit the AMI model to
beneficiaries with STEMI only, the minority of beneficiaries with AMI
whose care is less varied, and exclude beneficiaries with NSTEMI, the
majority of beneficiaries with AMI whose care is more varied and highly
dependent on the beneficiary's risk factors for adverse outcomes, would
miss a substantial opportunity to test an EPM for a large proportion of
Medicare beneficiaries with AMI. We believe there are substantial
opportunities for care redesign under the AMI model to improve the
quality and efficiency of episode care for both NSTEMI and STEMI
patients so we will not limit the model to one subgroup of
beneficiaries hospitalized for treatment of AMI. In response to the
commenters who were concerned that including beneficiaries with NSTEMI
and STEMI in the AMI model could interfere with CMS' ability to
evaluate the impact of the AMI model on patient care and outcomes, we
note that as discussed in section IV. of this final rule, we will
examine the impact of the AMI model on subgroups of beneficiaries to
better understand variations in payments and outcomes within and
between hospitals. The identification of subgroups to be examined will
include a variety of key clinical and demographic factors.
---------------------------------------------------------------------------
\50\ Episodes for AMI beneficiaries initiated by all U.S. IPPS
hospitals not in Maryland and constructed using standardized
Medicare FFS Parts A and B claims, as proposed in this rule that
began in CYs 2012-2014.
\51\ Amsterdam EA, Wenger NK, Brindis RG, Casey DE Jr, Ganiats
TG, Holmes DR Jr, Jaffe AS, Jneid H, Kelly RF, Kontos MC, Levine GN,
Liebson PR, Mukherjee D, Peterson ED, Sabatine MS, Smalling RW,
Zieman SJ. 2014 ACC/AHA guideline for the management of patients
with non-ST-elevation acute coronary syndromes: a report of the
American College of Cardiology/American Heart Association Task Force
on Practice Guidelines. Circulation. 2014;130:e344-e426.
\52\ O'Gara PT, Kushner FG, Ascheim DD, Casey DE Jr, Chung MK,
de Lemos JA, Ettinger SM, Fang JC, Fesmire FM, Franklin BA, Granger
CB, Krumholz HM, Linderbaum JA, Morrow DA, Newby LK, Ornato JP, Ou
N, Radford MJ, Tamis-Holland JE, Tommaso CL, Tracy CM, Woo YJ, Zhao
DX. 2013 ACCF/AHA guideline for the management of ST-elevation
myocardial infarction: a report of the American College of
Cardiology Foundation/American Heart Association Task Force on
Practice Guidelines. Circulation. 2013;127.
---------------------------------------------------------------------------
We also analyzed the distribution of AMI ICD-9-CM diagnosis codes
for FY 2014 discharges from AMI and PCI MS-DRGs (ICD-10-CM was not in
use in that year) in the principal versus secondary position for
beneficiaries who would be included in the AMI model under our proposal
because of their assignment to an AMI MS-DRG or to a PCI MS-DRG.\53\ We
found that 94 percent of historical episodes assigned to PCI MS-DRGs
had an AMI ICD-9-CM diagnosis code in the principal position. Of those
episodes with an AMI ICD-9-CM diagnosis code in the secondary position,
the most common principal diagnoses were 996.72 (Other complications
due to other cardiac device, implant, and graft) and 414.01 (Coronary
atherosclerosis of native coronary artery), which constituted 53
percent of cases with an AMI ICD-9-CM diagnosis code only in a
secondary position, while the remaining episodes had one of over 200
different ICD-9-CM diagnoses codes in the principal position. In
addition, we found that 86 percent of episodes assigned to AMI MS-DRGs
had an AMI ICD-9-CM diagnosis code in the principal position. Of those
cases with an AMI ICD-9-CM diagnosis code in the secondary position,
the most common principal diagnoses in descending order of frequency
were 428.23 (Acute on chronic systolic heart failure); 427.31 (Atrial
fibrillation); 428.33 (Acute on chronic diastolic heart failure);
428.43 (Acute on chronic combined systolic and diastolic heart
failure); 428.0 (Congestive heart failure, unspecified); and 428.21
(Acute systolic heart failure). These diagnoses constituted 62 percent
of cases with an AMI ICD-9-CM code only in a secondary position, while
the remaining episodes had one of over 200 different, but primarily
cardiac, ICD-9-CM diagnoses codes in the principal position. We note
that the diagnosis code patterns we observed did not confirm the views
of some commenters that beneficiaries with underlying non-cardiac
disease and a troponin leak, such as a metastatic breast cancer with
internal bleeding, would be included in the AMI model based on our
proposal. However, the AMI model would include some beneficiaries
discharged from AMI MS-DRGs with significant underlying cardiac
conditions such as heart failure and atrial fibrillation in the
principal diagnosis code position, another example provided by some
commenters.
---------------------------------------------------------------------------
\53\ Inpatient claims from all U.S. IPPS hospitals not in
Maryland were derived from the October 2013-September 2014 Inpatient
Claims File located in the Chronic Conditions Warehouse.
---------------------------------------------------------------------------
ICD-CM diagnosis coding does not rely on clinical definitions; it
is the physician who is responsible for documenting the patient's
diagnosis. In other words, coders cannot determine if a patient
suffered an AMI based on cardiac biomarkers. If the physician documents
an AMI, then the coder is required to report the ICD-10-CM code
describing the type of AMI. The coder does not interpret the troponin
levels of a beneficiary.
Based on our analysis of historical claims and the established
rules for medical coding, we believe that it is appropriate to include
the small percentage of beneficiaries with an ICD-CM AMI diagnosis code
only in the secondary position upon discharge from AMI and PCI MS-DRGs
in the AMI model because the principal diagnoses on these claims
generally represent beneficiaries with coronary obstruction. The
secondary AMI diagnosis on the claim would have resulted from a
physician diagnosis of AMI which, as the commenters stated, should be
represented by changes in cardiac biomarker values and at least one
other characteristic of a specified list. In addition to representing a
reasonably homogeneous population, we believe this approach provides an
unambiguous definition for AMI model participants to use to identify
beneficiaries discharged from PCI MS-DRGs who would be in the AMI
model. Because the model is focused on a condition, AMI, rather than a
procedure, and some beneficiaries admitted for PCI will not have an
AMI, it is necessary for PCI MS-DRGs to pair ICD-CM diagnosis codes
with the MS-DRG to identify AMI model beneficiaries.
While we observed that 14 percent of beneficiaries assigned to AMI
MS-DRGs only had an AMI ICD-9-CM diagnosis code in the secondary
position and most commonly another cardiac diagnosis in the principal
position, this group is a small minority of beneficiaries discharged
from AMI MS-DRGs. We do not believe that it is necessary to exclude
these beneficiaries from the AMI model for purposes of clinical
homogeneity because the beneficiaries should have had an AMI documented
by a physician for an AMI diagnosis
[[Page 248]]
code to be included in a secondary position on the hospital claim. We
further observed from our analysis of FY 2014 claims for discharges
from AMI MS-DRGs that those beneficiaries with an AMI ICD-9-CM code in
the principal position commonly had similar cardiac diagnoses (for
example, atrial fibrillation and heart failure) as those beneficiaries
where the order of diagnosis coding was reversed.\54\ Care coordination
and management of other cardiac conditions which would be included in
the AMI episode definition as discussed in section III.C.3.b. of this
final rule would be common for beneficiaries discharged from AMI MS-
DRGs, regardless of whether AMI is the principal or a secondary
diagnosis on the hospital claim that led to the beneficiary's discharge
from an AMI MS-DRG. Therefore, limiting the AMI model beneficiaries
only to those assigned to AMI MS-DRGs based on a principal diagnosis
code of AMI would not significantly increase clinical homogeneity of
those AMI model beneficiaries discharged after medical treatment for
AMI. Moreover, to exclude beneficiaries discharged from AMI MS-DRGs
with an AMI ICD-9-CM diagnosis code only in a secondary position on the
hospital claim from the model could substantially complicate timely EPM
participant identification of the beneficiaries in the model by
including only a subset of beneficiaries assigned to AMI MS-DRGs upon
discharge. Thus, we do not believe it is necessary for AMI MS-DRGs to
pair AMI ICD-CM diagnosis codes with the MS-DRG to identify AMI model
beneficiaries.
---------------------------------------------------------------------------
\54\ Inpatient claims from all U.S. IPPS hospitals not in
Maryland were derived from the October 2013-September 2014 Inpatient
Claims File located in the Chronic Conditions Warehouse.
---------------------------------------------------------------------------
Comment: In addition to the commenters who recommended that CMS
apply specific coding strategies to increase clinical homogeneity of
beneficiaries in AMI episodes, other commenters recommended that CMS
exclude a variety of beneficiaries who would otherwise meet the
proposed AMI model criteria for inclusion. Some commenters further
recommended CMS to make a pricing adjustment for AMI episodes for these
beneficiaries if CMS does not exclude them from the model altogether.
Suggestions included excluding beneficiaries who are in the following
clinical scenarios:
Cardiogenic shock or, at a minimum, the subset of
beneficiaries with cardiogenic shock who are transferred from an AMI
model participant or who are transferred to an AMI model participant,
as the impact of the AMI model on transfer decisions could delay access
to life-saving therapies at specialized centers.
Sepsis who do not have clinically traditional AMI and
would not be expected to follow a typical clinical pathway for AMI.
Experiencing a second or greater AMI, who are more likely
to have complex cardiac needs beyond immediate management of the AMI.
Undergoing organ transplantation or ventricular assist
device (VAD) implantation during the episode, because regional pricing
could limit access to life-saving therapies only available at those few
centers capable of caring for advanced heart failure patients and organ
transplant candidates.
Receiving outpatient inotropes for advanced heart failure
during AMI episodes, because these therapies allow beneficiaries to
avoid a surgical bridge to transplant with VAD implantation but are
used in a group of beneficiaries who might otherwise receive a VAD. The
commenters believes this would be consistent with excluding
beneficiaries who receive VAD during AMI episodes from the AMI model.
Undergoing CABG or other cardiac surgery within 90 days
following discharge from the hospitalization for AMI because they must
be medically optimized prior to surgery to ensure safe outcomes. This
percentage of beneficiaries is higher for certain hospitals with
complex patient populations, and the proposed payment methodology would
not adequately account for these high-cost cases.
Response: We appreciate the recommendations of the commenters
regarding the exclusion of certain complex, potentially high-cost
beneficiaries from the AMI model. We do not believe it would be
appropriate to exclude beneficiaries experiencing cardiogenic shock or
a second or subsequent AMI from the AMI model because there are
significant opportunities for improving the quality and efficiency of
care for these beneficiaries during episodes, despite their greater
complexity and medical needs, and we believe it is important to include
these beneficiaries in the test of the AMI model. In response to the
commenters who recommended that we exclude beneficiaries with sepsis
and atypical AMI from the AMI model, based on our proposed definition
of the beneficiaries to be included in the AMI model and the ICD-CM
diagnosis code analysis discussed in the response to the previous
comment, we do not believe that beneficiaries with sepsis and
clinically atypical AMI would generally be included in the AMI model
because they would not be assigned to AMI or PCI MS-DRGs.
While readmission for cardiac transplantation or VAD implantation
would be excluded from AMI episodes based on our proposed AMI model
exclusion list, these beneficiaries would otherwise initiate and remain
in AMI episodes throughout the 90-day post-discharge period both before
and following cardiac transplantation or VAD implantation that occurs
during the 90-day period. Other readmissions and Part B services
furnished to these beneficiaries would be included in the episodes
based on the proposed exclusion list. We believe it is important to
include in the AMI model these beneficiaries with complex care needs
following hospitalization for AMI, including those receiving outpatient
inotropes during AMI episodes, because there are opportunities to
improve the quality and efficiency of their care, despite their
experiencing severe sequelae following AMI.
Finally, we note that we also do not believe it would be
appropriate to exclude from the AMI model those beneficiaries receiving
CABG or other cardiac surgery during AMI episodes after a period of
medical optimization following discharge from the anchor
hospitalization. As discussed in section III.D.4.b.(2)(c) of this final
rule, we are providing a pricing adjustment for AMI episodes with a
CABG readmission for beneficiaries who follow this medically
appropriate clinical pathway. We refer to section III.D.4.b.(2) of this
final rule for further discussion of risk adjustment in the context of
the AMI model's implementation of downside risk and progression to
regional pricing for AMI episodes.
Comment: Several commenters supported excluding intracardiac
valvular and ablation procedures from historical AMI episodes for
clinical consistency between historical AMI episodes and those during
the AMI model performance years. They explained that intracardiac
valvular and ablation procedures are typically unrelated to management
of an AMI but would historically have substantially impacted the total
spending in historical AMI episodes for beneficiaries discharged from
MS-DRGs 246 through 251 in centers that performed those procedures.
Response: We appreciate the support from the commenters. We
continue to believe it is appropriate to define historical AMI episodes
for beneficiaries discharged under PCI MS-DRGS 246-251 as those that do
not include the ICD-9-CM procedure codes in Table 4.
[[Page 249]]
Final Decision: After consideration of the public comments
received, we are finalizing the proposals in Sec. 512.100(c)(1) to
include the care of beneficiaries in the AMI model who meet the general
beneficiary care inclusion criteria as discussed in section
III.C.4.a.(1) of this final rule and who are discharged under an AMI
MS-DRG (280-282), representing those individuals admitted with AMI who
receive medical therapy but no revascularization, or discharged under a
PCI MS-DRG (246-251) with an ICD-10-CM diagnosis code of AMI as
displayed in Table 6 on the IPPS claim for the anchor hospitalization
in the principal or secondary diagnosis code position, without
modification.
We are also finalizing the proposals in Sec. 512.100(d)(4) to
define historical AMI episodes for beneficiaries discharged under PCI
MS-DRGS 246-251 as those that do not include the ICD-9-CM procedure
codes in Table 4, without modification.
Table 4--Final ICD-9-CM Procedure Codes in any Position on the IPPS
Claim for PCI MS-DRGS (246-251) That Do Not Define Historical AMI
Episodes
------------------------------------------------------------------------
ICD-9-CM procedure code ICD-9-CM procedure code description
------------------------------------------------------------------------
35.52............................. Repair of atrial septal defect with
prosthesis, closed technique.
35.96............................. Percutaneous balloon valvuloplasty.
35.97............................. Percutaneous mitral valve repair
with implant.
37.26............................. Catheter based invasive
electrophysiologic testing.
37.27............................. Cardiac mapping.
37.34............................. Excision or destruction of other
lesion or tissue of heart,
endovascular approach.
37.36............................. Excision, destruction, or exclusion
of left atrial appendage.
37.90............................. Insertion of left atrial appendage
device.
------------------------------------------------------------------------
Finally, we are finalizing the proposals in Sec. 512.100(d)(1)-(3)
for the sub-regulatory process to be used on an annual, or more
frequent, basis to update the AMI ICD-10-CM diagnosis code list and to
address issues related to AMI diagnosis codes raised by the public,
without modification. As part of this process, we will use the
following standard when revising the list of ICD-10-CM diagnosis codes
representing AMI: The ICD-10-CM diagnosis code is sufficiently specific
that it represents an AMI. We will post a list of potential AMI ICD-10-
CM diagnosis codes to the CMS Web site at https://innovation.cms.gov/initiatives/epm to allow for public input on our planned application of
the standard, and then adopt the AMI ICD-10-CM diagnosis code list with
posting to the CMS Web site of the final AMI ICD-CM diagnosis code list
after our consideration of the public input. We will provide sufficient
time for public input based on the complexity of potential revisions
under consideration, typically at least 30 days, and, while we will not
respond to individual comments as would be required in a regulatory
process, we can discuss the reasons for our decisions about changes in
response to public input with interested stakeholders.
We note that we reviewed the FY 2017 ICD-10-CM diagnosis code
changes that became available after publication of the EPM proposed
rule in the Federal Register on August 2, 2016. There are no changes or
additions to the ICD-10-CM diagnosis codes reporting AMI for FY 2017 so
we are not suggesting modifications for FY 2017 to the final list
displayed in Table 6 of ICD-10-CM AMI diagnosis codes in the principal
or secondary position on the IPPS claim for PCI MS-DRGs (246-251) that
initiate AMI episodes. Thus, we are not initiating a sub-regulatory
update process for FY 2017 AMI ICD-10-CM diagnosis code updates at this
time.
(2) CABG Model
We proposed the CABG model to incentivize improvements in the
coordination and quality of care, as well as episode efficiency, for
beneficiaries treated with CABG irrespective of AMI during the CABG
hospitalization, thereby including beneficiaries undergoing elective
CABG in the CABG model as well as beneficiaries with AMI who have a
CABG during their initial AMI treatment. The CABG model would be
similar to the CJR model in that the anchor hospitalization would be
defined by admission for a surgical procedure, which would be defined
by the MS-DRGs for that procedure alone (80 FR 73280). All CABG
procedures are performed in the inpatient hospital setting. Thus, we
proposed to include beneficiaries admitted and discharged from an
anchor hospitalization paid under CABG MS-DRGs (231-236) under the IPPS
in the CABG model. Based on Medicare claims data for historical CABG
episodes beginning in CYs 2012-2014, the annual number of potentially
eligible beneficiary discharges for the CABG model nationally was
approximately 48,000.\55\
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\55\ Episodes for CABG beneficiaries initiated by all U.S. IPPS
hospitals not in Maryland and constructed using standardized
Medicare FFS Parts A and B claims, as proposed in the proposed rule,
that began in CYs 2012-2014.
---------------------------------------------------------------------------
The proposal for identifying beneficiaries included in the CABG
model was included in proposed Sec. 512.100(c)(2). We sought comment
on our proposal to identify beneficiaries included in the CABG model.
The following is a summary of the comments received and our
responses.
Comment: Similar to the suggestions of commenters recommending that
CMS exclude certain beneficiaries discharged from AMI MS-DRGs or PCI
MS-DRGs with an AMI ICD-10-CM diagnosis code from the AMI model,
several commenters recommended that CMS exclude a variety of
beneficiaries from the CABG model who would otherwise meet the proposed
CABG model criteria for inclusion. Recommendations include excluding
beneficiaries who are in the following clinical scenarios:
Cardiogenic shock or, at a minimum, the subset of
beneficiaries with cardiogenic shock who are transferred from a model
participant or who are transferred to a model participant, as the
impact of the CABG model on transfer decisions could delay access to
life-saving therapies at specialized centers;
Undergoing organ transplantation or VAD implantation
during the CABG episode, as regional pricing could limit access to
life-saving therapies only available at those few centers capable of
caring for advanced heart failure patients and organ transplant
candidates.
Receiving outpatient inotropes for advanced heart failure
during CABG episodes, because these therapies allow beneficiaries to
avoid a surgical bridge to transplant with ventricular assist device
(VAD) implantation but are used in a group of beneficiaries who might
otherwise receive a VAD. The
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commenters state that this would be consistent with excluding
beneficiaries who receive VAD during CABG episodes from the CABG model.
Undergoing a second or greater CABG, given the increase in
complexity and comorbidities associated with this population.
Undergoing a salvage CABG due to a failed or aborted PCI,
either during a single admission or a readmission, due to the
clinically frail beneficiaries that result in high-cost episodes.
Response: We appreciate the recommendations of the commenters
regarding the exclusion of certain complex, potentially high-cost
beneficiaries from the CABG model, and note that in some cases
recommendations for exclusion were the same as for the AMI model. We do
not believe it would be appropriate to exclude beneficiaries
experiencing cardiogenic shock, undergoing a second or subsequent CABG,
or undergoing salvage CABG from the CABG model because there are
significant opportunities for improving the quality and efficiency of
care for these beneficiaries during episodes, despite their greater
complexity and medical needs, and we believe it is important to include
these beneficiaries in the test of the CABG model.
While readmission for cardiac transplantation or VAD implantation
would be excluded from CABG episodes based on our proposed CABG model
exclusion list, these beneficiaries would otherwise initiate and remain
in CABG episodes throughout the 90-day post-discharge period both
before and following cardiac transplantation or VAD implantation that
occurs during the 90-day period. Other readmissions and Part B services
furnished to these beneficiaries would be included in the episodes
based on the proposed exclusion list. We believe it is important to
include in the CABG model these beneficiaries with complex care needs
following CABG surgery, including those receiving outpatient inotropes
during CABG episodes, because there are opportunities to improve the
quality and efficiency of their care, despite their experiencing severe
sequelae following CABG. We refer to section III.D.4.b.(2) of this
final rule for further discussion of risk adjustment in the context of
the CABG model's implementation of downside risk and progression to
regional pricing for CABG episodes.
Final Decision: After consideration of the public comments
received, we are finalizing the proposals in Sec. 512.100(c)(2) to
include the care of beneficiaries in the CABG model who meet the
general beneficiary care inclusion criteria as discussed in section
III.C.4.a.(1) of this final rule and are discharged under a CABG MS-DRG
(231-236) paid under the IPPS, without modification.
(3) SHFFT (Excludes Lower Extremity Joint Replacement) Model
We proposed the SHFFT model to incentivize improvements in the
coordination and quality of care, as well as episode efficiency, for
beneficiaries treated surgically for hip and femur fractures, other
than hip arthroplasty. Together, the CJR and SHFFT models would cover
all surgical treatment options (that is, hip arthroplasty and fixation)
for Medicare beneficiaries with hip fracture.
The SHFFT model would be similar to the CJR model in that the
anchor hospitalization would be defined by admission for a surgical
procedure, which would be defined by the MS-DRGs for that procedure
alone (80 FR 73280). Additionally, most SHFFT procedures are furnished
in the inpatient hospital setting, consisting primarily of hip fixation
procedures, with or without reduction of the fracture, as well as open
and closed surgical approaches. Thus, we proposed to include
beneficiaries admitted and discharged from an anchor hospitalization
paid under SHFFT MS-DRGs (480-482) under the IPPS in the SHFFT model.
Based on Medicare claims data for historical SHFFT episodes beginning
in CYs 2012-2014, the annual number of potentially eligible beneficiary
discharges for the SHFFT model nationally was approximately
109,000.\56\
---------------------------------------------------------------------------
\56\ Episodes for SHFFT beneficiaries initiated by all U.S. IPPS
hospitals not in Maryland and constructed using standardized
Medicare FFS Parts A and B claims, as proposed in the proposed rule,
that began in CYs 2012-2014.
---------------------------------------------------------------------------
The proposal for identifying beneficiaries included in the SHFFT
model was included in proposed Sec. 512.100(c)(3). We sought comment
on our proposal to identify beneficiaries included in the SHFFT model.
The following is a summary of the comments received and our
responses.
Comment: A number of commenters expressed support for the proposal
to define the clinical conditions included in the SHFFT model as
beneficiaries who are admitted and discharged under SHFFT MS-DRGs.
Other commenters recommended that CMS apply additional episode-specific
criteria to exclude beneficiaries from the SHFFT model who would be
discharged from the SHFFT MS-DRGs. Recommendations of beneficiaries
from some commenters to be excluded include:
Beneficiaries with fracture due to falls or trauma in
association with acute myocardial infarction; cardiac arrhythmia;
syncope; cerebrovascular accident; seizure; head injury; or polytrauma
to reduce the large risk of increases in patient transfers from EPM
participants seeking to reduce their financial responsibility for high-
cost beneficiaries;
Beneficiaries with dementia or Alzheimer's disease due to
ethical issues around withholding surgery that could arise in the case
of EPM participants attempting to reduce their financial risk;
Beneficiaries already residing in a SNF at the time of
fracture, who would necessitate an unavoidable SNF stay after discharge
from the anchor hospitalization that would increase the episode cost
attributable to the EPM participant;
Beneficiaries with fractures related to cancer, who would
be expected to be high-cost cases;
Beneficiaries with a history of previous hip fracture;
previous surgery in the region; retained hardware; open fracture;
periprosthetic fractures; and congenital deformities who would be
expected to have atypical and potentially costly hip fracture care
pathways; and
Beneficiaries who smoke or have diabetes, which are risk
factors for fracture nonunion and infection, respectively, because
these behaviorally mediated risk factors for costly care cannot be
managed prior to hip surgery, unless the SHFFT model adjusts prices for
the higher financial risk attributable to these beneficiaries.
Response: We appreciate the recommendations of the commenters to
exclude certain beneficiaries receiving SHFFT from the SHFFT model due
their personal circumstances, other clinical conditions, or
circumstances that led to the hip fracture. We agree with the
commenters that beneficiaries in this group may be more likely to
require complex care during the anchor hospitalization and significant,
intensive health services during the 90 day post-hospital discharge
period, which could result in high-cost SHFFT episodes. However, we do
not believe it would be appropriate to exclude beneficiaries with
complex social or clinical circumstances from the SHFFT model because
there are significant opportunities for improving the quality and
efficiency of care for these beneficiaries during episodes, despite
their greater complexity and medical needs, and we believe it is
important to
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include these beneficiaries in the test of the SHFFT model. As
discussed in section III.G.4. of this final rule, we will be monitoring
for issues related to access to care. We expect that all Medicare
beneficiaries with hip fracture are offered clinically appropriate
treatments for their fracture and that all transfers of beneficiaries
with hip fracture to other hospitals are medically necessary and not
determined by the SHFFT model participant's assessment of the
beneficiary's risk of a high-cost SHFFT episode. We also refer to
section III.D.4.b.(2) of this final rule for further discussion of risk
adjustment in the context of the SHFFT model's implementation of
downside risk and progression to regional pricing for SHFFT episodes.
Comment: Some commenters stated that there is a sizeable minority
of beneficiaries with hip fracture who should not and do not get
hospitalized or if hospitalized are not treated with surgery for
fracture so would not be included in the SHFFT or CJR models. These
commenters observed that these beneficiaries were not discussed in the
proposed rule and, therefore, no discussion was included about the
decisions related to the appropriate treatment of hip fracture in the
case of serious disability, frailty, and concurrent illness. The
commenters contended that EPM participants that have historically
served a substantial frail population could be seriously disadvantaged
under the SHFFT model due to the significant care needs for these
beneficiaries following hip fracture surgery and might seek to reduce
their traditional commitment to this population in various ways, which
were contrary to the interests of this highly vulnerable population.
Some commenters further speculated that beneficiaries with hip fracture
could be shifted to no surgery or to joint replacement if SHFFT model
participants seek to reduce high-cost cases that present the most
financial risk under the SHFFT model. The commenters further stated
that the SHFFT model may drive SHFFT model participants to provide more
expensive hip replacement to beneficiaries due to their desire to avoid
SNF admission because of the longer need for protected weight-bearing
post-internal fixation after SHFFT in comparison with total joint
replacement where immediate weight-bearing may be possible.
Response: While we agree with the commenters that surgical fracture
repair may not be appropriate for some beneficiaries with hip fracture,
the proposed SHFFT model was designed to include only those
beneficiaries with surgical fracture repair other than joint
replacement and not those for which surgical fracture repair was not
performed. We believe the decision about fracture treatment should
remain that of the beneficiary in consultation with any caregivers and
his or her treating physicians. We did not propose to define the SHFFT
model by hip fracture alone because we believe the primary
opportunities for care redesign under an EPM that seeks to improve
episode quality and efficiency are in the surgical treatment of hip
fracture, rather than in the primary non-surgical management of hip
fracture for beneficiaries who may or may not be hospitalized.
We do not believe that EPM participants would direct Medicare
beneficiaries to other treatments that would result in their not being
included in the SHFFT model simply on the basis of the beneficiary's
potential for being a high-cost hip fracture surgical episode. We refer
to section III.D.4.b.(2) for discussion of risk adjustment for complex
beneficiaries under the SHFFT model. In addition, we note that
beneficiaries with hip fracture who are treated with joint replacement,
a care pattern that some commenters believe could result from SHFFT
model participants' efforts to avoid of high-cost cases under the SHFFT
model, would be included in the CJR model for most SHFFT model
participants who are also CJR participant hospitals as discussed in
section III.B.3. of this final rule. Thus, it is unlikely that a shift
from a SHFFT procedure to joint replacement would financially benefit
the SHFFT model participant. As discussed in sections III.G.4. through
6. of this final rule, we will be closely monitoring for access to
care, quality of care, and delayed care under the SHFFT model.
Final Decision: After consideration of the public comments
received, we are finalizing the proposals in Sec. 512.100(c)(3) to
include the care of beneficiaries in the SHFFT model who meet the
general beneficiary care inclusion criteria as discussed in section
III.C.4.a.(1) of this final rule and are discharged under a SHFFT MS-
DRG (480-482) under the IPPS, without modification.
b. Definition of the Related Services Included in EPM Episodes
The general principles for the definition of related services are
the same for the AMI, CABG, and SHFFT models, so we address them in a
single discussion in this section. Like the CJR model, we are
interested in testing inclusive AMI, CABG, and SHFFT episodes to
incentivize comprehensive, coordinated, patient-centered care for the
beneficiary throughout the episode (80 FR 73303). Therefore, we
proposed to exclude Medicare items and services furnished during the
EPM episodes only when unrelated to the EPM episode diagnosis and
procedures based on clinical rationale that would result in standard
exclusions from all of the episodes in a single EPM. Thus, we proposed
to include all items and services paid under Medicare Part A and Part B
unless they fall under an exclusion because they are unrelated to the
EPM episodes.
Also like the CJR model, we proposed that the items and services
ultimately included in the EPM episodes after the exclusions are
applied are called related items and services, and that Medicare
spending for related items and services be included in the historical
data used to set EPM-episode benchmark prices and in the calculation of
actual EPM episode payments that would be compared against the quality-
adjusted target price to assess the performance of EPM participants (80
FR 73303 and 73315). Additionally, we proposed that Medicare spending
for unrelated items and services (excluded from the EPMs' episode
definitions) would not be included in the historical data used to set
EPM-episode benchmark prices or in the calculation of actual EPM
episode payments. We proposed that related items and services for EPM
episodes would include the following items and services paid under
Medicare Part A and Part B, after the EPM-specific exclusions are
applied:
Physicians' services.
Inpatient hospital services.
Inpatient psychiatric facility (IPF) services.
Long-Term Care Hospital (LTCH) services.
Inpatient Rehabilitation Facility (IRF) services.
Skilled Nursing Facility (SNF) services.
Home Health Agency (HHA) services.
Hospital outpatient services.
Independent outpatient therapy services.
Clinical laboratory services.
Durable medical equipment.
Part B drugs.
Hospice.
We note that inpatient hospital services would include services
paid through IPPS operating and capital payments. The AMI, CABG, and
SHFFT episodes also could include certain per-member-per-month model
payments as discussed in section III.D.6.d. of the proposed rule (81 FR
50871 through 50872). These items and services for the
[[Page 252]]
EPMs are the same items and services included in CJR episodes (80 FR
73303 and 73315).
Similar to the CJR model and for the reasons explained in the CJR
Final Rule, we proposed to exclude drugs that are paid outside of the
MS-DRGs included in the EPM episode definitions, specifically
hemophilia clotting factors, identified by CPT code, diagnosis code,
and revenue center on IPPS claims, from the EPM episodes (80 FR 73303
and 73315). Hemophilia clotting factors, in contrast to other drugs
that are administered during a hospitalization and paid through the MS-
DRG, are paid separately by Medicare in recognition that clotting
factors are costly and essential to appropriate care of certain
beneficiaries. Therefore, we believe there are no EPM episode
efficiencies to be gained in the variable use of these high cost drugs.
We also proposed to exclude IPPS new technology add-on payments for
drugs, technologies, and services from these EPM episodes, excluding
them from both the actual historical episode data used to set EPM-
episode benchmark prices and from actual EPM episode payments that are
reconciled to the quality-adjusted target prices like the CJR model (80
FR 73303-73304 and 73315). This would apply to both the anchor
hospitalization and any related readmissions during the EPM episodes.
New technology add-on payments are made separately and in addition to
the MS-DRG payment under the IPPS for specific new drugs, technologies,
and services that substantially improve the diagnosis or treatment of
Medicare beneficiaries and would be inadequately paid under the MS-DRG
system. We believe it would not be appropriate for the EPM to
potentially diminish beneficiaries' access to new technologies or to
burden hospitals who choose to use these new drugs, technologies, or
services with concern about these payments counting toward EPM
participants' actual EPM episode payment. Additionally, new drugs,
technologies, or services approved for the add-on payments vary
unpredictably over time in their application to specific clinical
conditions.
Finally, we proposed to exclude OPPS transitional pass-through
payments for medical devices as defined in Sec. 419.66 from the EPM
episodes because, through the established OPPS review process, we have
determined that these technologies have a substantial cost but also
lead to substantial clinical improvement for Medicare beneficiaries.
This proposal also is consistent with the CJR model final exclusions
policy (80 FR 73308 and 73315).
We proposed to follow the same general principles in determining
other proposed excluded Part A and Part B services from the EPM
episodes that we use in the CJR model in order to promote coordinated,
high-quality, patient-centered care (80 FR 73304). These include
identifying excluded (unrelated) services rather than included
(related) services based on clinical review. We would operationalize
these principles for the new EPMs, as we do for the CJR model, by
excluding unrelated inpatient hospital admissions during the EPM
episode by identifying MS-DRGs for exclusion on an EPM-specific basis
(80 FR 73304 through 73312 and 73315). We would further exclude
unrelated Part B services during the EPM episode based on the diagnosis
code on the claim by identifying categories of ICD-CM codes for
exclusion (identified by code ranges) on an EPM-specific basis. ICD-9-
CM diagnosis code exclusions would apply to historical episodes used to
construct EPM-episode benchmark prices, while ICD-10-CM diagnosis code
exclusions would apply to EPM episodes during the EPMs' performance
years. We proposed to identify unrelated Part B services and
readmissions based on the BPCI Model 2 Part B exclusion lists that
apply to the anchor MS-DRG that initiates the EPM episode, or to the
price MS-DRG if it is different than the anchor MS-DRG as described
further in section III.D.4.b.(2)(a) of this final rule. This proposal
is consistent with our use of the BPCI Model 2 LEJR ICD-9-CM, ICD-10-
CM, and MS-DRG exclusion lists in the CJR model (80 FR 73304 and
73315).
The BPCI episode-specific exclusion lists were initially developed
more than 3 years ago for the BPCI initiative through a collaborative
effort of CMS staff, including physicians from medical and surgical
specialties, coding experts, claims processing experts, and health
services researchers. The lists have been shared with thousands of
entities and individuals participating in episodes in one or more
phases of the BPCI initiative, and have undergone refinement in
response to stakeholder input about specific diagnoses for exclusion,
resulting in only minimal changes over the last 3 years. Thus, the BPCI
exclusion lists have been vetted broadly in the health care community;
refined based on input from a wide variety of providers, researchers
and other stakeholders; and successfully operationalized in the BPCI
models. We proposed their use in the AMI, CABG, and SHFFT models based
on our confidence related to our several years of experience that these
definitions are reasonable and workable for AMI, CABG, and SHFFT
episodes, for both providers and CMS, and based on our rulemaking for
the CJR model. We note that the BPCI Model 2 exclusion lists for the 48
clinical conditions being tested in the BPCI models include lists that
apply to every MS-DRG that could be an anchor MS-DRG (or price MS-DRG,
if applicable) for the AMI, CABG, and SHFFT episodes.
Similar to the CJR model, we proposed to include in EPM episodes
all Part A services furnished post-hospital discharge during the EPM
episode, as these services are typically intended to be comprehensive
in nature (80 FR 73304 and 73315). We specifically proposed to exclude
unrelated hospital readmissions for MS-DRGs that group to the following
categories of diagnoses: Oncology, trauma medical admissions, surgery
for chronic conditions unrelated to a condition likely to have been
affected by care furnished during the EPM episode, and surgery for
acute conditions unrelated to a condition resulting from or likely to
have been affected by care during the EPM episode. The rationale for
these exclusions is the same as the rationale for their exclusion in
the CJR model (80 FR 73304).
Specifically with respect to Part B services, similar to the CJR
model, we proposed to exclude acute disease diagnoses unrelated to a
condition resulting from or likely to have been affected by care during
the EPM episode, and certain chronic disease diagnoses, as specified by
CMS on a diagnosis-by-diagnosis basis, depending on whether the
condition was likely to have been affected by care during the EPM
episode or whether substantial services were likely to be provided for
the chronic condition during the EPM episode (80 FR 73305 and 73315).
Thus, we would include all Part B services with principal diagnosis
codes on the associated Part B claims that are directly related
(clinically and per coding conventions) to EPM episodes, claims for
diagnoses that are related to the quality and safety of care furnished
during EPM episodes, and claims for services for diagnoses that are
related to preexisting chronic conditions such as diabetes, which may
be affected by care furnished during EPM episodes.
In general, the anchor MS-DRG that initiates the AMI, CABG, or
SHFFT episode would determine the exclusion list that applies to the
EPM episode. For example, AMI episodes may have different exclusion
lists applied based on whether the AMI episode is initiated by
admission to the participant hospital
[[Page 253]]
that results in discharge from an AMI anchor MS-DRG or a PCI anchor MS-
DRG with AMI ICD-10-CM diagnosis code. If a price MS-DRG applies to the
AMI episode that includes a chained anchor hospitalization as described
in section III.D.4.b.(2)(a) of this final rule, the exclusion list that
applies to the price MS-DRG would apply to the AMI episode. Complete
lists of excluded MS-DRGs for readmissions and excluded ICD-CM codes
for Part B services furnished during EPM episodes after EPM beneficiary
discharge from an anchor or chained anchor hospitalization in the AMI,
CABG, and SHFFT models are posted on the CMS Web site at https://innovation.cms.gov/initiatives/epm.
Like the CJR model policy, we proposed that these exclusion lists
would be updated by sub-regulatory guidance on an annual basis, at a
minimum, to reflect annual changes to ICD-10-CM coding and annual
changes to the MS-DRGs under the IPPS, as well as to address any other
issues that are brought to our attention throughout the course of the
EPMs' performance period (80 FR 73304 through 73305 and 73315). The
standards for this updating process reflect the previously discussed
general principles for determining excluded services. That is, we
proposed to not exclude any items or services that are directly related
to the EPM episode diagnosis or procedure (for example, a subsequent
admission for heart failure or repeat revascularization) or the quality
or safety of care (for example, sternal wound infection following
CABG); or to chronic conditions that may be affected by the EPM
diagnosis or procedure and the post-discharge care (for example,
diabetes). We proposed to exclude items and services for chronic
conditions that are generally not affected by the EPM diagnosis or
procedure and the post-discharge care (for example, prostate removal
for cancer), and for acute clinical conditions not arising from
existing EPM episode-related chronic clinical conditions or
complications from the EPM episode (for example, appendectomy).
Similar to the CJR model, we proposed that the potential revised
exclusions, which could include additions to or deletions from the
exclusion lists, would be posted to the CMS Web site to allow for
public input (80 FR 73305 and 73315). Through the process for public
input on potential revised exclusions and then posting of the final
revised exclusions, we proposed to provide information to the public
about when the revisions would take effect and to which episodes they
would apply.
The proposal for included services for an EPM was included in
proposed Sec. 512.210(a). The proposal for excluded services from the
EPM episode was included in proposed Sec. 512.210(b). The proposal for
updating the lists of excluded services for EPMs was included in
proposed Sec. 512.210(c). We sought comment on our proposals for
included and excluded services for the AMI, CABG, and SHFFT models and
updating the lists of excluded services.
The following is a summary of the comments received and our
responses.
Comment: Most commenters expressed general support for CMS'
proposed episode definition strategy that would include Part A and Part
B items and services and exclude certain unrelated readmissions based
on a list of MS-DRGs, as well as certain unrelated Part B services
based on the principal diagnosis on the claim, consistent with the
episode definition approach for LEJR under the CJR model and the
approach used in the BPCI initiative for several years for BPCI, SHFFT,
AMI, PCI, and CABG episodes. The commenters acknowledged that most
items and services would be included in the episode definition under
the proposal, thus creating broadly defined SHFFT, AMI, and CABG
episodes. In some cases, while commenters agreed with the proposed
general strategy for identifying EPM episode exclusions, they made
specific recommendations for additional exclusions based on a different
exclusions standard, and these commenters are summarized later in this
section, where responses are also provided. In other cases, commenters
who agreed with the strategy for identifying EPM episode exclusions
stated that if CMS finalizes broad EPM episode definitions, risk
adjustment would be necessary in order to ensure fair payment to EPM
participants.
Several commenters recommended CMS to provide greater clarity about
the services included in and excluded from EPM episodes. One commenter
stated that it is hard to differentiate included versus excluded
services, and further added that people are ``irreducible bundles'' and
someone needs to be responsible for all of the issues for people when
they are very sick. The commenter recommended that the longer-term
value of patient-centered medical homes, comprehensive ACOs, and
primary care geriatricians should be considered for beneficiaries
completing EPM episodes and recommended that moving people with complex
illness into such arrangements should be a feature of all CMS
innovations as part of moving fee-for-service payment toward quality
and value. A few commenters recommended that CMS provide a clear
definition and methodology for the term ``related services'' which
would be applied consistently throughout various payment models so
providers could verify how their services would be identified and paid.
Finally, several commenters requested that CMS utilize an inclusions
list rather than an exclusion list to avoid including inappropriate
services by default. One commenter presented analysis that showed AMI
model readmission for seizures and other for organic disturbance and
mental retardation would be included in AMI episodes, and the commenter
believes that neurological and mental health conditions are not related
to cardiac care for AMI.
Response: We appreciate the support of many commenters for our
proposed general approach to identifying excluded items and services
for the EPMs. As we stated in the proposed rule (81 FR 50832), we are
interested in testing inclusive AMI, CABG, and SHFFT episodes to
incentivize comprehensive, coordinated, patient-centered care for the
beneficiary throughout the episode. We agree with the commenter that it
can be hard to distinguish included versus excluded services because
sick people have many complex and interrelated clinical conditions and
corresponding health care needs. The proposed EPM episode definitions
are broad in part for this reason. Additionally, while we also agree
with the commenter that the ongoing and acute health care needs of
medically complex beneficiaries may be addressed through a patient-
centered medical home or ACO, many of these vulnerable beneficiaries
currently are not included in such models or programs. In the case of
other beneficiaries who are included in medical home or ACO models or
programs, they may have specific, new care management needs arising
from an acute cardiac event, CABG, or hip fracture surgery that may be
best managed by the EPM participant that has substantial expertise in
coordinating and managing care throughout AMI, CABG, or SHFFT episodes
because of its participation in the EPM, while the ACO or patient-
centered medical home may have less specific expertise in managing
beneficiaries recovering from major orthopedic or cardiac surgery or an
AMI. We expect that EPM participants, accountable for EPM episode
quality and cost performance
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under the EPMs, will work closely with all providers and other
organizations with which a model beneficiary has established
relationships, toward the mutual goal of high quality, well-coordinated
care that maximizes the rate of a beneficiary's return of function and
improvements in health following surgery or AMI. We further expect that
the medical management and care coordination during EPM episodes will
continue to be provided as beneficiaries' transition out of EPM
episodes, potentially into a primary care medical home or other model
or program with accountability for population health, such as an ACO.
Because our proposed inclusive approach to EPM episode definitions
results in many more items and services that are included in EPM
episodes than excluded, we believe it is most efficient to identify
excluded items and services as we proposed. With regard to the
commenters who were concerned that an exclusion list could include
inappropriate services by default, we note that we posted to the CMS
Web site the proposed exclusion lists for the AMI, CABG, and SHFFT
models for comment in association with the proposed rule and are
finalizing the initial exclusion lists through this rulemaking where we
have considered and responded to all the comments we received on our
proposed exclusions. Thus, no items and services would be included in
EPM episodes by default because the exclusion lists have been
established through notice and comment rulemaking. In addition, as
discussed later in this section, we proposed a sub-regulatory process
for updating the exclusion lists to reflect ICD-10-CM coding and annual
changes to the MS-DRGs under the IPPS, as well as to address any other
issues that are brought to our attention throughout the course of the
EPMs' performance periods. The standards for the process reflect the
proposed general principles for excluded services and the process
itself allows opportunity for public input. Thus, we believe that all
items and services included in EPM episodes are intentionally included,
after consideration of public input, rather than included by default.
We note that in the example raised by the commenter of ``default
inclusion,'' we disagree with the commenter that readmissions for
neurological and mental health conditions are unrelated to cardiac care
for AMI. For example, an AHRQ Evidence Report on post-myocardial
infarction found that the evidence is consistent that in patients with
AMI, depression is common at the time of the hospitalization and
persists for at least several months after hospital discharge without
treatment.\57\ Further, the report found that depression is associated
with a significantly increased risk of subsequent death, and of cardiac
readmission and poor quality of life during the first year. Thus, we
would not exclude readmission for treatment of depression from AMI
episodes because we believe that depression would generally be a
chronic condition that was likely to have been affected care during the
AMI model episode. Under our proposal, readmissions for neurological
and mental health conditions would not be excluded from AMI episodes
because they are not MS-DRGs that we proposed to exclude from the AMI
episodes, specifically oncology; trauma medical; chronic disease
surgical unrelated to a condition likely to have been affected by care
during the EPM episode; or acute disease surgical unrelated to a
condition resulting from or likely to have been affected by care during
the AMI episode. Thus, we consider those readmissions related to AMI
episodes as they are medical MS-DRGs for conditions that are likely to
have resulted from or been affected by care during the AMI anchor
hospitalization or during the 90 days post-hospital discharge.
---------------------------------------------------------------------------
\57\ Bush DE, Ziegelstein RC, Patel UV, et al. Post-Myocardial
Infarction Depression. Rockville (MD): Agency for Healthcare
Research and Quality (US); 2005 May. (Evidence Reports/Technology
Assessments, No. 123.) Available from: https://www.ncbi.nlm.nih.gov/books/NBK37817/.
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By posting to the CMS Web site the lists of excluded services for
the EPMS, we believe we are providing the clarity and detail needed for
any provider to understand whether his or her services furnished to a
beneficiary in an EPM episode are included in the EPM episode
definition because they are related to the episode or excluded from the
EPM episode because they are unrelated. To date, we have applied the
same general approach to identifying exclusions in the BPCI initiative,
the CJR model, and the proposed EPMs, which should facilitate provider
understanding about exclusions under these different episode payment
models. We note, however, that the exclusion list differs based on the
clinical condition that is the focus of the episode so a provider that
is paid under Part B or a hospital would not be able to have a uniform
determination of whether services furnished were included or excluded
from an episode without knowledge of the beneficiary's specific episode
in an episode payment model as well as the clinical condition for which
the provider furnished services. All of the Innovation Center episode
payment models except Model 4 of BPCI use retrospective payment, so all
providers would be paid according to the usual fee-for-service systems
that apply, regardless of whether the items or services furnished by
the provider are included in or excluded from a beneficiary's episode.
Comment: While some commenters expressed full support for CMS'
proposed definition of related services, other commenters recommended
CMS to exclude specific additional groups of services from EPM
episodes. The commenters requested that CMS further exclude:
Readmissions that were already planned for the beneficiary
prior to the anchor hospitalization because their occurrence would be
unrelated to episode care;
Readmissions that were part of the planned post-discharge
care for the beneficiary after the anchor hospitalization, because
these provide no opportunity for efficiency yet could lead to high-cost
episodes:
Medical readmissions for unrelated acute and chronic
conditions;
Part B services that are not directly related to the
episode;
Cardiac rehabilitation, intensive cardiac rehabilitation,
and chronic care management services where appropriate utilization
under the EPMs in the context of historical low utilization would lead
to increased episode costs during the EPM performance period;
Behavioral and substance abuse services because these are
not always integral or of strong relevance to the clinical definitions
of the EPMs, and CMS does not provide claims data to model participants
for these services so no participants can predict, model, or calculate
episode spending; and
Outpatient chemotherapy, psychiatric readmissions, and
high cost intravenous therapy administered through DME that are
unrelated to the episode and could lead to increased episode costs.
Response: We believe that it is not necessary to exclude from EPM
episodes planned readmissions and outpatient services, regardless of
whether those plans were made prior to the anchor hospitalization or
during the anchor hospitalization but prior to discharge, solely
because the readmissions or outpatient services are planned in advance.
While we understand that certain other CMS programs account differently
for planned readmissions by excluding them from readmission
calculations, such as the HRRP which reduces payments to hospitals with
excess readmissions, we do not believe that planned readmissions should
be
[[Page 255]]
excluded from EPM episodes, where the goals of the EPMs are to improve
the quality and efficiency of episode care and where we do not make a
specific assessment about excess readmissions. Just like unplanned
readmissions, we believe that planned readmissions should be excluded
from EPM episodes only if they are unrelated to the EPM episodes based
on the proposed standards for exclusion of inpatient readmissions that
group to the following categories of diagnoses: Oncology; trauma
medical; chronic disease surgical unrelated to a condition likely to
have been affected by care during the EPM episode; and acute disease
surgical unrelated to a condition resulting from or likely to have been
affected by care during the EPM episode. We continue to believe these
standards are appropriate to identify excluded readmissions from EPM
episodes given our design of the EPMs to test comprehensive,
coordinated patient-centered care for the beneficiary throughout
broadly defined EPM episodes. Unless a readmission is excluded from the
EPM episode based on these standards, any readmission, whether planned
or unplanned, would be related to the EPM episode and be affected by
the clinical condition that is the basis for that episode. We
appreciate the concerns of the commenters about ensuring appropriate
EPM episode prices in the case of planned readmissions. While we are
not adopting any specific methodologies for identifying and making
episode payment adjustments for such planned, related readmissions now
except in the case of a CABG readmission during an AMI episode as
discussed in section III.D.4.b.(2)(c), we will study this issue in more
detail especially as it relates to the cardiac models. Should we
determine a change to our policies regarding planned, related
readmission could be appropriate, we will make proposals through future
rulemaking.
To the extent that planned readmissions reflect certain clinically
appropriate care patterns for beneficiaries in EPM episodes based on
plans made during the anchor hospitalization, we expect that such
readmissions would be included in the historical EPM episodes used to
establish EPM-episode payments and thus hospitals would be
appropriately paid, on average, for EPM episode care. To the extent
that efficiencies in EPM episode care are possible and medically
appropriate, reducing planned readmissions may provide an opportunity
for increased EPM episode efficiencies. However, we would not expect
EPM participants to reduce EPM-episode spending by shifting the
utilization of medically necessary services, such as planned
readmissions, until after the EPM episode ends. We refer to section
III.D.4.b.(2)(c) of this final rule for discussion of the pricing
adjustment for CABG readmissions during AMI episodes due to this
costly, clinically-appropriate care pattern of delayed CABG for some
beneficiaries with AMI.
Furthermore, while we expect that certain elective admissions
considered related under the EPMs may be planned prior to the anchor
hospitalization for the EPM episode and could, therefore, occur during
the 90-day post-discharge period, we believe that such actual
readmissions after CABG, SHFFT or AMI treatment are uncommon during the
post-surgical recovery or post-AMI recovery period for EPM
beneficiaries that extends 90 days following discharge from the anchor
hospitalization. If such readmissions were planned, they would often be
canceled due to the intervening surgery or AMI until the beneficiary
has fully recovered. We will not exclude them all as unrelated because
any readmission not on the EPM exclusion list may be related care
furnished during the post-surgical or post-AMI recovery period. Our
exclusion methodology does not allow us to identify those readmissions
that are truly elective; that is, the condition was present and the
readmission was planned prior to the hospitalization that anchored the
EPM episode and scheduled during the 90-day post-hospital discharge
period.
For readmissions to medical MS-DRGs, the selection of the principal
diagnosis code is not clear-cut so we believe they should all be
included in the EPM episode definition so providers focus on
comprehensive care to beneficiaries in episodes. We believe that
readmissions to medical MS-DRGs are generally linked to the
hospitalization or event as a complication of the illness that led to
the procedure or event, a complication of treatment or interactions
with the health care system, or a chronic illness that may have been
affected by the course of care. Therefore, we believe it is infeasible
under the EPMs to identify medical readmissions for unrelated acute and
chronic medical conditions, other than our proposal to exclude
readmissions for oncology and trauma medical diagnoses.
Similarly, our proposal identified those Part B services unrelated
to the episode as acute disease diagnoses unrelated to a condition
resulting from or likely to have been affected by care during the EPM
episode and certain chronic disease diagnoses depending on whether the
condition was likely to have been affected by care during the EPM
episode or whether substantial services were likely to be provided for
the chronic condition during the EPM episode. We do not believe that
requiring a direct relationship between the diagnosis for the Part B
services and the clinical condition that is the basis for the EPM
episode is appropriate under the broadly defined episodes of the EPMs.
Most medical conditions are likely to be affected by care during the
EPM episode, yet they may not have a direct relationship to the
clinical condition that is the reason for the anchor hospitalization.
We also do not believe that it would be appropriate to exclude
other specific Part B services that are related to the clinical
conditions that are the basis for EPM episodes, such as cardiac
rehabilitation, intensive cardiac rehabilitation, and chronic care
management services, just because they are underrepresented in the
baseline period upon which benchmark episode prices are set. As
discussed in section III.D.4.b.(3) of this final rule, to the extent
that care redesign under the EPMs increases utilization of these
services to improve episode quality and efficiency, periodic updates to
the 3 years of historical data used to establish EPM-episode benchmark
prices would result in greater representation of these services that
reflect more recent care patterns.
Additionally, we do not believe that it would be appropriate to
exclude behavioral health and substance abuse services, including
psychiatric readmissions, from EPM episodes because these services are
for conditions that are likely to affect EPM episode care. We note that
these services are not common in episodes and, while we acknowledge
that the episode claims data provided to EPM participants will not
include these data, our proposal to exclude this information but
include the costs of the services in EPM episodes is consistent with
our usual treatment of these services in other similar CMS programs and
models where providers must take on risk in managing the care of their
beneficiaries, such as the Shared Savings Program and BPCI initiative.
Based on our experience to date with bundled payment models and the
Shared Savings Program, this policy has not been a significant
impediment to the operations of these efforts. For example, in the most
recent episodes in BPCI Models 2 and 3, the claims for behavioral
health and substance abuse services included in episodes that we
[[Page 256]]
did not share with BPCI participants accounted for less than 0.1
percent of total episode spending. We refer to section III.K. of this
final rule for further discussion of issues related to sharing
beneficiary-identifiable data for behavioral health and substance abuse
services with EPM participants.
With regard to the commenters requesting that we exclude outpatient
chemotherapy services from the EPM episode definitions, we agree that
these should be excluded from EPM episodes in accordance with our
proposal that excludes services based on ICD-9-CM and ICD-10-CM cancer
diagnosis codes on the proposed EPM exclusion lists from historical and
actual EPM episodes. In the case of high-cost intravenous therapy
administered through DME, we would only exclude such treatments if the
claims reported ICD-10-CM diagnosis codes that would identify these
services as unrelated to the EPM episodes. Otherwise, despite the cost
of this therapy, these services would be included in EPM episodes
because they are related.
Comment: Several commenters recommended CMS to exclude readmissions
for PCI from AMI episodes, stating that current STEMI clinical
guidelines for the culprit artery lesion in addition to other multi-
vessel stenosis states, ``Approximately 50% of patients with STEMI have
multivessel disease. PCI options for patients with STEMI and
multivessel disease include: (1) Culprit artery-only primary PCI, with
PCI of non-culprit arteries only for spontaneous ischemia or
intermediate or high-risk findings on pre-discharge noninvasive
testing; (2) multi-vessel PCI at the time of primary PCI; or (3)
culprit artery-only primary PCI followed by staged PCI of non-culprit
arteries.'' \58\ Another commenter quoted on the topic from the most
recent update to the guidelines published in 2016, ``Although several
observational studies and a network meta-analysis have suggested that
multivessel staged PCI may be associated with better outcome than
multivessel primary PCI, there are insufficient observational data and
no randomized data at this time to inform a recommendation with regard
to the optimal timing of nonculprit vessel PCI.''
---------------------------------------------------------------------------
\58\ Levine GN, Bates ER, Blankenship JC, et al. 2015 ACC/AHA/
SCAI Focused Update on Primary Percutaneous Coronary Intervention
for Patients With ST-Elevation Myocardial Infarction: An Update of
the 2011 ACCF/AHA/SCAI Guideline for Percutaneous Coronary
Intervention and the 2013 ACCF/AHA Guideline for the Management of
ST-Elevation Myocardial Infarction. J Am Coll Cardiol.
2016;67(10):1235-1250. doi:10.1016/j.jacc.2015.10.005.
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The commenters recommended CMS to exclude planned readmissions for
PCI from the AMI episode definition because the AMI model as proposed
would discourage the recommended course of care of a secondary PCI
procedure for AMI patients with multivessel disease. The commenters
believe that the AMI episode definition could encourage the treatment
of secondary lesions during the initial angioplasty and in other cases
could provide an incentive to delay treatment of the secondary lesions
until after the 90-day post-hospital discharge duration of the AMI
episode has concluded. The commenters added that another strategy of
EPM participants to deal with limited AMI episode payments might be to
inappropriately refer multivessel disease patients into the separate
CABG model.
Alternatively if CMS does not excluded planned PCI readmissions,
the commenters recommended CMS to exclude STEMI beneficiaries with
multivessel disease from the AMI model and/or make accommodations in
the pricing methodology for the extra cost of treating such
beneficiaries appropriately. As another alternative, the commenters
requested that CMS shorten the AMI episode duration to 30 days post-
discharge so that secondary PCI could be performed for multivessel
disease without the financial constraints of an ongoing AMI episode.
Finally, the commenters recommended that if the AMI episodes cannot be
revised to avoid these potentially harmful incentives, CMS should
monitor and evaluate whether these shifts in pattern of care are
occurring and whether they have affected patient outcomes.
Response: While we appreciate the concerns of the commenters, as we
stated in the proposed rule (81 FR 50852), fewer than 3 percent of
those AMI model beneficiaries who receive inpatient or outpatient PCIs
during AMI episodes receive the PCIs between 2 and 90 days post-
discharge from an anchor or chained anchor hospitalization. Since a PCI
for an AMI typically is provided during the anchor hospitalization and
most PCIs later in an episode occur in the context of a beneficiary
presenting through the emergency department, we believe that in most
cases of PCI following discharge from the anchor hospitalization, the
beneficiary likely has experienced a complication of care resulting in
a PCI that may potentially be avoided through care management during
the AMI episode. This PCI would clearly be related to the AMI episode
and should not be excluded from the AMI episode.
It would also be inappropriate to exclude beneficiaries with STEMI
and multivessel disease from the AMI model simply because their plan of
care could include a secondary PCI procedure as these beneficiaries
would represent nearly 50 percent of STEMI patients, who themselves
make up a significant percent of beneficiaries in the AMI model. While
we expect that few beneficiaries would follow this care pattern based
on our analysis of historical AMI episodes, in this scenario the PCI
would clearly be related to the AMI and, therefore, be appropriately
included in the AMI episode definition. Given that our intention is to
offer appropriate incentives for care quality and efficiency by holding
AMI model participants accountable for readmissions that could be
related to the quality of care provided prior to the readmission, we
believe that a pricing adjustment for a PCI readmission or outpatient
PCI would not be appropriate.
We note that the recently updated treatment guidelines cited by the
commenters state there is insufficient observation data and no
randomized data to inform a recommendation regarding the optimal timing
of non-culprit vessel PCI. The guidelines contain no specific
recommendation for the timing of delayed treatment of secondary
lesions, while specifically stating that the ``recommendation with
regard to multivessel primary PCI in hemodynamically stable patients
with STEMI has been upgraded and modified . . . to include
consideration of multivessel PCI, either at the time of primary PCI or
as a planned, staged procedure.'' Given that there is no specific
recommendation regarding the routine performance of multivessel PCI for
patients with STEMI and multivessel disease, nor a recommendation on
the timing for multivessel PCI if it is performed, we do not believe
the AMI model definition discourages patterns of care that are
recommended for AMI patients with multivessel disease. We also do not
see any reason why the care patterns related to performing PCI for
multivessel disease following STEMI should lead us to shorten the AMI
episode duration from 90 days post-discharge to 30 days or to make a
pricing adjustment for AMI episodes that include this pattern of care.
We refer to section III.C.4.c.(2) of this final rule for further
discussion of the AMI episode duration.
As recommended by the commenters, we will evaluate care patterns
under the AMI model for secondary PCI following an initial PCI for
treatment of AMI to determine whether shifts in care are
[[Page 257]]
occurring and whether changes in beneficiary outcomes are observed. We
refer to section IV. of this final rule for further discussion of our
plans for evaluation of the AMI model.
Comment: One commenter requested confirmation of their
understanding of CMS' proposal to exclude MS-DRGs for inpatient
hospital readmissions that group to the ``Trauma medical'' category of
diagnoses. The commenter interpreted this provision as trauma diagnoses
unrelated to the initial MS-DRG triggering an episode.
Response: By trauma medical diagnoses, we mean that those MS-DRGs
that represent a readmission for medical treatment of trauma during an
EPM episode are excluded. For example, we would exclude MS-DRGs 082-087
in the Traumatic Stupor & Coma series and MS-DRGs 088-090 in the
Concussion series.
Comment: Several commenters recommended CMS to exclude hospice
services from the EPM episode definition as they generally would be
unrelated to the EPM episodes. The commenters stated that including
hospice services in EPM episodes could result in incentives for
underutilization of the hospice benefit. They encouraged CMS to exclude
all hospice services in order to ensure timely access to hospice for
EPM beneficiaries. One commenter pointed out that exclusion of hospice
services from the EPM episode definitions would be consistent with
their exclusion from BPCI episodes.
Response: We appreciate the interest of the commenters in ensuring
continued beneficiary access to hospice services under the EPMs. We
note that although we exclude hospice services from BPCI episodes, we
include them in LEJR episodes in the CJR model (80 FR 73307). We
understand that EPM beneficiaries could receive hospice services during
an episode under several different types of clinical circumstances. For
example, the beneficiary could be enrolled in hospice prior to a SHFFT
episode, experience a pathologic hip fracture, and require a SHFFT
procedure to stabilize his or her hip. Alternatively, the beneficiary
could have a CABG and enter into hospice at some point during the
episode in the 90 days following discharge from the anchor
hospitalization, either after experiencing a surgical complication
leading to a terminal prognosis, progressive severe heart failure
despite the CABG, or based on a new diagnosis of a terminal stage of an
illness.
As we explained in the CJR Final Rule (80 FR 73307), Medicare
hospice care is palliative care for individuals with a prognosis of
living 6 months or less if the terminal illness runs its normal course.
As referenced in Sec. 418.22(b)(1), to be eligible for Medicare
hospice services, the patient's attending physician (if any) and the
hospice medical director must certify that the individual is
``terminally ill,'' as defined in section 1861(dd)(3)(A) of the Act and
our regulations at Sec. 418.3; that is, the individual's prognosis is
for a life expectancy of 6 months or less if the terminal illness runs
its normal course. When an individual is terminally ill, many health
problems are brought on by underlying condition(s), as bodily systems
are interdependent. Section 1861(dd)(1) of the Act establishes the
services that are to be rendered by a Medicare certified hospice
program and those services include: Nursing care; physical therapy;
occupational therapy; speech-language pathology therapy; medical social
services; home health aide services (now called hospice aide services);
physician services; homemaker services; medical supplies (including
drugs and biologics); medical appliances; counseling services
(including dietary counseling); short-term inpatient care (including
both respite care and care necessary for pain control and acute or
chronic symptom management) in a hospital, nursing facility, or hospice
inpatient facility; continuous home care during periods of crisis and
only as necessary to maintain the terminally ill individual at home;
and any other item or service which is specified in the plan of care
and for which payment may otherwise be made under Medicare, in
accordance with Title XVIII of the Act. The services offered under the
Medicare hospice benefit must be available, as needed, to beneficiaries
24 hours a day, 7 days a week (section 1861(dd)(2)(A)(i)of the Act).
The regulations at Sec. 418.54(c) stipulate that the comprehensive
hospice assessment must identify the patient's physical, psychosocial,
emotional, and spiritual needs related to the terminal illness and
related conditions, and address those needs in order to promote the
hospice patient's well-being, comfort, and dignity. The comprehensive
assessment must take into consideration the following factors: The
nature and condition causing admission (including the presence or lack
of objective data and subjective complaints); complications and risk
factors that affect care planning; functional status; imminence of
death; and severity of symptoms (Sec. 418.54(c)). Additionally, the
hospice Conditions of Participation (CoPs) at Sec. 418.56(c) require
that the hospice must provide all reasonable and necessary services for
the palliation and management of the terminal illness, related
conditions and interventions to manage pain and symptoms. Therapy and
interventions must be assessed and managed in terms of providing
palliation and comfort without undue symptom burden for the hospice
patient or family. In the December 16, 1983, Hospice final rule (48 FR
56010 through 56011), regarding what is related versus unrelated to the
terminal illness, we stated: ``We believe that the unique physical
condition of each terminally ill individual makes it necessary for
these decisions to be made on a case-by-case basis. It is our general
view that hospices are required to provide virtually all the care that
is needed by terminally ill patients.''
Thus, we believe that hospice services furnished to EPM
beneficiaries should be included in the episode definition for the
EPMs, regardless of the specific diagnosis of the beneficiary, because
hospices are to provide virtually all care that is needed by terminally
ill patients. This is consistent with our conclusion when we considered
hospice services in the LEJR episode definition under the CJR model (80
FR 73307). If an EPM beneficiary was receiving hospice services during
an episode, either because the beneficiary was enrolled in hospice
prior to surgery or a cardiac event and continued in hospice following
surgery or the cardiac event or the beneficiary enrolled in hospice
following the surgery or cardiac event that initiated the EPM episode,
we believe that hospice services would encompass care related to the
EPM episode and should, therefore, be included in the episode
definition. As previously noted, given the comprehensive nature of the
hospice benefit and the fact that body systems are interdependent at
end of life, virtually all care needed by the terminally-ill individual
would be related to the terminal prognosis and thus the responsibility
of the hospice.
As previously noted, hospices are required, per the Hospice CoPs at
Sec. 418.56(c), to provide all reasonable and necessary services for
the palliation and management of the terminal illness, related
conditions, and interventions to manage pain and symptoms. For patients
that underwent surgery or cardiac care under the EPMs that have also
elected the Medicare hospice benefit, hospice services would need to
respond to the care needs of the EPM beneficiary following surgery or
hospitalization for cardiac care. As in the case of other medically
necessary services that would improve a beneficiary's quality of care
and quality
[[Page 258]]
of life, we expect that EPM beneficiaries will receive clinically
appropriate referrals to hospice in a timely manner. Furthermore, we
also believe hospice services could contribute to episode efficiency
through improved comprehensive care coordination and management for EPM
beneficiaries that have a terminal prognosis. As previously stated,
hospices are required to provide comprehensive care coordination and
management per the hospice CoPs at 418.56. As discussed in sections
III.G.4. through 6. of this final rule, we will be monitoring for
access to care, quality of care, and delayed care and will take actions
as described if problems are found.
Comment: One commenter recommended that CMS exclude Inpatient
Psychiatric Facility (IPF) services from the EPM episode definition as
not being related to or resulting from the EPM clinical condition,
consistent with their treatment in BPCI episodes.
Response: We are clarifying that under the BPCI models, IPF
services furnished following discharge from the episode anchor
hospitalizations but during the episode are included in the episode
definition, unless they fall into one of the excluded MS-DRGs for the
episode. Thus, we include inpatient psychiatric services whether paid
under the IPPS or the IPF PPS in all episodes under the BPCI initiative
according to the same policy that would exclude readmissions paid under
either payment system based on the same exclusion list. As we concluded
for the CJR model (80 FR 73306), we see no reason for the EPMs not to
apply the standards we proposed to define related and unrelated Part A
and Part B services with respect to IPF services furnished during EPM
episodes. Therefore, we believe the list of excluded MS-DRGs applicable
to the EPM episode identifies those IPF admissions during the episode
that would be clinically unrelated to the episode so we exclude them
from the EPM episode definition, whereas IPF services any time during
an EPM episode that result in discharge from an MS-DRG that is not
excluded would be related and included in the EPM episode definition.
We disagree with the commenter that all IPF services furnished
following discharge from the anchor hospitalization that initiates the
EPM episode after surgery are unlikely to be related to or resulting
from the EPM clinical condition or its treatment. Thus, we believe the
MS-DRG exclusions for the EPM episodes identify those circumstances
when IPF services are unrelated to the episode.
Comment: Several commenters recommended that CMS exclude post-acute
care services from EPM episodes if the beneficiary chooses a facility
not recommended by the EPM participant or treating physician. Other
commenters recommended that CMS exclude post-acute care services
following excluded readmissions due to how little is known about the
causal relationship between an unrelated hospital readmission and
subsequent post-acute care services.
Response: As discussed in section III.G.2. of this final rule, the
proposed EPMs would not limit an EPM beneficiary's ability to choose
among Medicare providers or the range of services that would be
available to them. Beneficiaries would continue to choose any Medicare
participating provider, or any provider that has opted out of Medicare,
with the same costs, copayments, and responsibilities as they have with
other Medicare services. Therefore, it would not be appropriate to
exclude post-acute care services from the EPM episode definition if the
beneficiary chooses a post-acute care facility that is not recommended
by the EPM participant or the beneficiary's treating physician.
With regard to requests that we exclude post-acute services from
EPM episodes following excluded readmissions, as Part A services are
generally intended to be comprehensive in nature and because the
beneficiary in an EPM episode would still be in the recovery period for
the 90 days following surgery or an AMI, we believe any post-acute care
services provided during the EPM episode would be related to the SHFFT,
CABG, or AMI. Regardless of the reason for the hospitalization
immediately preceding the initiation of post-acute care services during
an EPM episode, the post-acute care provider would need to address the
beneficiary's post-surgical or post-AMI recovery, even if the post-
acute care services followed an unrelated admission to the hospital.
Comment: Several commenters identified additional MS-DRGs or
conditions resulting in hospitalization that they recommended be
excluded from the cardiac episodes. The commenters requested that
clinical conditions that group to the following MS-DRGs be excluded
from the AMI and CABG model episode definitions, generally on the basis
that these readmissions are not integral to the management of
beneficiaries in the 90 days following discharge from the AMI or CABG
anchor hospitalization:
222 (Cardiac Defibrillator Implant with Cardiac
Catheterization with AMI/HF/Shock with MCC).
223 (Cardiac Defibrillator Implant with Cardiac
Catheterization with AMI/HF/Shock without MCC).
224 (Cardiac Defibrillator Implant with Cardiac
Catheterization without AMI/HF/Shock with MCC).
225 (Cardiac Defibrillator Implant with Cardiac
Catheterization without AMI/HF/Shock without MCC).
226 (Cardiac Defibrillator Implant without Cardiac
Catheterization with MCC).
227 (Cardiac Defibrillator Implant without Cardiac
Catheterization without MCC).
266 (Endovascular Cardiac Replacement with MCC).
267 (Endovascular Cardiac Replacement without MCC).
273 (Percutaneous Intracardiac Procedures with MCC).
274 (Percutaneous Intracardiac Procedures without MCC).
Another commenter claimed that CMS' proposal to include nearly all
surgical MS-DRGs within Major Diagnostic Category (MDC) 5 (Diseases and
Disorders of the Circulatory System) in the AMI and CABG episode
definition, rather than also requiring an acute care ICD-CM diagnosis
code on the claim for the MS-DRG in MDC 5 to be included in the
episode, especially within the 31 to 90 days following discharge from
the anchor hospitalization, could penalize hospitals for providing
necessary care within the timeframe for AMI and CABG episodes. Examples
provided by the commenter included abdominal aortic aneurysm;
peripheral bypass surgical and endovascular procedures; surgical valve
repair or replacement; planned inpatient or outpatient
electrophysiology admissions to replace cardiac defibrillators or
pacemakers; and staged outpatient revascularization procedures several
months after an initial intervention for AMI.
One commenter recommended that readmissions for extracorporeal
membrane circulation (ECMO) that would group to MS-DRG 003 (ECMO or
Tracheostomy with MV > 96 hours or PDX Except Face, Mouth and Neck with
Major O.R. Procedure) be excluded from the CABG episode definition.
Another commenter recommended the addition of 241 MS-DRGs to CMS' the
readmissions exclusion list for CABG episodes, in addition to the 370
MS-DRGs proposed by CMS on the list, on the basis that these MS-DRGs
did not have any clinical relevance to CABG. These additional MS-DRGs
would result in the exclusion of 611 MS-DRGs out of a total of
approximately 760 MS-DRGs from CABG episodes.
[[Page 259]]
Finally, the commenter who favored CMS' adopting a more robust
methodology for differentiating planned from unplanned use of inpatient
and outpatient services within the 90-day post-discharge period,
similar to the methodology used in the HRRP for AMI and CABG, requested
that should CMS continue with the MS-DRG exclusion list that CMS
revisit the proposed exclusion lists for AMI and CABG episodes. The
commenter claimed there were some inconsistencies in the treatment of
AMI MS-DRG-anchored AMI episodes and CABG episodes compared with PCI
MS-DRG-anchored AMI episodes. The commenter identified MS-DRGs 326
(Stomach, Esophageal, and Duodenal Procedures with MCC); 327 (Stomach,
Esophageal, and Duodenal Procedures with CC); 328 (Stomach, Esophageal,
and Duodenal Procedures without CC/MCC); 266 (Endovascular Cardiac
Valve Replacement with MCC); and 267 (Endovascular Cardiac Valve
Replacement without MCC) as on the PCI MS-DRG-anchored AMI exclusion
list but not on the AMI MS-DRG-anchored AMI and CABG MS-DRG exclusion
list, and was unclear about the rationale for these differences.
Response: We appreciate the requests by the commenters to add
certain MS-DRGs to the exclusion list for one or both of the cardiac
care models. CMS clinicians and coding staff reviewed the three
different proposed exclusion lists for AMI MS-DRG-anchored AMI
episodes, PCI MS-DRG-anchored AMI episodes, and CABG episodes for the
inconsistencies identified by one of the commenters against the
proposed standards for excluding readmissions during EPM episodes. We
proposed to exclude MS-DRGs 326-328 from PCI-anchored AMI episodes and
CABG episodes but not from AMI MS-DRG-anchored episodes. Based on
clinical review, we determined that admissions to these MS-DRGs would
be for acute disease surgical diagnoses unrelated to a condition
resulting from or likely to have been affected by care during the AMI
or CABG episode so these MS-DRGs meet the proposed standards for
exclusion from AMI MS-DRG-anchored AMI episodes. Therefore, we are
adding MS-DRGs 326-328 to the AMI MS-DRG-anchored AMI exclusion list.
MS-DRGs 266-267 are on the exclusion list for PCI MS-DRG-anchored AMI
episodes, but not on the exclusion list for AMI MS-DRG-anchored AMI
episodes or CABG episodes. Based on clinical review, we determined that
admissions to these MS-DRGs would be for chronic disease surgical
diagnoses unrelated to a condition likely to have been affected by care
during the AMI or CABG episode so these MS-DRGs meet the proposed
standards for exclusion from both AMI MS-DRG-anchored AMI episodes and
CABG episodes. Therefore, we are adding MS-DRGs 266-267 to the AMI MS-
DRG-anchored AMI exclusion list and the CABG exclusion list.
We note that MS-DRGs 222-227 and 273-274 requested for exclusion
from AMI and CABG episodes by several commenters are surgical MS-DRGs
in MDC 5. As another commenter pointed out, some of these may represent
planned readmissions following discharge from the anchor
hospitalization during the 90-day post-discharge period. However, based
on our proposed readmission exclusion methodology that identifies
excluded MS-DRGs without examining the diagnosis coding on hospital
claims to determine the reason for the readmission, as discussed in our
response to comments earlier in this section, we will not exclude
planned readmissions from the AMI and CABG episode definitions. Thus,
we proposed that MS-DRGs 222 through 227 and 273 through 274 not be
excluded from AMI (regardless of PCI or AMI MS-DRG-anchor) and CABG
episodes, and we are continuing to include these MS-DRGs in those
episodes, as well as the other surgical MS-DRGs in MDC 5 that we did
not propose to exclude from all AMI and CABG episodes. Based on
clinical review, we determined that these readmissions for circulatory
system procedures are related services in AMI and CABG episodes, based
on our proposed standards for excluding surgical MS-DRGs from the EPMs:
Chronic disease surgical diagnoses unrelated to a condition likely to
have been affected by care during the EPM episode; and acute disease
surgical diagnoses unrelated to a condition resulting from or likely to
have been affected by care during the EPM episode. While some
commenters stated that these readmissions were not integral to AMI and
CABG episodes, that is not the standard we used for determining related
readmissions because we are adopting broad episode definitions for the
EPMs. While we are not adopting any specific methodologies for
identifying and making episode payment adjustments for such planned,
related readmissions now except in the case of a CABG readmission
during an AMI episode as discussed in section III.D.4.b.(2).(c). of
this final rule, we will study this issue in more detail especially as
it relates to the cardiac models. Should we determine a change to our
policies regarding planned, related readmission could be appropriate,
we will make proposals through future rulemaking.
Finally, we carried out a clinical review of the 241 MS-DRGs
recommended by a commenter for addition to the CABG exclusion list, as
well as MS-DRG 003 that was recommended for exclusion by another
commenter. About three-quarters of the MS-DRGs recommended for
exclusion were medical MS-DRGs that did not meet our proposed standards
for excluding readmissions based on medical diagnoses, specifically
oncology or trauma medical diagnoses. As we first discussed in the CJR
Final Rule (80 FR 73304) and in the EPM proposed rule (81 FR 50833), we
believe all other readmissions for medical MS-DRGs should be included
in EPM episodes because these are generally linked to the condition
that was the focus of the anchor hospitalization as a complication of
that illness, a complication of treatment or interactions with the
health care system, or a chronic illness that may have been affected by
the course of episode care. The inclusion of most MS-DRGs in EPM
episodes should encourage providers to focus on comprehensive care for
beneficiaries during episodes. More than half of the surgical MS-DRGs
recommended for CABG episode exclusion were in MDC 5 and, with the
exception of MS-DRGs 266-267 discussed previously, we will not exclude
them from CABG episodes based on the reasons discussed earlier in this
response. Of the remaining surgical MS-DRGs spread across 7 MDCs
representing different body systems, we will also not exclude any of
these MS-DRGs because they do not meet our standards for excluding MS-
DRGs from CABG episodes, namely that the readmissions are for chronic
disease surgical diagnoses unrelated to a condition likely to have been
affected by care during the CABG episode or acute disease surgical
diagnoses unrelated to a condition resulting from or likely to have
been affected by care during the CABG episode. We believe that our
determinations may be different than the commenters' recommendations
because our standard for exclusion in broadly defined CABG episodes is
much more stringent than the commenters' review of MS-DRGs based on
their clinical relevance to CABG.
Comment: Several commenters requested that CMS add MS-DRGs 469 and
470 for major joint replacement of the lower extremity to the exclusion
list for SHFFT episodes, unless the joint replacement was for the joint
that
[[Page 260]]
underwent a SHFFT procedure that initiated the SHFFT episode. The
application of the exclusion in this way would exclude elective LEJR
readmissions from SHFFT episodes. The commenters claimed this approach
would avoid outliers and penalizing the orthopedic surgeon for
identification and treatment of unmet medical needs while treating a
beneficiary following a hip fracture. One commenter stated that these
circumstances would be highly variable, particularly in hospitals with
small patient volume. They recommended excluding MS-DRGs 469 and 470
from SHFFT episodes so as not to penalize low-volume hospitals who
performed costly elective LEJR during SHFFT episodes on an occasional
basis.
Response: Based on our proposed methodology to identify excluded
readmissions by a list of MS-DRGs, we would have to substantially
increase the complexity of our exclusions methodology to identify only
a subset of MS-DRG 469 and 470 readmissions for exclusion because they
were not related to the joint surgery that initiated the SHFFT episode.
We do not believe this additional complexity is necessary because we
expect that LEJR replacement of another joint, whether elective or for
fracture, would be rare during SHFFT episodes. Most LEJR is elective,
rather than for fracture, and given the prolonged partial weight-
bearing commonly required for recovery from SHFFT procedures and the
general complexity and frailty of many beneficiaries who would be
included in SHFFT episodes, we believe that elective LEJR of a joint
other than that involved in the initial SHFFT surgery during the 90
days post-discharge from the SHFFT model anchor hospitalization would
be exceedingly rare. We would expect that most LEJR procedures during
SHFFT episodes would be related because they would involve the joint
that had an initial SHFFT procedure.
Comment: One commenter recommended that CMS exclude Part B services
from CABG episodes based on individual ICD-9-CM and ICD-10-CM diagnosis
codes, rather than categories as CMS proposed. The commenter claimed
that CMS' proposed process would result in over 22,000 ICD-10-CM
diagnosis codes that would be classified as included in the CABG
episode, thereby resulting in those services being considered as
related items and services. The commenter believes that this
methodology would result in many of the included services having no
clinical relevance to a CABG. The commenter recommended CMS to specify
Part B episode exclusions at the ICD-CM code level to ensure that only
services that are clinically related to a CABG are included in the
episode. The commenter recommended 4,960 specific ICD-9-CM and 18,859
specific ICD-10-CM diagnosis codes be added to the CABG exclusion list.
Another commenter recommended that CMS exclude the following ICD-
10-CM diagnosis code categories from AMI episodes as they are not
integral to AMI treatment: I47 (Paroxysmal tachycardia); I48 (Atrial
fibrillation and flutter); and I49 (Other cardiac arrhythmias). The
same commenter recommended that CMS exclude ICD-9-CM diagnosis code
category 427 (Cardiac dysrhythmias) from AMI episodes.
Response: We appreciate the recommendations from the commenter
about additional ICD-9-CM and ICD-10-CM diagnosis code categories to be
excluded from AMI episodes. However, with respect to their requested
additions to the AMI Part B exclusion list, we believe the four
categories of ICD-CM codes recommended for exclusion do not meet our
proposed Part B exclusions standards, specifically those services that
are for acute disease diagnoses unrelated to a condition resulting from
or likely to have been affected by care during the EPM episode or for
certain chronic disease diagnoses, depending on whether the condition
was likely to have been affected by care during the EPM episode or
whether substantial services were likely to be provided for the chronic
condition during the EPM episode. The ICD-CM diagnosis code categories
describe different types of cardiac arrhythmias, which can result from
an AMI, where the arrhythmia would be an acute condition related to the
AMI episode, or can be a chronic condition where the management of the
arrhythmia would be affected by the AMI treatment. Thus, we do not
agree with the commenter that these ICD-CM diagnosis code categories
should be excluded from AMI episodes.
With respect to CABG episodes, another commenter recommended almost
19,000 ICD-10-CM diagnosis codes be added to the CABG exclusion list.
The commenter submitted individual codes in 750 ICD-10-CM categories
for exclusion, of which there were 563 categories (75%) in which they
requested excluding all codes. We note that there are about 71,000
billable ICD-10-CM codes in 1,910 categories, compared to about 15,000
ICD-9-CM codes in 1,042 categories. Due to the large number of
diagnosis codes, we believe it would be operationally infeasible and
unnecessarily complex to determine excluded Part B services at the
individual diagnosis code level. We further believe that the ICD-CM
diagnosis code categories are sufficiently narrow and descriptive that
they can be appropriately used to determine Part B exclusions without
substantial risk of misidentifying services that are unrelated to CABG
episodes according to our proposed Part B exclusions standards. We have
several years of experience with 48 different BPCI clinical episodes in
Model 2, including CABG, which has a similar design to the proposed
CABG model. We have encountered no significant concerns from BPCI
Awardees or other stakeholders about our BPCI methodology which
excludes Part B services based on ICD-CM diagnosis code categories,
just as we use in the CJR model and proposed for the CABG model.
Therefore, we are continuing to consider changes to the Part B
exclusion list for the EPMs based on ICD-CM categories.
We did not perform another clinical review of the 187 categories
where the commenter only requested that we exclude some of the
individual ICD-10-CM diagnosis codes in the category, because we will
continue to exclude ICD-10-CM codes at the category level. CMS
clinicians and coding staff reviewed all of the 563 ICD-10-CM diagnosis
code categories where the commenter recommended that we exclude all the
diagnosis codes in order to make a determination about additional
exclusions at the category level. While the commenters claimed that
diagnosis codes in these categories had no clinical relevance to CABG,
we do not agree that the additional categories where the commenter
recommended 100 percent of the ICD-10-CM diagnosis codes for exclusion
meet our proposed standards for exclusion. For example, the commenter
requested that we exclude the categories K20 (Esophagitis) and I12
(Hypertensive chronic kidney disease) for Part B services from the CABG
model episode definition. However, these two ICD-10-CM diagnosis code
categories do not meet our proposed standards for the exclusion of Part
B services because they include acute disease diagnoses for a condition
arising from or likely to have been affected by care during the CABG
episode in the case of Esophagitis and chronic disease diagnoses likely
to have been affected by care during the CABG episode in the case of
Hypertensive chronic kidney disease. The commenter's recommendations
were prepared based on a standard of ``clinical relevance'' to CABG
which we believe is too narrow to define related
[[Page 261]]
Part B services for the proposed CABG model which was designed to test
comprehensive, coordinated patient-centered care for the beneficiary
throughout broadly defined EPM episodes. In our clinical review based
on the proposed standards for Part B exclusions, we determined that the
563 ICD-10-CM diagnosis code categories where the commenter recommended
that we exclude 100 percent of the diagnosis codes do not meet the
standards for exclusion from CABG episodes. Therefore, we are making no
changes to the CABG episode ICD-10-CM Part B exclusion list.
The same commenter who made recommendations about additional ICD-
10-CM diagnosis code exclusions also recommended ICD-9-CM diagnosis
codes in 436 ICD-9-CM categories for exclusion, and of those, the
commenter recommended that all codes be excluded in 336 (77 percent) of
the categories. We did not perform an additional clinical review of the
categories where the commenter only requested that we exclude some of
the individual ICD-9-CM diagnosis codes in the category, as we will
continue to exclude ICD-9-CM codes at the category level. CMS
clinicians and coding staff reviewed all of the 100 ICD-9-CM diagnosis
categories where the commenter recommended that we exclude all the
diagnosis codes in order to make a determination about additional
exclusions at the category level. Similar to our findings from our
review of the ICD-10-CM diagnosis code categories where all codes were
recommended for exclusion, the ICD-9-CM categories with all codes
recommended by the commenter for CABG episode exclusion do not meet our
proposed exclusion standards for Part B services. For example, the
commenter recommended that we exclude all codes in ICD-9-CM diagnosis
code category 584 (Acute kidney failure) and 250 (Diabetes mellitus)
from CABG episodes. However, these two ICD-9-CM diagnosis code
categories do not meet our proposed standards for the exclusion of Part
B services because they include acute disease diagnoses for a condition
arising from or likely to have been affected by care during the CABG
episode in the case of Acute kidney failure and chronic disease
diagnoses likely to have been affected by care during the CABG episode
in the case of Diabetes mellitus. In our clinical review, we found that
none of the 100 ICD-9-CM categories where the commenter recommended
that we exclude 100 percent of the diagnosis codes meet our proposed
standards for excluding Part B services from CABG episodes, so we are
making no changes to the CABG episode ICD-9-CM Part B exclusion list.
Comment: One commenter stated that their understanding was that
emergency transportation of beneficiaries with AMI would be included in
AMI episodes. The commenter pointed out that this cost could vary
substantially based on the transport mileage and the mode of transport,
with air transport being substantially more costly than ground
transport. The commenter claimed that the EPM participant where the
episode would be initiated has little or no input on the transport
method used but would be held accountable for the transportation cost
in the AMI episode. The commenter requested that transport of the
beneficiary to the AMI model participant where the AMI episode is
initiated be excluded because the AMI model participant would have
little or no control of that cost.
Response: We proposed to include all Part A and Part B items and
services in AMI episodes beginning with the admission of the
beneficiary for the anchor hospitalization and extending through anchor
hospitalization discharge, whereupon the AMI model exclusion list would
be applied to Part A and Part B items and services during the 90 days
post-discharge to make a determination about their inclusion in the AMI
episode definition. With respect to the inclusion of Part B ambulance
claims for air or ground transport in the AMI episode definition, we
would exclude those services that occurred prior to the hospital
admission. If the ambulance transport occurs on the day of initial
admission for the anchor hospitalization and has place-of-service code
for ambulance on the claim, the claim would not be included in the AMI
episode definition, an approach which would be consistent with the
specific request of the commenter.
However, if ambulance transport occurs any other time during the
anchor hospitalization, the transportation would be included in the AMI
episode definition as we include all Part B services without regard to
the Part B exclusion list, except DME to which we apply the Part B
exclusion list during the anchor hospitalization as well. Following
discharge from the anchor hospitalization, the inclusion or exclusion
of ambulance transport in the AMI episode during the 90 day post-
discharge would be determined by our proposed methodology for
determining exclusion of any Part B items and services based on the
principal diagnosis code on the claim and whether that diagnosis code
is on the AMI model exclusion list.
We note that medically appropriate air ambulance transportation is
a Medicare-covered service regardless of the state or region in which
it is rendered. However, contractors approve claims only if the
beneficiary's medical condition is such that transportation by either
basic or advanced life support ground ambulance is not appropriate.
Medical reasonableness is only established when the beneficiary's
condition is such that the time needed to transport a beneficiary by
ground, or the instability of transportation by ground, poses a threat
to the beneficiary's survival or seriously endangers the beneficiary's
health.\59\ Thus, the circumstances of covered air transport are
limited and, once the AMI episode is initiated, the AMI model
participant would have an ongoing role in beneficiary care that would
result in the participant's input into the mode of transport should
transport be required.
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\59\ Medicare Benefit Policy Manual, Chapter 10--Ambulance
Services, 10.4 and 10.4.2.
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Comment: One commenter recommended that CMS include the costs of
pre-operative home visits in EPM episodes, including services to
discuss goals of care and advance care planning services. Another
commenter requested that CMS account for preventive services in the
EPMs, although they acknowledged the associated challenges in
benchmarking target prices based on historical claims data. One
commenter suggested that CMS include the proposed HCPCS G-codes for the
Collaborative Care model such that screening and follow-up would be
included in the payment structure for each EPM, while another commenter
recommended CMS to make resources for care coordination strategies
available to support advancing care coordination through appropriate
pre-discharge planning and post-discharge follow up. The commenter
observed that the majority of opportunities to advance care
coordination and improve patient outcomes are in decreasing hospital
length of stay to only what is necessary for appropriate treatment,
preventing unnecessary readmissions, and controlling post-acute care
costs. The commenter stated that opportunities to improve care
coordination include strong pre-discharge planning activities;
prevention of unnecessary patient visits to the emergency department
through early recognition of decompensation; increasing appropriate
referral to cardiac rehabilitation services; and
[[Page 262]]
effective patient and family education. The commenter claimed that
ensuring the social and environmental components are in place prior to
discharge is critical and that communication of the most appropriate
post-acute care facilities to not only the patients, but to their
families and caregivers, can be essential to a patient's recovery.
Response: The only items and services that are included in EPM
episode definitions are those that are separately paid by Medicare
under Part A or Part B. We established EPM episode definitions in order
to add Medicare payments for items and services included in the EPM
episode definitions into EPM-episode benchmark prices based on
historical EPM episodes and into the calculation of actual EPM-episode
spending. In addition, we proposed that EPM episodes begin with the
anchor hospitalization. Therefore, for the same reasons as discussed in
the CJR Final Rule (81 FR 73316 through 73317) regarding LEJR episodes,
we would not include any pre-operative home visits that could be
separately paid by Medicare in the EPM episode definitions because they
would precede the initiation of the episode which begins with admission
to the hospital and discharge from an MS-DRG that is included in the
EPM.
In terms of including preventive services and potential new HCPCS
G-codes for Part B services in the Collaborative Care model in the EPM
episode definitions, we note that according to our standard methodology
for identifying excluded Part B services under the EPMs, specific Part
B services would be included in both historical EPM episodes and actual
EPM episodes to the extent that the ICD-9-CM or ICD-10-CM diagnosis
code on the claim for the preventive service or HCPCS G-code for Part B
services in the Collaborative Care model is related to the EPM episode
and, therefore, not on the EPM episode exclusion list. With regard to
CMS making specific financial resources available to EPM participants
for pre-discharge planning, post-discharge follow-up, or other care
coordination activities, EPM participants would need to develop their
own strategies and use their own resources for these activities, as
well as engage with EPM collaborators, to redesign care to achieve good
quality and cost performance under the EPMs. CMS will not provide
additional payments under the EPMs specifically for these types of
planning and follow-up activities. However, EPM participants who
achieve acceptable episode quality or better and reduce actual EPM-
episode spending below the quality-adjusted price are eligible for
payment of the difference through a reconciliation payment, which can
support the resources used by EPM participants and collaborators in
redesigning care to achieve model success.
Comment: Several commenters commended CMS for proposing to exclude
IPPS new technology add-on payments for drugs, technologies, and
services from EPM episodes, as well as OPPS transitional pass-through
payments for medical devices. They believe that these proposals would
ensure EPM beneficiaries/access to valuable new drugs, technologies,
services, and devices. The commenters recommended CMS to go further and
exclude additional innovative technologies from EPM episodes by
establishing a review process to determine whether their costs should
be excluded from EPM-episode benchmark prices and actual EPM-episode
spending. The commenters reasoned that this new review process would
allow manufacturers to identify high-cost breakthrough technologies and
treatments that offer clinical improvements for all or certain types of
patients or offer significant therapeutic advances for new populations
or conditions. The commenters recommended that CMS utilize the same
processes as those used to determine eligibility for IPPS new
technology add-on payments but without regard to the statutory or
regulatory policies that apply only to new technology approvals. They
further suggested that CMS also allow individual EPM participants to
request an EPM payment adjustment if they adopt breakthrough treatment
in advance of other hospitals, as well as manufacturers and developers
to request the adjustment.
One commenter recommended CMS to consider other innovative capital
investments for an EPM episode payment adjustment and to provide
payment for new technologies at 100 percent of their cost, not 50
percent as under current CMS programs for payment of new technologies.
Finally, another commenter suggested that CMS should provide a
financial incentive to EPM participants to use technologies that are
shown to improve patient outcomes and reduce cost within 12 to 24
months.
Response: We appreciate the support of the commenters for our
proposals regarding the exclusion of new technology payments from EPM
episodes and agree that EPM beneficiaries should have access to
beneficial new technologies while they are in EPM episodes. We do not
believe it would be appropriate for the EPMs to potentially hamper
beneficiaries' access to new technologies that are receiving IPPS new
technology add-on payments or OPPS transitional pass-through payments
or to burden EPM participants who choose to use these new drugs,
technologies, services, or devices with concerns about these payments
counting toward actual EPM-episode spending.
However, for the same reasons that were discussed previously in the
CJR Final Rule (80 FR 73308) regarding LEJR episodes, we will not
establish a new process to review innovative technologies or different
technologies that would be ineligible for a payment adjustment under
the Medicare program and make individual determinations regarding their
exclusion from the EPM episode definitions, as recommended by some
commenters. Because the EPMs are retrospective reconciliation models
that pay all providers and suppliers under the regular Medicare program
throughout the episode of care, we believe it is more appropriate to
rely on the existing processes under the Medicare program to make
determinations about separate payment for new technology items and
services. If those existing processes identify new technologies that
would qualify for add-on payments under the IPPS or transitional pass-
through payments under the OPPS, we will exclude them from the EPM
episode definitions as we proposed, to ensure that beneficiaries'
access to new technology items and services is not influenced by their
care being included in the EPMs. Similarly, under these retrospective
EPMs, we will not provide additional payments for new technologies
beyond those that are paid under the Medicare program.
Finally, we do not believe it would be appropriate under the EPMs
to provide financial incentives to EPM participants to use specific
technologies that improve beneficiary outcomes and reduce cost over any
specific period of time. We understand that because the EPMs would
extend 90 days post-discharge from the anchor hospitalization, the EPMs
specifically incentivize the use of technologies and provision of
services that improve quality and reduce cost within the limited
episode timeframe for which the EPM participant is responsible for
episode quality and cost performance. However, we believe that EPM
participants, treating physicians, and other EPM collaborators are best
positioned to select technologies and furnish services that improve the
quality of care and reduce cost for EPM beneficiaries and expect that
their
[[Page 263]]
decisions factor in the long-term interests of beneficiaries as well.
Comment: One commenter stated that there was significant evidence
demonstrating that the use of more expensive drug-eluting stents (DES)
results in better long-term outcomes in many patients and fewer repeat
procedures for in-stent restenosis. The commenter added that long-term
benefit for patients (avoiding the risk, inconvenience and cost of
secondary procedures) and to Medicare (via fewer repeat procedures in
the long term) would not be fully captured in an episode extending 90
days post hospital discharge, but the full additional costs of DESs
would be. The commenter recommended CMS take steps to ensure that the
financial models used for the EPMs do not discourage the appropriate
use of DES. The commenter claimed that if the AMI model results in
fewer beneficiaries receiving DES, long-term outcomes may deteriorate
and overall costs may grow.
Response: As discussed in section III.C.4.a.(2) of this final rule,
we would initiate AMI episodes from PCI MS-DRGs (246-251) with an AMI
ICD-CM diagnosis code in the principal or a secondary position on the
claim for the anchor hospitalization. Medicare payment for coronary
stents, whether bare metal or DES, used during a PCI performed during a
hospitalization are included in the IPPS payment for the inpatient
hospitalization. While they are not paid separately by Medicare,
payment for the required resources would be included in AMI episodes
because the IPPS services for the anchor hospitalization are included
in the episodes. We proposed to risk-stratify EPM-episode prices based
on MS-DRG as discussed in section III.D.4.b.(1) of this final rule and
there are separate MS-DRGs for PCIs that use DES (246 and 247) and non-
DES (248 and 249) for which there would be separate AMI episode prices.
Therefore, we do not believe that the financial incentives under the
AMI model encourage the use of any specific coronary stent because the
episode prices take into consideration the IPPS payment for the
specific MS-DRG that applies to the AMI model beneficiary. We do not
expect the AMI model to discourage the appropriate use of DES.
Comment: Several commenters pointed out that Arkansas and Tennessee
have bundled payment programs that include CABG episodes, and their
efforts to implement bundled payments include state Medicaid and
commercial health plans. The commenters stated that in Arkansas, the
episode definition is consistent, specifically naming the duration,
responsible entity, and the included services and conditions, across
all participating payers. If MSAs from Arkansas or Tennessee are
selected for the AMI and CABG models, the commenters recommended that
CMS should align the CABG episode definition with that of the state
Medicaid plan. The commenters stated that this approach to episode
definition would decrease the complexity and cost to providers in those
states and reduce overlapping, independent efforts at care redesign
that both hospitals and cardiac surgery groups would be simultaneously
undertaking, potentially independently. The commenters added that this
would also allow CMS to experiment with different episode definitions
than those under the BPCI initiative and CJR model and proposed for the
EPMs.
Response: We appreciate the commenters drawing our attention to the
states that are currently engaged in testing bundled payment models. We
are encouraged that several states have identified clinical conditions
that overlap with those proposed in the EPMs for testing bundled
payment models, specifically CABG and PCI in the context of acute AMI
(acute PCI). The choice of these states to test bundled payment models
for some of the same clinical conditions that are included the EPMs
provides additional support for the opportunities under our proposal of
these models for Medicare beneficiaries. Specifically, Arkansas and
Tennessee are testing CABG bundled payment models which are similar to
the CMS CABG model, while Ohio and Tennessee are testing acute PCI
bundled payment models that are similar to the subset of beneficiaries
in the CMS AMI model discharged from PCI MS-DRGs with an AMI ICD-CM
diagnosis code on the hospital claim. As displayed in section III.B.5
of this final rule, MSAs in Arkansas, Tennessee, and Ohio have been
selected for participation in the CMS AMI and CABG models.
The state and CMS models for acute PCI and CABG episodes have
similar design features. First, the responsible entity for CABG
episodes is the hospital in Tennessee (the physician in Arkansas) like
the CMS model and for acute PCI episodes in both states it is the
facility where the PCI is performed, which would most commonly be the
hospital for an acute procedure as in the CMS model where the hospital
is responsible. Second, both the state and CMS models begin with the
inpatient hospitalization (or with performance of the procedure),
although the state model episodes extend 30 days following discharge,
whereas the CMS model episodes extend 90 days. We note that for CMS
CABG episodes, 92 percent of episode spending occurs during the anchor
hospitalization and the 30 days post-discharge, while 84 percent of
acute PCI episode spending occurs during that same period of time.\60\
Thus, despite the differences in episode duration between the state and
CMS models, the large majority of episode spending occurs in the first
30 days post-discharge so the state and CMS models contain most of the
same episode spending. Third, the state and CMS models include most
services furnished in the episode post-discharge from the anchor
hospitalization, although the state models are not quite as inclusive.
Fourth, episode payments are tied to quality measures in both the state
and CMS models. Finally, both the state and CMS models included two-
sided risk and risk adjustment (or risk stratification) based on payer-
specific factors.
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\60\ Episodes for AMI and CABG beneficiaries initiated by all
U.S. IPPS hospitals not in Maryland and constructed using
standardized Medicare FFS Parts A and B claims, as proposed in the
proposed rule, that began in CY 2012-2014.
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Both the state and CMS CABG and acute PCI models support the
implementation and testing of bundled payment models for these costly
episodes that significantly impact the health of individuals with
cardiac disease. While it is operationally infeasible for CMS to apply
the different definitions used by state Medicaid agencies in different
states testing episode payment in an EPM of the scope of the CMS CABG
and AMI models, the state and CMS models that included CABG and acute
PCI are sufficiently similar and clinical pathways around CABG and
acute PCI care reasonably well-established such that we believe
coordination among the various providers, including hospitals and
physicians, caring for all beneficiaries in CABG and acute PCI
episodes, regardless of payer, should not pose a significant burden on
the providers involved. Although the CMS CABG model places the
responsibility for the episode upon the hospital, like the Tennessee
CABG model, the financial arrangements that are permissible for
individuals and entities that collaborate with the hospital toward the
goal of improved quality and efficiency of CABG episode care as
discussed in section III.I. of this final rule provide participant
hospitals with substantial opportunity to share upside and downside
risk with their collaborators, including physicians that might be
leading CABG bundled payment efforts
[[Page 264]]
in Arkansas. The financial arrangement policies under the CMS CABG
model should help to minimize the occurrence of independent,
potentially overlapping efforts of hospitals and physician groups to
redesign care for CABG patients covered by different insurers. We
believe that the state and CMS bundled payment models for overlapping
clinical conditions are complementary efforts that will provide
substantial new information about the effects of bundled payments on
the quality and cost of care for CABG and acute PCI. While we
understand that implementation of the EPMs will result in testing CABG
and acute PCI episodes with minor differences in design for
beneficiaries of Medicare versus Medicaid and other commercial payers
in MSAs selected for the AMI and CABG models in Arkansas, Tennessee,
and Ohio, these differences are unlikely to affect the episode care
redesign strategies of the responsible hospitals under the CMS and
state models.
Comment: While a number of commenters supported the proposal to
update the EPM excluded services through the proposed sub-regulatory
process to provide for flexibility and timeliness in adding exclusions
to EPM episodes, several commenters opposed CMS' proposal to make
changes to EPM episode exclusions through an annual, at a minimum,
update outside of rulemaking. The commenters encouraged CMS to use
notice and comment rulemaking to evaluate and exclude additional
services from EPM episodes. The commenters stated that because
participation in the EPMs is required in selected geographic areas and,
therefore, the EPMs affect a large number of hospitals and providers,
it is important that CMS implement the process to update services to be
excluded from these episodes through notice and comment rulemaking, so
that provider feedback throughout the course of EPM implementation is
reflected in CMS' decisions. They added that hospitals of different
sizes, geographic locations, organizational capabilities, and socio-
economic factors all have unique preferences, and their ideas and
opinions should be accounted for when CMS makes changes to the list of
conditions and services to be included and/or excluded from the
episodes.
Many commenters recommended CMS to continue to evaluate the list of
services to be excluded from EPM episodes. They encouraged CMS to
consider excluding a variety of additional services, including hospital
readmissions planned for the beneficiary prior to the anchor
hospitalization for consistency with other CMS policies such as the
treatment of planned readmissions under the HRRP; ongoing care for
beneficiaries' chronic conditions for which management is outside the
scope of the EPMs and their exclusion could confound the EPM test of
optimizing quality and costs for certain episodes; and post-acute care
following excluded readmissions where little is known about the causal
relationship between the hospital readmission and subsequent post-acute
care services.
Response: We appreciate the interest of the commenters in ensuring
that future changes to the EPM episode definitions involve a
transparent process with opportunity for broad stakeholder input. We
have some experience with a similar sub-regulatory update process for
the CJR model for both the list of excluded services and the fracture
ICD-10-CM diagnosis codes that are used to identify episodes for
fracture risk-stratification. We used this process after publication of
the CJR Final Rule and again more recently to update the CJR model
exclusion list for changes to the FY 2017 IPPS MS-DRGs and ICD-10-CM
diagnosis codes. We have received significant public input through
those processes, which has allowed us to consider and incorporate, as
appropriate based on the regulatory review standards for the processes,
stakeholder input and in turn communicate timely final updates to the
exclusions and fracture lists to CJR participant hospitals. We have not
heard any concerns about the sub-regulatory update processes as we have
applied them during CJR model implementation.
As we concluded for the CJR model, we continue to believe that
updating the exclusions annually, at a minimum, is most appropriate for
the 5-year EPMs, and allowing more frequent updates than through
rulemaking as necessary to accommodate timely ICD-10-CM annual coding
changes and annual IPPS MS-DRG changes, as well as to address
significant issues raised by EPM participants and other stakeholders or
by CMS as we continue to evaluate the list of excluded services for the
EPM episodes. We will explore the additional areas recommended by the
commenters and others that may arise during EPM implementation, and we
will utilize the exclusion list update process to suggest any future
changes based on our additional analyses.
The commenters who supported an exclusion list update process
outside of rulemaking did not suggest specific revisions to the
proposed standards for updating the EPM episode exclusions, namely:
We would not exclude the following items or services that
are:
++ Directly related to the EPM episode or the quality or safety of
the EPM episode care.
++ For chronic conditions that may be affected by the EPM episode
care.
We would exclude the following items and services that
are:
++ For chronic conditions not generally affected by the EPM episode
care.
++ For acute clinical conditions, not arising from existing EPM
episode-related chronic clinical conditions or complications of EPM
episode care.
Thus, we continue to believe these standards provide the
appropriate clinical review framework for updates to the EPM exclusion
list. Finally, we believe that our proposed process to post the
potential revised exclusions, which could include additions to or
deletions from the exclusion list, to the CMS Web site to allow for
public input on our planned application of these standards, and then
adopt changes to the exclusion list with posting to the CMS Web site of
the final revised exclusion list after our consideration of the public
input is consistent with the recommendation of commenters that we use a
transparent process reflective of broad opportunity for public input,
including implementation experience with the EPMs. Conducting this
update process outside of rulemaking based on the standards set forth
in this final rule allows us the greatest flexibility to update the
exclusions as changes to the MS-DRGs and ICD-10-CM diagnosis codes,
upon which our exclusions rely, are released. This process also allows
us to respond quickly to any episode definition issues that arise
during implementation of the EPMs across the broad array of EPM
participants in the selected MSAs, as well as consider any new analysis
conducted by CMS or stakeholders about the relationship among items and
services to the EPM episodes that might result in a different
assessment of the inclusion or exclusion of existing MS-DRGs or ICD-10-
CM diagnosis codes in the definition of EPM episodes. We would widely
publicize the opportunity for review and public input through the CMS
Web site and listservs. We also note that any changes to our overall
approach to identifying excluded items and services or to our standards
for evaluating items and services for exclusion would be address
through future rulemaking. Therefore, we are finalizing our proposal to
update the exclusion list annually, at a minimum, using the standards
and process as described.
[[Page 265]]
Final Decision: After consideration of the public comments
received, we are finalizing the proposals in Sec. 512.210(a), without
modification, to identify related items and services for EPM episodes
as the following items and services paid under Medicare Part A and Part
B, after the EPM-specific exclusions are applied:
Physicians' services.
Inpatient hospital services.
IPF services.
LTCH services.
IRF services.
SNF services.
HHA services.
Hospital outpatient services.
Independent outpatient therapy services.
Clinical laboratory services.
Durable medical equipment.
Part B drugs.
Hospice.
We are also finalizing the proposals, without modification, to use
the following standards to exclude items and services from EPM
episodes:
Hospital readmissions for MS-DRGs that group to the
following categories of diagnoses: Oncology; trauma medical admissions;
surgery for chronic conditions unrelated to a condition likely to have
been affected by care furnished during the EPM episode; and surgery for
acute conditions unrelated to a condition resulting from or likely to
have been affected by care during the EPM episode.
Part B items and services for acute disease diagnoses
unrelated to a condition resulting from or likely to have been affected
by care during the EPM episode, and certain chronic disease diagnoses,
as specified by CMS on a diagnosis-by-diagnosis basis, depending on
whether the condition was likely to have been affected by care during
the EPM episode or whether substantial services were likely to be
provided for the chronic condition during the EPM episode.
Drugs that are paid outside of the MS-DRGs included in the
EPM episode definitions, specifically hemophilia clotting factors.
IPPS new technology add-on payments for drugs,
technologies, and services.
OPPS transitional pass-through payments for medical
devices.
We are finalizing the proposals in Sec. 512.210(b) to exclude from
EPM episodes specific readmissions, Part B-covered items and services
with specific ICD-9-CM or ICD-10-CM diagnosis codes in the principal
position on claims for items and services during the 90 days post-
discharge from the anchor hospitalization, and additionally Part-B
covered DME with specific ICD-9-CM or ICD-10-CM diagnosis codes in the
principal position on claims during the anchor hospitalization, with
modification to place MS-DRGs 326-328 on the AMI MS-DRG-anchored AMI
exclusion list and MS-DRGs 266-267 on the AMI MS-DRG-anchored AMI
exclusion list and the CABG exclusion list. As discussed in section
III.C.4.a.(5) of this final rule, we are not finalizing our proposed
AMI model inpatient-to-inpatient transfer episode initiation and
attribution policy so we will not use the terms chained anchor
hospitalization and price MS-DRG in the final AMI episode definition
and pricing policies. Therefore, the applicable EPM exclusion list is
applied to the EPM episode on the basis of the MS-DRG that anchors the
EPM episode. The final EPM exclusion lists based on ICD-9-CM and ICD-
10-CM diagnosis codes and MS-DRGs as of FY 2016 are posted on the CMS
Web site at https://innovation.cms.gov/initiatives/epm.
Lastly, we are finalizing our proposals in Sec. 512.210(c) to
update the exclusion lists by sub-regulatory guidance on an annual
basis, at a minimum, to reflect annual changes to ICD-10-CM coding and
annual changes to the MS-DRGs under the IPPS, as well as to address any
other issues that are brought to our attention throughout the course of
the EPMs, without modification. The standards for this updating process
are:
Include any items or services that are directly related to
the EPM episode diagnosis or procedure (for example, a subsequent
admission for heart failure or repeat revascularization) or the quality
or safety of care (for example, sternal wound infection following
CABG);
Include items or services for chronic conditions that may
be affected by the EPM diagnosis or procedure and the post-discharge
care (for example, diabetes);
Exclude items and services for chronic conditions that are
generally not affected by the EPM diagnosis or procedure and the post-
discharge care (for example, prostate removal for cancer); and
Exclude items and services for acute clinical conditions
not arising from existing EPM episode-related chronic clinical
conditions or complications from the EPM episode (for example,
appendectomy).
The potential revised exclusions, which could include additions to
or deletions from the exclusion lists, will be posted to the CMS Web
site to allow for public input. After receiving and reviewing public
input on potential revised exclusions, we will post the final revised
exclusion lists, including providing information to the public about
when the revisions would take effect and to which episodes they would
apply.
With the publication of this final rule, we are initiating the sub-
regulatory update process to incorporate changes to the MS-DRGs and
ICD-10-CM diagnosis codes for 2017 into the EPMs by posting potential
changes to the exclusion lists for the EPMs. We did not consider the
2017 changes in the EPM proposed rule, because the final MS-DRGs and
ICD-10-CM codes were not yet available when the proposed rule was
published in the Federal Register on August 2, 2016. There are no MS-
DRG changes for FY 2017 that resulted in our suggesting potential
changes to the exclusion lists for the EPMs. We are suggesting
potential modifications to the principal ICD-10-CM diagnosis code
categories for excluded Part B services in the AMI, CABG, and SHFFT
models as of July 1, 2017, based on new ICD-10-CM diagnosis code
categories for FY 2017 and clinical review of existing ICD-10-CM
diagnosis code categories to which new ICD-10-CM diagnosis codes have
been added for FY 2017. The potential modifications to the exclusion
list for each EPM are posted on the CMS Web site at https://innovation.cms.gov/initiatives/epm. We request that public input on the
potential modifications be sent to epm@cms.hhs.gov by 11:59 p.m. on
Friday, January 27, 2017. After receiving and reviewing public input on
potential revised exclusions, we will post the final revised exclusions
by February 24, 2017, including providing information to the public
about when the revisions will take effect and to which episodes they
would apply.
4. EPM Episodes
a. Beneficiary Care Inclusion Criteria and Beginning of EPM Episodes
(1) General Beneficiary Care Inclusion Criteria
Because of the clinical variability leading up to these EPM
episodes and the challenge of identifying unrelated services given the
multiple chronic conditions experienced by many EPM beneficiaries, we
proposed to follow the CJR model precedent and not begin an EPM episode
prior to the anchor hospitalization (80 FR 73315 and 73318). We
proposed that all services that were already included in the IPPS
payment based on established Medicare policies (for example, 3-day
payment window payment policies) would be included in these EPM
episodes, and that the defined population of Medicare beneficiaries
whose care would be included in the EPMs would meet all of
[[Page 266]]
the following criteria on admission to the anchor or chained anchor
hospitalization:
Enrolled in Medicare Part A and Part B.
Eligible for Medicare not on the basis of end-stage renal
disease.
Not enrolled in any managed care plan (for example,
Medicare Advantage, Health Care Prepayment Plans, cost-based health
maintenance organizations).
Not covered under a United Mine Workers of America health
plan, which provides health care benefits for retired mine workers.
Have Medicare as their primary payer.
Not aligned to an ACO in the Next Generation ACO model or
an ACO in a track of the Comprehensive ESRD Care Initiative
incorporating downside risk for financial losses.
Not under the care of an attending or operating physician,
as designated on the inpatient hospital claim, who is a member of a
physician group practice that initiates BPCI Model 2 episodes at the
EPM participant for the MS-DRG that would be the anchor MS-DRG under
the EPM.
Not already in any BPCI model episode.
Not already in an AMI, SHFFT, CABG or CJR model episode
with an episode definition that does not exclude the MS-DRG that would
be the anchor MS-DRG under the applicable EPM.
For a discussion of our proposal to exclude certain ACO-assigned
beneficiaries from EPM episodes, we refer to section III.D.6.c.(3) of
the proposed rule (81 FR 50869 through 50870). For a discussion of our
proposals for addressing potential overlap of beneficiaries in episode
payment models that are relevant to these last two criteria, we refer
to sections III.D.6.c.(1) and (2) of the proposed rule (81 FR 50868
through 50869).
The proposal for beneficiary care inclusion policies was included
in proposed Sec. 512.230. We sought comment on our proposal of
beneficiary care inclusion policies.
The following is a summary of the comments received and our
responses. We refer to sections III.D.6.c.(1) through (3) of this final
rule for a summary of the comments received and our responses on the
proposed three general beneficiary care inclusion criteria that relate
to beneficiaries in other CMS models and programs.
Comment: Many commenters expressed support for the proposed general
beneficiary care inclusion criteria as reasonable and consistent with
other models and programs. On the other hand, a number of commenters
requested that CMS exclude beneficiaries with certain clinical
characteristics from all three proposed EPMs, including beneficiaries
receiving hospice care before or during the episode; experiencing an
inpatient psychiatric hospitalization preceding or during an episode;
having preexisting functional disabilities in activities of daily
living; bearing a diagnosis of dementia; residing in a SNF; and
experiencing illnesses for which it is expected that the beneficiary
would be likely to die within the upcoming year. The commenters
generally stated that these beneficiaries should be excluded due to
high and variable needs for care that would not be typical for
beneficiaries in EPM episodes. One commenter recommended CMS to adopt
an ``out clause'' for the most complex patients to be exempt from the
EPMs, such as beneficiaries with multi-organ system involvement or
comorbidities or poly-chronic illnesses. The commenters were concerned
that without accurate risk adjustment under the EPMs, hospitals
disproportionately caring for these beneficiaries would experience
undue financial risk for necessary episode care. The commenters
recommended that if CMS did not exclude high-risk beneficiaries, CMS
must adopt more robust risk adjustment to account for socioeconomic,
clinical, or other risk factors that are out of the hospital's control
and impact patients' health and recovery. Several commenters
recommended that at least the initial implementation of the EPMs should
exclude vulnerable populations with complicated or intensive care needs
from the EPMs until the EPMs demonstrate sufficient quality outcomes
and have developed accurate risk adjustments and patient safeguards to
ensure high-quality care for populations that the commenters believe
could face serious care disadvantages in the EPMs and put hospitals at
an unacceptable level of financial risk.
Response: Most beneficiaries with anchor hospitalizations that
would initiate EPM episodes would have underlying conditions that may
affect care throughout the episode or that may be influenced by the
surgery or AMI that initiates the episode. Similar to our rationale in
the CJR Final Rule regarding LEJR episodes (80 FR 73371), we believe it
is important to include these beneficiaries in the EPMs so that they
can benefit from the increased opportunities for care coordination and
management throughout the episodes, and including the broadest feasible
array of Medicare beneficiaries in the EPMs provides EPM participants
with the greatest volume of episodes and incentive to redesign episode
care. We do not believe it would be appropriate to exclude
beneficiaries from the EPMs just because they are potentially expected
to have high-cost, variable health care needs under the EPMs. We refer
to section III.D.4.b.(2) of this final rule for a discussion of risk
adjustment for the EPMs. Therefore, we will not exclude additional
beneficiaries with certain clinical characteristics from the EPMs
beyond those general beneficiary care inclusion criteria that we
proposed.
Comment: Several commenters requested that CMS exclude
beneficiaries with a home address not in the service area of the
treating hospital. The commenters believe that including beneficiaries
in this scenario would result in an unfair financial and administrative
burden for EPM participants relative to other EPM beneficiaries
residing in the service area of the hospital in meeting the challenges
of remote post-discharge care coordination and ensuring ultimate
quality outcomes for medically complex out-of state-patients.
Response: We acknowledge that in occasional circumstances, EPM
participants may have limited ability to coordinate care. For similar
reasons as our discussion in the CJR Final Rule (80 FR 73317 through
73318) regarding LEJR episodes, following the care coordination that
takes place in the EPM participant during the anchor hospitalization,
we expect that much of the subsequent coordination of post-acute care
services and other related services for EPM beneficiaries during the 90
days post-discharge can be accomplished through telecommunications that
do not require the patient to remain within the geographic proximity of
the hospital responsible for the EPM episode. In addition, the design
of the EPMs does not preclude hospitals from coordinating care with
other providers outside of their immediate service area, which may be
necessary especially in the case of beneficiaries who are admitted to a
o-i or inpatient-to-inpatient (i-i) transfer hospital after an
outpatient-to-inpatient or inpatient-to-inpatient transfer,
respectively, for a different or higher level of cardiac care that is
not available at the local hospital to which they originally presented
with symptoms of an AMI. As discussed in section III.C.4.a.(5) of this
final rule, under our final AMI model policy we are canceling all AMI
episodes that begin at an initial treating hospital through an
inpatient admission that
[[Page 267]]
initiates the AMI episode when the beneficiary is transferred for
admission to an i-i transfer hospital after the AMI episode begins.
Thus, hospitals that are AMI and CABG model participants and that
receive beneficiaries in transfer either from outpatient or inpatient
status at an initial treating hospital will commonly initiate and be
responsible for AMI or CABG episodes that begin at the o-i/i-i transfer
hospital. This attribution of episodes to the o-i/i-i transfer hospital
increases the probability that the home of beneficiaries is not in the
service area of the responsible hospital under the AMI or CABG model,
yet most commenters requested that we adopt this transfer attribution
policy. Therefore, we believe that most EPM participants have the tools
to engage in effective remote care coordination that results in high
quality episode care.
Finally, we note that we are finalizing several waivers of Medicare
program rules, as discussed in section III.J. of this final rule, to
facilitate efficient and effective episode care coordination for
beneficiaries in remote or distant locations outside of the EPM
participant's immediate community. We are also finalizing policies for
financial arrangements in section III.I. of this final rule that allow
EPM participants to share upside and downside financial risk with a
variety of individuals and entities who collaborate with the EPM
participant in redesigning care and caring for EPM beneficiaries,
regardless of the geographic proximity of these individuals and
entities to the EPM participant. Through financial arrangements, EPM
participants could align the financial incentives of providers in the
EPM beneficiary's home community with the goals of the EPM participant
to improve the quality and reduce the cost of EPM episodes. Therefore,
we will not exclude beneficiaries from the EPMs who are referred to EPM
participants that are not close to the beneficiary's home.
Comment: Several commenters requested clarification about whether
patients who buy in to Medicare A or B through the Medicaid program
would be excluded from the EPMs.
Response: As long as the beneficiaries are enrolled in both
Medicare Part A and Part B, regardless of whether enrollment occurs
through Medicaid program buy in, and assuming the beneficiaries meet
the other general beneficiary care inclusion criteria, their care would
be included in the EPMs.
Comment: A commenter presented a scenario where an EPM participant
admitted and successfully treated a beneficiary with a SHFFT procedure,
but the patient later falls and has a subsequent hip fracture requiring
surgical fracture repair within the post[hyphen]acute period of the
episode. The commenter requested clarification about whether this
instance would trigger a new SHFFT episode or the cost of the
readmission to repair the second fracture would be included in the
prior SHFFT episode's total cost.
Response: During such a readmission, the beneficiary would already
be in a SHFFT episode. Therefore, the ongoing SHFFT episode would not
be canceled and a new SHFFT episode would not be initiated because the
beneficiary would not meet the proposed beneficiary care inclusion
criteria to initiate a SHFFT episode since he or she is already in a
SHFFT episode. Because SHFFT MS-DRGs 480-482 are not on the exclusion
list for SHFFT episodes, the related readmission would be included in
the ongoing SHFFT episode and its cost included in the calculation of
actual episode spending for the SHFFT episode that began with the
initial hospitalization for a SHFFT procedure.
Final Decision: After consideration of the public comments
received, we are finalizing the proposals in Sec. 512.230 for the
general beneficiary care inclusion criteria, with modification to
remove references to chained anchor hospitalization which we are not
including in the final EPM policies as discussed in section
III.C.4.a.(5) of this final rule. We are additionally excluding from
EPM episodes beneficiaries who are assigned to a Shared Savings Program
ACO in Track 3, as discussed in section III.D.6.c.(3) of this final
rule. We define the population of Medicare beneficiaries whose care is
included in the EPM as those who meet all of the following criteria on
admission to the anchor hospitalization:
Enrolled in Medicare Part A and Part B.
Eligible for Medicare not on the basis of end-stage renal
disease.
Not enrolled in any managed care plan (for example,
Medicare Advantage, Health Care Prepayment Plans, cost-based health
maintenance organizations).
Not covered under a United Mine Workers of America health
plan, which provides health care benefits for retired mine workers.
Have Medicare as their primary payer.
Not prospectively assigned to:
++ An ACO in the Next Generation ACO model;
++ An ACO in a track of the Comprehensive ESRD Care Model
incorporating downside risk for financial losses; or
++ A Shared Savings Program ACO in Track 3.
Not under the care of an attending or operating physician,
as designated on the inpatient hospital claim, who is a member of a
physician group practice that initiates BPCI Model 2 episodes at the
EPM participant for the MS-DRG that would be the anchor MS-DRG under
the EPM.
Not already in any BPCI model episode.
Not already in an AMI, SHFFT, CABG or CJR model episode
with an episode definition that does not exclude the MS-DRG that would
be the anchor MS-DRG under the applicable EPM.
(2) Beginning AMI Episodes
We proposed that, as long as the beneficiary met the general
beneficiary care inclusion criteria, then an AMI episode would begin
with admission of a Medicare beneficiary to an IPPS hospital for the
following MS-DRGs, where the specific MS-DRG would be called the anchor
MS-DRG for the episode:
AMI MS-DRGs--
++ 280 (Acute myocardial infarction, discharged alive with MCC);
++ 281 (Acute myocardial infarction, discharged alive with CC); and
++ 282 (Acute myocardial infarction, discharged alive without CC/
MCC).
PCI MS-DRGs, when the claim includes an AMI ICD-10-CM
diagnosis code in the principal or secondary position on the IPPS claim
as specified in Table 3--
++ 246 (Percutaneous cardiovascular procedures with drug-eluting
stent with MCC or 4+ vessels/stents);
++ 247 (Percutaneous cardiovascular procedures with drug-eluting
stent without MCC);
++ 248 (Percutaneous cardiovascular procedures with non-drug-
eluting stent with MCC or 4+ vessels/stents);
++ 249 (Percutaneous cardiovascular procedures with non-drug-
eluting stent without MCC);
++ 250 (Percutaneous cardiovascular procedures without coronary
artery stent with MCC); and
++ 251 (Percutaneous cardiovascular procedures without coronary
artery stent without MCC).
Table 3 displays the ICD-9-CM codes that we proposed to use to
identify historical AMI episodes for beneficiaries discharged from PCI
MS-DRGs, as well as the ICD-10-CM diagnosis codes that would be used to
identify AMI episodes for beneficiaries discharged from PCI MS-DRGs
throughout the duration of the AMI model. The sub-regulatory process
for updating this AMI ICD-10-CM diagnosis code list was described in
[[Page 268]]
section III.C.3.a.(1) of the proposed rule (81 FR 50831).
We first identified the ICD-9-CM diagnosis codes for the initial
AMI episode-of-care that were historically used to report care for a
newly diagnosed AMI patient admitted to the hospital. These codes all
have a fifth digit of ``1'' and were applicable until the patient was
discharged from acute medical care, including for any transfers to and
from other acute care facilities that occurred. These AMI ICD-9-CM
diagnosis codes would be used to identify historical AMI episodes for
developing AMI model-episode benchmark prices for anchor PCI MS-DRGs.
We proposed to cross-walk the ICD-9-CM diagnosis codes for the initial
AMI episode-of-care to the ICD-10-CM diagnosis codes that would be
reported for similar beneficiaries during the AMI model performance
years. The crosswalk in Table 5 is consistent with the crosswalk CMS
posted for public comment regarding ICD-9-CM to ICD-10-CM diagnosis
codes used for HIQR Program measures, including AMI quality
measures.\61\
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\61\ https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/HospitalQualityInits/Downloads/HIQR-ICD9-to-ICD10-Tables.pdf.
Table 5--Proposed ICD-9-CM and ICD-10-CM AMI Diagnosis Codes in the Principal or Secondary Position on the IPPS
Claim for PCI MS-DRGS (246-251) That Initiate AMI Episodes
----------------------------------------------------------------------------------------------------------------
ICD-10-CM
ICD-9-CM Diagnosis code ICD-9-CM Description Diagnosis code ICD-10-CM Description
----------------------------------------------------------------------------------------------------------------
410.01........................ Acute myocardial infarction of 121.09 ST elevation (STEMI) myocardial
anterolateral wall, initial infarction involving other
episode of care. coronary artery of anterior
wall.
122.0 Subsequent ST elevation (STEMI)
myocardial infarction of
anterior wall.
410.11........................ Acute myocardial infarction of 121.01 ST elevation (STEMI) myocardial
other anterior wall, initial infarction involving left main
episode of care. coronary artery.
121.02 ST elevation (STEMI) myocardial
infarction involving left
anterior descending coronary
artery.
121.09 ST elevation (STEMI) myocardial
infarction involving other
coronary artery of anterior
wall.
122.0 Subsequent ST elevation (STEMI)
myocardial infarction of
anterior wall.
410.21........................ Acute myocardial infarction of 121.10 ST elevation (STEMI) myocardial
inferolateral wall, initial infarction involving other
episode of care. coronary artery of inferior
wall.
122.1 Subsequent ST elevation (STEMI)
myocardial infarction of
inferior wall.
410.31........................ Acute myocardial infarction of 121.11 ST elevation (STEMI) myocardial
inferoposterior wall, initial infarction involving right
episode of care. coronary artery.
122.1 Subsequent ST elevation (STEMI)
myocardial infarction of
inferior wall.
410.41........................ Acute myocardial infarction of 121.19 ST elevation (STEMI) myocardial
other inferior wall, initial infarction involving other
episode of care. coronary artery of inferior
wall.
122.1 Subsequent ST elevation (STEMI)
myocardial infarction of
inferior wall.
410.51........................ Acute myocardial infarction of 121.29 ST elevation (STEMI) myocardial
other lateral wall, initial infarction involving other
episode of care. sites.
122.8 Subsequent ST elevation (STEMI)
myocardial infarction of other
sites.
410.61........................ True posterior wall infarction, 121.29 ST elevation (STEMI) myocardial
initial episode of care. infarction involving other
sites.
122.8 Subsequent ST elevation (STEMI)
myocardial infarction of other
sites.
410.71........................ Subendocardial infarction, 121.4 Non-ST elevation (NSTEMI)
initial episode of care. myocardial infarction.
122.2 Subsequent non-ST elevation
(NSTEMI) myocardial
infarction.
410.81........................ Acute myocardial infarction of 121.21 ST elevation (STEMI) myocardial
other specified sites, initial infarction involving left
episode of care. circumflex coronary artery.
121.29 ST elevation (STEMI) myocardial
infarction involving other
sites.
122.8 Subsequent ST elevation (STEMI)
myocardial infarction of other
sites.
410.91........................ Acute myocardial infarction of 121.3 ST elevation (STEMI) myocardial
unspecified site, initial infarction of unspecified
episode of care. site.
122.9 Subsequent ST elevation (STEMI)
myocardial infarction of
unspecified site.
----------------------------------------------------------------------------------------------------------------
The proposal for beginning AMI episodes was included in proposed
Sec. 512.240(a)(1). We sought comment on our proposal to begin AMI
episodes.
We address some of the comments related to the proposed AMI ICD-CM
diagnosis codes displayed in Table 5 in section III.C.3.a.(1) of this
final rule in the context of our discussion of the clinical conditions
that define AMI episodes. We received no comments specific to the ICD-
9-CM to ICD-10-CM crosswalk of the AMI ICD-CM diagnosis codes included
in Table 5.
[[Page 269]]
The following is a summary of the comments received on other issues
related to our proposal to begin AMI episodes and our responses.
Comment: Several commenters stated that uncomplicated acute AMI can
be treated and discharged the next day. They pointed out that under
Medicare's Two-Midnight rule, these beneficiaries would be classified
as outpatients. They requested clarification about whether CMS believes
these beneficiaries with AMI should be classified as inpatient even if
the expectation of the treating physician is a less than Two-Midnight
hospital stay so the AMI model would include all beneficiaries with
AMI.
Response: The AMI model does not change Medicare's current payment
policy for classifying Medicare beneficiaries as outpatients or
inpatients, including beneficiaries with AMI. Therefore, AMI model
participants should continue to follow all existing Medicare rules that
apply to classifying beneficiaries as inpatients or outpatients for
beneficiaries with AMI who could potentially initiate AMI episodes if
they were admitted to the AMI model participant.
To provide greater clarity to hospitals and physician stakeholders,
and to address the higher frequency of beneficiaries being treated as
hospital outpatients for extended periods of time, CMS adopted the Two-
Midnight rule for admissions beginning on or after October 1, 2013.
This rule established Medicare payment policy regarding the benchmark
criteria to use when determining whether inpatient admission is
reasonable and necessary for purposes of payment under Medicare Part
A.\62\ In general, the original Two-Midnight rule stated that:
---------------------------------------------------------------------------
\62\ Fact Sheet: Two-Midnight Rule; CMS; October 30, 2015.
---------------------------------------------------------------------------
Inpatient admissions would generally be payable under Part
A if the admitting practitioner expected the patient to require a
hospital stay that crossed two midnights and the medical record
supported that reasonable expectation.
Medicare Part A payment was generally not appropriate for
hospital stays expected to last less than two midnights. Cases
involving a procedure identified on the inpatient-only list or that
were identified as ``rare and unusual exception'' to the Two-Midnight
benchmark by CMS were exceptions to this general rule and were deemed
to be appropriate for Medicare Part A payment.
The Two-Midnight rule also specified that all treatment decisions
for beneficiaries were based on the medical judgment of physicians and
other qualified practitioners. The Two-Midnight rule did not prevent
the physician from providing any service at any hospital, regardless of
the expected duration of the service.
We acknowledge that full provider implementation of hospital care
in accordance with the Two-Midnight rule did not occur immediately on
October 1, 2013 and that the first CMS' contractor reviews of short
stay inpatient admissions did not begin until October 2015. Therefore,
we understand that shifts in classifying certain beneficiaries with
uncomplicated AMI as outpatients instead of inpatients could have
occurred during the period of historical AMI episodes that would span
January 1, 2013 and December 31, 2015 and would be used for setting
quality-adjusted target prices in performance years 1 and 2 of the AMI
model. Under our monitoring and evaluation activities as discussed in
sections III.G.4. through 6. and section IV. of this final rule,
respectively, we will monitor the site-of-service for treatment of
beneficiaries with AMI over the course of the model to detect any
issues related to access to care, quality of care, or delayed care. We
will also evaluate the AMI model with respect to changes in AMI case
mix for AMI model participants, and if we observe them, we would
conduct analyses about the potential causes of such changes, including
whether AMI model participants shifted to treating some uncomplicated
beneficiaries with AMI as outpatients rather than inpatients. We
further note that when we first update the data used for historical EPM
episode payments in performance year 3 of the EPMs to be calendar years
2015 through 2017, we expect that any changes in care patterns related
to the Two-Midnight rule would have been made by the beginning of that
3-year period.
Comment: One commenter agreed with CMS that it is currently rare
for a beneficiary with AMI to have an outpatient PCI and, therefore,
almost all beneficiaries with AMI who are treated with PCI would be in
the AMI model under current hospital treatment practices. However, the
commenter added that by excluding beneficiaries who receive outpatient
PCI from the AMI model, EPM participants may change their billing to
outpatient PCI, especially for more complex and costly beneficiaries
for which AMI episode costs would be expected to be high. The commenter
recommended that CMS should put all AMI patients on the inpatient only
list.
Response: We appreciate the concern expressed by the commenter
about the potential for the financial incentives in the AMI model to
lead to shifting in the site-of-service for PCI for beneficiaries with
AMI from inpatient to outpatient. We note that the OPPS inpatient only
list includes procedures that are only paid under the IPPS and does not
assign certain diagnoses to inpatient only care. PCI currently is
commonly performed in the outpatient hospital department for
beneficiaries that do not have AMI, and we do not believe it would be
appropriate to place PCI procedures on the inpatient only list due to
concerns about the shifting of the site-of-service from inpatient to
outpatient for AMI model beneficiaries who require PCI. As we stated in
the proposed rule (81 FR 50829) patients experiencing an AMI are almost
uniformly admitted to the hospital for further evaluation and
management based on clinical guidelines for the treatment of
beneficiaries with AMI.\63\ We do not believe that EPM participants
would change their patterns of treatment of beneficiaries with AMI,
especially for those complex patients with significant medical needs,
in ways that would risk beneficiaries not receiving the medically
necessary inpatient hospital evaluation and management recommended for
their AMI treatment. We will be monitoring patterns of care as
discussed in sections III.G.4. through 6. of this final rule for
evidence of clinically-unexplained changes in care, including the site-
of-service for AMI beneficiaries who receive PCI, especially if we
believe there is the potential to compromise beneficiary access to care
or quality of care or to delay care.
---------------------------------------------------------------------------
\63\ Amsterdam et al. 2014 AHA/ACC Guideline for the Management
of Patients with Non-ST--Elevation Acute Coronary Syndromes.
Circulation. 2014; 130:e344-e426.
---------------------------------------------------------------------------
Comment: A commenter requested that CMS further clarify how an EPM
participant can determine whether beneficiaries with AMI who have a
CABG would be attributed to the AMI or CABG model.
Response: We appreciate the opportunity to provide clarification on
the specific episode attribution of beneficiaries with AMI who have a
CABG. We refer to section III.D.4.a.(5) of this final rule for further
discussion of the final transfer attribution policy for AMI episodes
that involve an inpatient-to-inpatient transfer for AMI care. AMI and
CABG episodes are initiated based on the MS-DRG that is assigned to the
final discharge that occurs during the anchor hospitalization. Thus, if
a beneficiary hospitalized for treatment of AMI has a CABG during that
anchor hospitalization, we expect that the
[[Page 270]]
beneficiary would be discharged from a CABG MS-DRG (231-236) and,
therefore, would initiate a CABG episode. We refer to section
III.D.4.b.(b) of this final rule for the pricing adjustment that would
apply to CABG episodes for beneficiaries who have a CABG during the
initial hospitalization for AMI treatment. However, if a beneficiary
with an AMI hospitalized for initial treatment is discharged from the
anchor hospitalization and then readmitted for CABG during the 90 day
post-discharge episode duration, the beneficiary would initiate an AMI
episode, which would not be canceled due to the CABG readmission. We
refer to section III.D.4.b.(c) of this final rule for the pricing
adjustment that would apply to AMI episodes with CABG readmissions.
Final Decision: After consideration of the public comments
received, we are finalizing the proposals in Sec. 512.240(a)(1),
without modification, to begin AMI episodes with admission of a
Medicare beneficiary to an IPPS hospital for the following MS-DRGs,
where the specific MS-DRG is called the anchor MS-DRG for the episode:
AMI MS-DRGs--
++ 280 (Acute myocardial infarction, discharged alive with MCC);
++ 281 (Acute myocardial infarction, discharged alive with CC); and
++ 282 (Acute myocardial infarction, discharged alive without CC/
MCC).
PCI MS-DRGs, when the claim includes an AMI ICD-10-CM
diagnosis code in the principal or secondary position on the IPPS claim
as specified in Table 6--
++ 246 (Percutaneous cardiovascular procedures with drug-eluting
stent with MCC or 4+ vessels/stents);
++ 247 (Percutaneous cardiovascular procedures with drug-eluting
stent without MCC);
++ 248 (Percutaneous cardiovascular procedures with non-drug-
eluting stent with MCC or 4+ vessels/stents);
++ 249 (Percutaneous cardiovascular procedures with non-drug-
eluting stent without MCC);
++ 250 (Percutaneous cardiovascular procedures without coronary
artery stent with MCC); and
++ 251 (Percutaneous cardiovascular procedures without coronary
artery stent without MCC).
Table 6--Final ICD-9-CM and ICD-10-CM AMI Diagnosis Codes in the Principal or Secondary Position on the IPPS
Claim for PCI MS-DRGS (246-251) That Initiate AMI Episodes
----------------------------------------------------------------------------------------------------------------
ICD-10-CM
ICD-9-CM Diagnosis code ICD-9-CM Description Diagnosis code ICD-10-CM Description
----------------------------------------------------------------------------------------------------------------
410.01........................ Acute myocardial infarction of 121.09 ST elevation (STEMI) myocardial
anterolateral wall, initial infarction involving other
episode of care. coronary artery of anterior
wall.
122.0 Subsequent ST elevation (STEMI)
myocardial infarction of
anterior wall.
410.11........................ Acute myocardial infarction of 121.01 ST elevation (STEMI) myocardial
other anterior wall, initial infarction involving left main
episode of care. coronary artery.
121.02 ST elevation (STEMI) myocardial
infarction involving left
anterior descending coronary
artery.
121.09 ST elevation (STEMI) myocardial
infarction involving other
coronary artery of anterior
wall.
122.0 Subsequent ST elevation (STEMI)
myocardial infarction of
anterior wall.
410.21........................ Acute myocardial infarction of 121.10 ST elevation (STEMI) myocardial
inferolateral wall, initial infarction involving other
episode of care. coronary artery of inferior
wall.
122.1 Subsequent ST elevation (STEMI)
myocardial infarction of
inferior wall.
410.31........................ Acute myocardial infarction of 121.11 ST elevation (STEMI) myocardial
inferoposterior wall, initial infarction involving right
episode of care. coronary artery.
122.1 Subsequent ST elevation (STEMI)
myocardial infarction of
inferior wall.
410.41........................ Acute myocardial infarction of 121.19 ST elevation (STEMI) myocardial
other inferior wall, initial infarction involving other
episode of care. coronary artery of inferior
wall.
122.1 Subsequent ST elevation (STEMI)
myocardial infarction of
inferior wall.
410.51........................ Acute myocardial infarction of 121.29 ST elevation (STEMI) myocardial
other lateral wall, initial infarction involving other
episode of care. sites.
122.8 Subsequent ST elevation (STEMI)
myocardial infarction of other
sites.
410.61........................ True posterior wall infarction, 121.29 ST elevation (STEMI) myocardial
initial episode of care. infarction involving other
sites.
122.8 Subsequent ST elevation (STEMI)
myocardial infarction of other
sites.
410.71........................ Subendocardial infarction, 121.4 Non-ST elevation (NSTEMI)
initial episode of care. myocardial infarction.
122.2 Subsequent non-ST elevation
(NSTEMI) myocardial
infarction.
410.81........................ Acute myocardial infarction of 121.21 ST elevation (STEMI) myocardial
other specified sites, initial infarction involving left
episode of care. circumflex coronary artery.
121.29 ST elevation (STEMI) myocardial
infarction involving other
sites.
122.8 Subsequent ST elevation (STEMI)
myocardial infarction of other
sites.
410.91........................ Acute myocardial infarction of 121.3 ST elevation (STEMI) myocardial
unspecified site, initial infarction of unspecified
episode of care. site.
[[Page 271]]
122.9 Subsequent ST elevation (STEMI)
myocardial infarction of
unspecified site.
----------------------------------------------------------------------------------------------------------------
(3) Beginning CABG Episodes
We proposed that, as long as a beneficiary met the general
beneficiary care inclusion criteria, a CABG episode would begin with
the admission of a Medicare beneficiary to an IPPS hospital for a CABG
that is paid under the following CABG MS-DRGs and the specific MS-DRG
would be called the anchor MS-DRG for the episode:
231 (Coronary bypass with percutaneous transluminal
coronary angioplasty (PTCA) with MCC).
232 (Coronary bypass with PTCA without MCC).
233 (Coronary bypass with cardiac catheterization with
MCC).
234 (Coronary bypass with cardiac catheterization without
MCC).
235 (Coronary bypass without cardiac catheterization with
MCC).
236 (Coronary bypass without cardiac catheterization
without MCC).
The proposal for beginning CABG episodes was included in proposed
Sec. 512.240(b)(1). We sought comment on our proposal to begin CABG
episodes.
The following is a summary of the comments received and our
responses.
Comment: One commenter recommended that CMS begin elective CABG
prior to admission for the anchor hospitalization, since all of the
workup prior to an elective CABG happens in the weeks or months before
the hospitalization. The commenter claimed that the patient workup can
vary considerably among providers, which may result in unnecessary
costs. As an example, the commenter stated that a patient could have
every cardiac diagnostic test prior to CABG when only several may be
necessary. To help address unnecessary utilization prior to elective
CABG, the commenter recommended that CMS begin the episode for elective
CABG prior to the hospitalization for surgery.
The commenter further disagreed with CMS' proposal that elective
and urgent CABG would be included in one EPM, because the beneficiaries
behave differently during the episode and with respect to their risk
profiles. The commenter recommended that CMS separate CABG under these
two circumstances into separate EPMs and test both models.
Response: We appreciate the interest expressed by the commenter in
starting CABG episodes prior to the hospital admission, and we
recognize that the beneficiary's care that ultimately leads to the
CABG, including the physician-patient relationship and diagnostic
workup, can begin long before the surgical procedure. However, for
similar reasons to our consideration of analogous comments in the CJR
Final Rule (81 FR 73316 through 73317) regarding LEJR episodes,
beginning the episode too far in advance of the CABG would make it
difficult to avoid bundling unrelated items and services, and starting
the episode prior to the hospital admission is more likely to encompass
costs that vary widely among beneficiaries with CAD that are potential
candidates for CABG, which would make the episode more difficult to
price appropriately. We continue to believe that beginning the CABG
episode with the anchor hospitalization is most appropriate due to the
clinical variability leading up to the CABG and the challenge of
distinguishing between related and unrelated services. We also believe
that beginning the episode with the anchor hospitalization, and not
prior to admission, would be easier to administer and provide more
consistent episodes for testing the CABG model.
Furthermore, we agree with the commenter that beneficiaries
experiencing elective versus urgent CABG behave differently during the
episode due to their different health care needs. However, rather than
creating two EPMs for these beneficiaries for whom we believe the same
CABG episode definition would apply, we are providing a pricing
adjustment as discussed in section III.D.4.b.(2)(b) of this final rule
for CABG model beneficiaries with an AMI diagnosis code on the claim
for the anchor hospitalization who have substantially higher historical
episode spending than CABG model beneficiaries without AMI. The two
groups correspond to the urgent versus elective groups recommended by
the commenter. We believe this pricing adjustment policy accomplishes
the major objective of the commenter who recommended two CABG EPMs so
that we price CABG episodes for the two groups of CABG model
beneficiaries differently based on their different patterns of health
care utilization.
Final Decision: After consideration of the public comments
received, we are finalizing the proposals in Sec. 512.240(b)(1),
without modification, to begin CABG episodes with the admission of a
Medicare beneficiary to an IPPS hospital for a CABG that is paid under
the following CABG MS-DRGs and the specific MS-DRG is called the anchor
MS-DRG for the episode:
231 (Coronary bypass with percutaneous transluminal
coronary angioplasty (PTCA) with MCC).
232 (Coronary bypass with PTCA without MCC).
233 (Coronary bypass with cardiac catheterization with
MCC).
234 (Coronary bypass with cardiac catheterization without
MCC).
235 (Coronary bypass without cardiac catheterization with
MCC).
236 (Coronary bypass without cardiac catheterization
without MCC).
(4) Beginning SHFFT Episodes
We proposed that as long as a beneficiary met the general inclusion
criteria, a SHFFT episode would begin with the admission of a Medicare
beneficiary to an IPPS hospital for surgical treatment of hip or femur
fracture (other than joint replacement) that is paid under the
following SHFFT MS-DRGs and where the specific MS-DRG would be called
the anchor MS-DRG for the episode:
480 (Hip and femur procedures except major joint with
MCC).
481 (Hip and femur procedures except major joint with
complication or comorbidity (CC).
482 (Hip and femur procedures except major joint without
CC or MCC).
The proposal for beginning SHFFT episodes was included in proposed
Sec. 512.240(c)(1). We sought comment on our proposal to begin SHFFT
episodes.
We received no comments specific to our proposal to begin SHFFT
episodes.
Final Decision: We are finalizing the proposals in Sec.
512.240(c)(1), without modification, to begin SHFFT episodes with the
admission of a Medicare beneficiary to an IPPS hospital for
[[Page 272]]
surgical treatment of hip or femur fracture (other than joint
replacement) that is paid under the following SHFFT MS-DRGs and where
the specific MS-DRG is called the anchor MS-DRG for the episode:
480 (Hip and femur procedures except major joint with
MCC).
481 (Hip and femur procedures except major joint with
complication or comorbidity (CC).
482 (Hip and femur procedures except major joint without
CC or MCC).
(5) Special Policies for Hospital Transfers of Beneficiaries With AMI
The asymmetric distribution of cardiac care across hospitals makes
transfer, either from an inpatient admission or from the emergency
department (without inpatient admission) of one hospital to another, a
common consideration in the treatment course for beneficiaries with an
initial diagnosis of AMI. Therefore, transfer for cardiac care is an
important consideration for the AMI and CABG models.
The availability of revascularization and intensive cardiac care
are particularly important considerations in the transfer of
beneficiaries with an AMI. A substantial portion of hospitals do not
have revascularization capability (that is, a cardiac catheterization
lab for PCI or cardiothoracic surgeons who can perform CABG) or
cardiovascular intensive care units (CVICU) and, therefore, must
transfer beneficiaries to provide access to these services. In the PCI
and CABG examples, the discharge from the transfer hospital that
accepted the beneficiary would result in discharge under the MS-DRGs
for PCI (246-251) or CABG (231-236). For the CVICU example, the
transfer hospital's discharge MS-DRG would be AMI (280-282). There is
evidence of the asymmetric distribution of cardiac care in the 2014
IPPS and critical access hospital claims data: While 4,332 hospitals
submitted at least one claim for an AMI MS-DRG, only 1,755 (41 percent)
and 1,156 (27 percent) of these hospitals filed at least one claim for
PCI or CABG MS-DRGs, respectively.\64\
---------------------------------------------------------------------------
\64\ AMI, CABG and PCI MS-DRG inpatient claims from all U.S.
IPPS hospitals and CAHs derived from the 2014 Geographic Variations
Inpatient Claims File located in the Chronic Conditions Warehouse.
---------------------------------------------------------------------------
The potential transfer scenarios are best illustrated by the care
pathways experienced by beneficiaries with AMI. These beneficiaries
typically present to a hospital's emergency department where the
evaluation identifies the AMI diagnosis and determines the initial
indicated treatments. Depending on the beneficiary's clinical needs and
the hospital's treatment capacity, the beneficiary could be--
Admitted to the initial treating hospital, with no
transfer to another hospital during the initial hospitalization for
AMI. We refer to this scenario as no transfer;
Admitted to the initial treating hospital and later
transferred to a transfer hospital. We refer to this scenario as
inpatient-to-inpatient transfer and the transfer hospital as an i-i
transfer hospital; or
Transferred from the initial treating hospital to a
transfer hospital without admission to the initial treating hospital.
We refer to this scenario as outpatient-to-inpatient transfer and the
transfer hospital as an o-i transfer hospital.
Our proposals and alternatives considered for these scenarios are
described in detail in this section. In our proposals for AMI or CABG
episodes for initial AMI care, our overarching policy was that every
AMI or CABG episode would begin at the first AMI or CABG model
participant to which the beneficiary was admitted for an AMI MS-DRG,
PCI MS-DRG with an AMI ICD-CM diagnosis code, or CABG MS-DRG. The AMI
or CABG model participant where the episode began would then be
financially responsible for the AMI or CABG episode unless the episode
was canceled.
Based on our analysis of Medicare claims data, in the proposed rule
(81 FR 50836) we presented the finding that about 75 percent of
historical AMI episodes and CABG episodes for beneficiaries with AMI
began through the emergency department of the hospital where the anchor
hospitalization for the AMI or CABG episode would occur. In another 18
percent of historical AMI episodes and CABG episodes for beneficiaries
with AMI, the anchor hospitalization occurred at a transfer hospital
following an emergency department visit at another hospital without
admission to that hospital for an MS-DRG that would initiate an AMI or
CABG episode.\65\
---------------------------------------------------------------------------
\65\ Episode for beneficiaries with AMI initiated by all U.S.
IPPS hospitals and constructed using standardized Medicare FFS Parts
A and B claims, as proposed in the proposed rule, that end in CY
2014.
---------------------------------------------------------------------------
In each of these scenarios, policies to determine which episode
type would apply, the beginning of the episode, and the specific
hospital with financial responsibility for the episode must be
determined (for example, AMI or CABG, if CABG is provided as an initial
treatment in an outpatient-to-inpatient or inpatient-to-inpatient
scenario). In the proposed rule, we discussed each of the scenarios in
detail and provide a summary of the scenarios in Table 7.
In the no transfer scenario, the episode would begin upon admission
to an AMI or CABG model participant under circumstances that meet the
criteria discussed in sections III.C.4.a.(1) and (2) or (3) of the
proposed rule (81 FR 50847 through 50848), and the AMI or CABG episode
that applied would be determined by the specific MS-DRG for the anchor
hospitalization. Financial responsibility for the episode would be
attributed to the sole treating hospital involved in the initial AMI
care. Under this proposal, the treating hospital's quality measure
performance would determine the effective discount factor to be applied
to the AMI or CABG model benchmark episode price for the episode at
reconciliation as described in section III.D.4.b.(10) of the proposed
rule (81 FR 50861 through 50862).
The inpatient-to-inpatient transfer scenario had several potential
outcomes. If the beneficiary initially presented for AMI care to a
hospital that was not an AMI model participant and was admitted and
then transferred to an i-i transfer hospital that was an AMI or CABG
model participant, the episode would first initiate at the i-i transfer
hospital and, therefore, the i-i transfer hospital would be financially
responsible for the AMI or CABG episode. The i-i transfer hospital's
quality measure performance would determine the effective discount
factor to be applied to the AMI or CABG model benchmark episode price
for the episode at reconciliation as described in section
III.D.4.b.(10) of the proposed rule (81 FR 50861 through 50862).
If a beneficiary initially presented for AMI care to an AMI model
participant and was admitted and then transferred to an i-i transfer
hospital (hereinafter a chained anchor hospitalization) and the i-i
transfer hospital was not an AMI or CABG model participant, the episode
would initiate at the initial treating hospital and would only be
canceled for beneficiaries discharged from the i-i transfer hospital
under MS-DRGs that were not anchor MS-DRGs for AMI or CABG episodes as
discussed in section III.C.4.b. of the proposed rule (81 FR 50841
through 50842). The initial treating hospital's quality measure
performance would determine the effective discount factor to be applied
to the AMI or CABG model benchmark episode price for the episode at
reconciliation as described in section III.D.4.b.(10) of the proposed
rule (81 FR 50861 through 50862). We also refer to section
III.D.4.b.(2)(a) of the proposed rule (81 FR 50849 through 50851) for
[[Page 273]]
further discussion of our proposal for price MS-DRGs that could differ
from the anchor MS-DRG in AMI episodes that included a chained anchor
hospitalization, in order to provide pricing adjustments for episodes
where the initial treating hospital was responsible for the AMI
episode.
Inpatient-to-inpatient transfers between AMI and CABG model
participant hospitals were further considered in this section and
specifically included beneficiaries experiencing an AMI who were
transferred for revascularization (that is, PCI or CABG) or a higher
level of medical AMI care. We noted that of all beneficiaries
experiencing an AMI in historical episodes, about half received no
revascularization (PCI or CABG) during the anchor hospitalization or
the 90-day post-hospital discharge period, about 40 percent received a
PCI, and less than 10 percent had CABG surgery.\66\ Moreover, three-
quarters of CABG procedures and over 90 percent of PCIs for
beneficiaries experiencing an AMI occurred at the hospital that first
admitted the beneficiary for an inpatient hospitalization.\67\
---------------------------------------------------------------------------
\66\ Episodes for beneficiaries with AMI initiated by all U.S.
IPPS hospitals and constructed using standardized Medicare FFS Parts
A and B claims, as proposed in the proposed rule, that end in CY
2014.
\67\ Episodes for beneficiaries with AMI initiated by all U.S.
IPPS hospitals and constructed using standardized Medicare FFS Parts
A and B claims, as proposed in the proposed rule, that end in CY
2014.
---------------------------------------------------------------------------
However, given the asymmetric distribution of cardiac care
capacity, we noted in the proposed rule (81 FR 50837) that there would
be beneficiaries who initiated an AMI episode by admission to an
initial treating hospital but then required transfer to an i-i transfer
hospital for additional treatment during the AMI episode, resulting in
a chained anchor hospitalization. For historical AMI episodes ending in
CY 2014, only about 12 percent of beneficiaries who would have
initiated an AMI episode through admission and assignment to an AMI MS-
DRG at the initial treating hospital were transferred to an i-i
transfer hospital, with 30 percent and 20 percent receiving PCI or
CABG, respectively, at the i-i transfer hospital. Another 20 percent
were discharged from the i-i transfer hospital in the chained anchor
hospitalization under an AMI MS-DRG. The remaining 30 percent of
beneficiaries were discharged from the i-i transfer hospital in the
chained anchor hospitalization under other MS-DRGs that would not have
initiated AMI or CABG episodes, including cardiac valve surgery,
septicemia, and renal failure. From the perspective of hospital
capacity and transfer patterns, most hospitals transferred less than 10
percent of beneficiaries initiating a historical AMI episode under an
AMI MS-DRG at the first admitting hospital, and only a handful of
hospitals transferred the majority of their patients in this
scenario.\68\ This small number of hospitals that transferred the
majority of their patients included a range of urban and rural
hospitals with 50 to 250 beds.
---------------------------------------------------------------------------
\68\ Episodes for AMI beneficiaries initiated by all U.S. IPPS
hospitals and constructed using standardized Medicare FFS Parts A
and B claims, as proposed in the proposed rule, that end in CY 2014.
---------------------------------------------------------------------------
The need to transfer a beneficiary in an AMI episode during the
anchor hospitalization for appropriate care that resulted in a chained
anchor hospitalization where the hospitals were both AMI or CABG model
participants raised considerations about whether attribution of the AMI
episode should be to the first treating hospital that admitted the
beneficiary or the i-i transfer hospital, as well as considerations
about the specific model (AMI or CABG) for attribution of the episode
in some circumstances. For example, if the first treating hospital
initiated an AMI episode by admitting a beneficiary and then
transferred the beneficiary to another hospital where the beneficiary
was treated and ultimately discharged from acute care, ending the
chained anchor hospitalization under a CABG MS-DRG, then we needed to
determine whether the beneficiary would be included in the AMI or CABG
model, which hospital would assume financial responsibility for the
beneficiary's episode, and under what circumstances, if any, would the
AMI episode be canceled if a transfer occurred.
In considering the model episode that would include the
beneficiary's care and accountability for the beneficiary in inpatient-
to-inpatient transfer scenarios between AMI and CABG model participant
hospitals that resulted in a chained anchor hospitalization for AMI,
several factors were relevant, including the timing of final discharge
disposition of the beneficiary, including to post-acute care; the
location of the post-acute care; the identity and location of the
physician who was most responsible for managing the beneficiary's care
after discharge; and consistency with other CMS transfer policies. We
noted in the proposed rule (81 FR 50837) that while 64 percent of CABG
beneficiaries in historical episodes received post-acute care services
following discharge from the anchor hospitalization (most commonly home
health services--43 percent received home health services only and 13
percent a combination of home health and SNF services), only 36 percent
of historical AMI beneficiaries received post-acute services.\69\ Of
further relevance for beneficiaries with an AMI diagnosis was that
significant follow up care was usually performed by cardiologists who
managed the patient's underlying cardiovascular disease, rather than
the interventional cardiologist or cardiothoracic surgeon that
performed the revascularization procedure. PCI procedures, billed by
interventional cardiologists, have a 0-day global period, reflecting
that follow up care is not typically furnished by interventional
cardiologists. We further noted that patients in commercial programs
that require travel to regional centers of excellence for CABG
generally only stay in the remote location away from the patient's home
for a week or so post-hospital discharge. We expected that
beneficiaries hospitalized for treatment of AMI, even if they were
transferred to a revascularization hospital resulting in a chained
anchor hospitalization, would receive most follow up care in their
local communities, a view that was supported by many commenters on the
CJR model proposed rule who believed that many patients requiring post-
acute care prefer to return to their home communities for that care
following hospital discharge (80 FR 23457). Finally, consistency across
other CMS program policies when a beneficiary with an AMI experienced
an inpatient-to-inpatient transfer was relevant to developing policies
for the AMI and CABG models. Specifically, we noted that the Hospital-
Level, Risk-Standardized Payment Associated with a 30-Day Episode of
Care for AMI (NQF #2431) measure used in the hospital value-based
purchasing (HVBP) Program attributes payments for transferred
beneficiaries to the hospital that admitted the patient for the initial
AMI hospitalization.\70\
---------------------------------------------------------------------------
\69\ Episodes for AMI and CABG beneficiaries initiated by all
U.S. IPPS hospitals and constructed using standardized Medicare FFS
Parts A and B claims, as proposed in the proposed rule, that end in
CY 2014.
\70\ https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/HospitalQualityInits/Measure-Methodology.html.
---------------------------------------------------------------------------
Based on these considerations, we proposed that once an AMI episode
was initiated at an AMI model participant hospital through an inpatient
hospitalization, the AMI episode would continue under the financial
responsibility of that participant hospital, regardless of whether the
[[Page 274]]
beneficiary was transferred to another AMI or CABG model participant
hospital for further medical management of AMI, or for a PCI or CABG
during a chained anchor hospitalization. Under this proposal, the
initial treating hospital's quality measure performance would determine
the effective discount factor to be applied to the AMI model benchmark
episode price for the episode at reconciliation as described in section
III.D.4.b.(10) of the proposed rule (50861 through 50862) rule. Our
proposal to cancel AMI episodes for beneficiaries discharged from the
i-i transfer hospital under MS-DRGs that were not anchor MS-DRGs for
AMI or CABG episodes was discussed in section III.C.4.b. of the
proposed rule (81 FR 50841 through 50842). We also referred to section
III.D.4.b.(2)(a) of the proposed rule (81 FR 50849 through 50851) for
further discussion of the proposal for price MS-DRGs that could differ
from the anchor MS-DRG in AMI episodes that included a chained anchor
hospitalization, in order to provide pricing adjustments for episodes
where the initial treating hospital was responsible for the AMI
episode.
In the proposed rule (81 FR 50838), we noted that we did not
propose to cancel the AMI episode even if the transfer and admission to
the i-i transfer hospital would otherwise initiate a CABG episode at
the i-i transfer hospital. We believed that once the AMI episode had
been initiated, all related care during the episode (including hospital
care for transfers and related readmissions for CABG) should be fully
attributed to the AMI episode in the manner described in this section
for the episode and that the first hospital that initiated the AMI
episode should be financially responsible for the AMI episode.
Therefore, we did not propose to cancel the AMI episode if a CABG was
performed during a chained anchor hospitalization, nor did we propose
that a beneficiary could simultaneously be in an AMI and CABG episode
for overlapping periods of time due to the different MS-DRGs that
applied during the chained anchor hospitalization. Instead, we would
make an AMI episode pricing adjustment for these circumstances by
paying the AMI model participant based on a price MS-DRG that was
different from the anchor MS-DRG to reflect Medicare payment for the
CABG as discussed in section III.D.4.b.(2)(a) of the proposed rule (81
FR 50849 through 50851).
We considered several alternatives to our proposal for AMI episode
attribution for inpatient-to-inpatient transfer scenario where both
hospitals are AMI or CABG model participants. First, we considered
canceling the AMI episode initiated at the initial treating hospital
when a transfer occurs, and basing any AMI or CABG episode initiation
on the MS-DRG for the final i-i transfer hospital admission in the
chained anchor hospitalization as long as that latter hospital was an
AMI or CABG model participant. This would place financial
responsibility for the episode on the i-i transfer hospital if the
beneficiary went on to be discharged from acute care at that hospital.
Attributing episodes under this alternative policy would assign
beneficiaries to the final i-i transfer hospital for the AMI or CABG
episode based on the model episode definitions in sections
III.C.4.a.(2) and (3) of the proposed rule (81 FR 50834 through 50835).
That is, if the beneficiary was discharged from the final admission in
the chained anchor hospitalization under an AMI MS-DRG or a PCI MS-DRG,
then the AMI episode initiated at the initial treating hospital would
be canceled and the i-i transfer hospital accepting the beneficiary on
referral would initiate an AMI episode. Similarly, if the beneficiary
was discharged from the final admission in the chained anchor
hospitalization under a CABG MS-DRG, then the AMI episode initiated at
the first hospital would be canceled and the i-i transfer hospital
accepting the beneficiary on referral would initiate a CABG episode.
Under this alternative, the i-i transfer hospital's quality measure
performance would determine the effective discount factor to be applied
to the AMI or CABG model benchmark episode price for the episode at
reconciliation as described in section III.D.4.b.(10) of the proposed
rule (81 FR 50861 through 50862). However, we did not propose this
alternative because we believed that post-acute care and care
management following hospital discharge would be more likely to be
effectively provided near the beneficiary's home community, rather than
near the i-i transfer hospital accepting the beneficiary upon referral.
Second, we considered proposing an episode hierarchy such that,
during a chained anchor hospitalization, the most resource-intensive
MS-DRG during the whole chained anchor hospitalization would determine
the model episode and the financially responsible hospital for the
episode. For example, if we established CABG, PCI, and AMI MS-DRGs in
descending order of inpatient hospital resource-intensity, we would
initiate a model episode based on the most resource-intensive MS-DRG
during the chained anchor hospitalization and attribute the model
episode to the hospital discharging the beneficiary under that MS-DRG.
Under this scenario, either the initial treating or i-i transfer
hospital's quality measure performance would determine the effective
discount factor to be applied to the AMI or CABG model benchmark
episode price for the episode at reconciliation as described in section
III.D.4.b.(10) of the proposed rule (81 FR 50861 through 50862),
depending on the specific hospital discharging the beneficiary under
the most resource-intensive MS-DRG during the chained anchor
hospitalization. However, we did not propose this alternative because
we believed, like the first alternative we considered, this could
frequently lead to episode responsibility being attributed to the i-i
transfer hospital when the local hospital first caring for the
beneficiary with AMI may be better positioned to coordinate care in the
beneficiary's home community.
Thus, our proposal would have placed responsibility for care during
the 90-day post-hospital discharge period in the AMI episode on the AMI
model participant hospital to which the beneficiary initially presented
for AMI care and was admitted, rather than on the i-i transfer hospital
to which the beneficiary was transferred after initiating the AMI
episode. Given the broad episode definition of AMI episodes, we
believed that the post-discharge care required following
hospitalization that included CABG, PCI, or medical management was best
coordinated and managed by the hospital that originally admitted the
beneficiary for the AMI. Such post-discharge care could include follow
up for adherence to cardiac rehabilitation referral and management of
the beneficiary's underlying CAD and comorbidities. Even in the case of
the more common surgical complications of CABG, such as wound
infection, the beneficiary commonly would be admitted to the local
hospital for treatment.
We further proposed that, as discussed in section III.I.3. of the
proposed rule (81 FR 50918 through 50920), hospitals could be
collaborators in the AMI, CABG, and SHFFT models in order to increase
the financial alignment of hospitals and other EPM collaborators with
EPM participants that were financially responsible for EPM episodes.
Therefore, we expected that community hospital participants in the AMI
model would be able to enter into sharing arrangements with i-i
transfer hospitals accepting AMI model beneficiaries on referral to
allow sharing of episode reconciliation payments or
[[Page 275]]
repayment responsibility with the i-i transfer hospitals if those
hospitals played a significant role in care redesign of AMI or CABG
care pathways or management of beneficiaries throughout AMI or CABG
episodes, including during the 90 days post-hospital discharge. We
expected that community hospitals would need to coordinate closely with
i-i transfer hospitals accepting AMI model beneficiaries on referral as
the beneficiaries in AMI episodes were discharged from those hospitals,
in order to improve the quality and efficiency of AMI episodes. This
coordination could potentially be enhanced if i-i transfer hospitals
were AMI model collaborators with financial incentives that were
aligned with those of the AMI model participants through sharing
arrangements.
The proposal for AMI episode attribution in circumstances that
involve inpatient-to-inpatient transfers of beneficiaries with AMI was
included in proposed Sec. 512.240(a)(2). We sought comment on our
proposal for AMI episode attribution in circumstances that involved
inpatient-to-inpatient transfers of beneficiaries with AMI, including
comment on the alternatives considered.
In the outpatient-to-inpatient transfer scenario where a
beneficiary with AMI was transferred from the emergency department of
the initial treating hospital without admission to that hospital as an
inpatient to an o-i transfer hospital for admission, we proposed that
the AMI or CABG episode would begin at the o-i transfer hospital based
on the MS-DRG (and AMI ICD-CM diagnosis code if a PCI MS-DRG applies)
that was assigned to that anchor hospitalization. That is, if a
beneficiary received initial AMI care in a hospital emergency
department without admission and was transferred to an AMI or CABG
model participant (the o-i transfer hospital) for admission, then the
AMI or CABG episode would begin in the first hospital involved in the
beneficiary's AMI or CABG care that admitted the beneficiary as an
inpatient, specifically the o-i transfer hospital. Therefore, the o-i
transfer hospital would be financially responsible for the AMI or CABG
episode. This attribution was in accordance with the AMI and CABG model
rules, as discussed in sections III.C.4.a.(2) and (3) of the proposed
rule (81 FR 50834 through 50835), that initiated an AMI episode with a
hospitalization that results in discharge from an AMI MS-DRG or PCI MS-
DRG with an AMI ICD-CM diagnosis code in the principal or secondary
position from an AMI model participant or a CABG episode with a
hospitalization that resulted in discharge from a CABG MS-DRG. Under
this proposal, the o-i transfer hospital's quality measure performance
would determine the effective discount factor to be applied to the AMI
or CABG model benchmark episode price for the episode at reconciliation
as described in section III.D.4.b.(10) of the proposed rule (81 FR
50861 through 50862). Under this proposal, regardless of whether the
initial treating hospital was an AMI or CABG model participant, an AMI
or CABG episode would only be initiated at the o-i transfer hospital if
that hospital was an AMI or CABG model participant.
We considered an overarching alternative policy that would begin
every AMI or CABG episode at the first AMI or CABG model participant at
which either:
The beneficiary presented to the emergency department for
initial AMI care before being transferred to an o-i transfer hospital;
or
The beneficiary was admitted for an AMI MS-DRG, PCI MS-DRG
with an AMI ICD-CM diagnosis code, or a CABG MS-DRG.
The AMI or CABG model participant where the episode began would
then be financially responsible for the AMI or CABG episode unless the
episode was canceled. Under this alternative, there would no changes to
our proposals for attributing episodes with no transfers or inpatient-
to-inpatient transfers.
However, under this alternative, if the beneficiary presented for
initial AMI care to the emergency department of an AMI or CABG model
participant, the AMI or CABG episode would begin at this initial
treating hospital when a beneficiary was transferred from the emergency
department for his or her first inpatient hospitalization which
occurred at an o-i transfer hospital. This would place financial
responsibility for the AMI or CABG episode on the initial treating
hospital despite the fact that the beneficiary was transferred from
that hospital without being admitted, and the initial treating
hospital's quality measure performance would determine the effective
discount factor to be applied to the AMI or CABG model benchmark
episode price for the episode at reconciliation as described in section
III.D.4.b.(10) of the proposed rule (81 FR 50861 through 50862).
Identifying the emergency department visit at the initial treating
hospital would require using Field (Form Locator) 15--Point of Origin
for Admission or Visit code on the CMS 1450 IPPS claim from the o-i
transfer hospital to identify transfer from another hospital and
linking that claim to the hospital outpatient claims from the initial
treating hospital for the emergency department visit and other hospital
outpatient services that occurred within a certain period of time prior
to the o-i transfer hospital admission and that were related to the AMI
care. The episode would be assigned to the AMI model even if the
beneficiary received a CABG at the o-i transfer hospital, and we would
assign financial responsibility for the AMI episode to the initial
treating hospital. Under this alternative, the initial treating
hospital's quality measure performance would determine the effective
discount factor to be applied to the AMI model benchmark episode price
for the episode at reconciliation as described in section
III.D.4.b.(10) of the propose rule (81 FR 50861 through 50862). We
would also need to identify other types of related services to include
in the episode that would begin prior to the o-i transfer hospital
admission, such as physicians' services for care in the emergency
department.
This alternative would have had the benefit of consistently
including all care in each AMI or CABG episode that occurred following
presentation of a beneficiary with AMI to the emergency department of
an AMI or CABG model participant to the AMI or CABG episode, regardless
of whether an AMI or CABG episode involved no transfer, o-i transfer,
or i-i transfer. However, because this alternative would have begun the
AMI episode prior to the initial hospital admission, we would have
needed to establish additional policies for identifying the
beneficiaries who initiated these episodes and defined the timeframe
and services that would have been included in the AMI or CABG episode
prior to admission to the o-i transfer hospital.
We did not propose this alternative because we believed the
policies necessary to begin the AMI or CABG episode at the first
treating hospital when an inpatient hospitalization did not occur would
be complex, challenging to operationalize, and required assumptions
about the relationship of care to the AMI based solely on
administrative claims data that were insufficient to ensure we could
accurately identify related care. We believed it remained problematic
to define the services to be included in AMI or CABG episodes if those
services preceded an inpatient hospitalization that would otherwise
initiate the AMI or CABG episode. For example, we would need to define
the timeframe for beginning an AMI or CABG episode with an emergency
department visit for AMI that resulted in a transfer to the o-
[[Page 276]]
i transfer hospital, as well as the Part A and Part B services to be
included in the AMI or CABG episode that would result. As we discussed
in section III.C.4.a.(1) of the proposed rule (81 FR 50834), we did not
propose to begin any EPM episode prior to the anchor hospitalization
because of the clinical variability leading up to all EPM episodes and
the challenge of identifying unrelated services prior to the inpatient
hospitalization. Thus, we did not propose to make an exception for
transfers from the emergency department of the initial treating AMI or
CABG model participant hospital when the beneficiary with AMI was not
admitted to that hospital.
We sought comment on the proposal for AMI and CABG episode
initiation and attribution for the outpatient-to-inpatient transfer
scenario, as well as the alternative considered that would begin an
episode upon presentation of a beneficiary for initial AMI care to the
emergency department of an AMI or CABG model participant when the care
resulted in an outpatient-to-inpatient transfer.
Table 7 included in the proposed rule (81 FR 50840) provided a
summary of episode initiation and attribution at the beginning of AMI
care for no transfer, inpatient-to-inpatient transfer, and outpatient-
to-inpatient transfer scenarios, including a description of how these
related to the participation in the AMI or CABG models of hospitals
providing initial AMI care.
Table 7--Proposed Initiation and Attribution of AMI and CABG Episodes
That Involve No Transfer, or Outpatient-to-Inpatient or Inpatient-to-
Inpatient Transfers at the Beginning of AMI Care
------------------------------------------------------------------------
Proposed episode initiation and
Scenario attribution
------------------------------------------------------------------------
No transfer (participant): Beneficiary Initiate AMI or CABG episode
admitted to an initial treating based on anchor
hospital that is a participant in the hospitalization MS-DRG.
AMI or CABG model for an AMI MS-DRG, Attribute episode to the
PCI MS-DRG with AMI ICD-CM diagnosis initial treating hospital.
code, or CABG MS-DRG.
No transfer (nonparticipant): No AMI or CABG episode is
Beneficiary admitted to an initial initiated.
treating hospital that is not a
participant in the AMI or CABG model
for an AMI MS-DRG, PCI MS-DRG with AMI
ICD-CM diagnosis code, or CABG MS-DRG.
Inpatient-to-inpatient transfer Initiate AMI or CABG episode
(nonparticipant to participant): based on the MS-DRG at i-i
Beneficiary admitted to an initial transfer hospital.
treating hospital that is not an AMI Attribute episode to the i-i
or CABG model participant and later transfer hospital.
transferred to an i-i transfer
hospital that is an AMI or CABG model
participant for an AMI MS-DRG, PCI MS-
DRG with AMI ICD-CM diagnosis code, or
CABG MS-DRG.
Inpatient-to-inpatient transfer Initiate AMI or CABG episode
(participant to participant or based on anchor
participant to nonparticipant): hospitalization MS-DRG at
Beneficiary admitted to an initial initial treating hospital. If
treating hospital that is an AMI or the chained anchor
CABG model participant for an AMI MS- hospitalization results in a
DRG, PCI MS-DRG with AMI ICD-CM final AMI, PCI, or CABG MS-
diagnosis code, or CABG MS-DRG and DRG, calculate episode
later transferred to an i-i transfer benchmark price based on the
hospital for an AMI, PCI, or CABG MS- AMI, PCI or CABG MS-DRG with
DRG, regardless of whether the i-i the highest IPPS weight. If
transfer hospital is an AMI or CABG the final MS-DRG is not an
model participant. AMI, PCI, or CABG MS-DRG,
cancel the episode. Attribute
episode to the initial
treating hospital.
Outpatient-to-inpatient transfer Initiate AMI or CABG episode
(nonparticipant to participant or based on anchor
participant to participant): hospitalization MS-DRG at o-i
Beneficiary transferred without transfer hospital. Attribute
admission from the initial treating episode to the o-i transfer
hospital, regardless of whether the hospital.
initial treating hospital is an AMI or
CABG model participant, to a o-i
transfer hospital that is an AMI or
CABG model participant and is
discharged from the o-i transfer
hospital for an AMI MS-DRG, PCI MS-DRG
with AMI ICD-CM diagnosis code, or
CABG MS-DRG.
Outpatient-to-inpatient transfer No AMI or CABG episode is
(participant to nonparticipant): initiated.
Beneficiary transferred without
admission from the initial treating
hospital that is an AMI or CABG
participant to an o-i transfer
hospital that is not an AMI or CABG
model participant.
------------------------------------------------------------------------
The following is a summary of the comments received and our
responses.
Comment: A number of commenters expressed support for the proposed
AMI model transfer episode initiation and attribution policy that would
initiate an AMI episode under the responsibility of an initial treating
hospital that is an AMI model participant where the beneficiary is
assigned to an AMI MS-DRG or PCI MS-DRG with AMI ICD-CM diagnosis code
and the beneficiary is later transferred to another hospital and
ultimately discharged from an AMI, PCI, or CABG MS-DRG. One commenter
further recommended that CMS consider implementing this policy in the
BPCI initiative and future episode payment models that are under
development. Several commenters stressed the importance of
beneficiaries receiving rehabilitation services in their home
communities to improve adherence to the treatment plan, and
acknowledged that CMS' AMI model transfer attribution proposal would
encourage this care pattern. Another commenter pointed out that CMS
should differentiate patient-directed presentation with AMI at a
hospital emergency department versus emergency medical services-
directed delivery to the hospital emergency department. The commenter
explained that the usual practice in the case of STEMI identified in
the field by emergency medical services would be to transport the
beneficiary to a hospital with appropriate capacity to avoid any need
for transfer that could delay treatment and impair outcomes. The
commenter added that the trend nationally for emergency medical
services delivery of patients with an AMI is for the patient to be
taken to a facility that is capable of managing that patient rather
than taking them to the closest hospital. Thus, the commenter believes
the transfer issues should be only applicable to the minority of
beneficiaries who present to the emergency department under their own
power.
Other commenters who supported the proposed AMI model transfer
episode initiation and attribution policy, including the proposal to
cancel
[[Page 277]]
episodes that contain a chained anchor hospitalization with a final
discharge MS-DRG that is not an AMI, PCI, or CABG MS-DRG, however
expressed concern that the proposal for a price MS-DRG payment
adjustment does not go far enough to provide a level playing field for
AMI episodes involving a chained anchor hospitalization. One of these
commenters presented analysis showing that while only a minority of
episodes involving a chained anchor hospitalization resulted in a final
discharge MS-DRG other than an AMI, PCI, or CABG MS-DRG, the episode
costs were very high in those cases because they were atypical. The
commenter concluded that CMS' proposal to cancel these episodes was
appropriate.
Additional analysis by the commenter demonstrated that hospitals
that transfer AMI beneficiaries frequently are more likely to be
smaller community hospitals with much higher episode spending, who
would be penalized by the lack of a more robust transfer-adjustment
methodology just because they do not have the most sophisticated
cardiac care available. Several commenters stated that these hospitals
often have no choice but to transfer their most complicated patients to
larger, tertiary hospitals so that the patients can receive the most
appropriate cardiac care and that hospitals should not be penalized for
doing so. These commenters requested that CMS exclude the IPPS amount
paid to the initial admitting hospital when calculating quality-
adjusted target prices and actual episode spending to put these
hospitals on a more level playing field with larger referral hospitals
that offer comprehensive cardiac care in order to encourage the best
provision of care to beneficiaries in AMI episodes. Additionally, the
commenters recommended that CMS provide additional explanation of the
framework for chained anchor hospitalizations in the final rule and
include illustrative examples about how the methodology works.
One commenter expressed support for the second of the two
alternatives considered by CMS for attributing AMI episodes in
inpatient-to-inpatient transfer scenarios that would begin an AMI
episode and assign episode responsibility to the hospital in the
chained anchor hospitalization discharging the beneficiary under the
most resource-intensive MS-DRG according to a hierarchy of CABG, PCI,
and AMI MS-DRGs in descending order of inpatient hospital resource-
intensity. The commenter reasoned that in comparison with CMS'
proposal, this approach would provide a more direct association in the
transfer policy between hospital episode responsibility and the
hospital providing the highest level of care for the beneficiary with
AMI during the chained anchor hospitalization. The commenter stated
that if a hospital admits a beneficiary but then has to transfer the
beneficiary to another hospital for more advanced cardiac care that the
initial treating hospital cannot provide, it does not seem reasonable
to make that initial hospital responsible for all follow up care post-
discharge for that condition.
The majority of commenters opposed CMS' proposed AMI model transfer
episode initiation and attribution policy, with the majority addressing
the inpatient-to-inpatient transfer scenario where the initial treating
hospital and the i-i transfer hospital are both AMI and CABG model
participants. In general, the commenters believe the inpatient-to-
inpatient transfer proposal was too complex and would be unmanageable
for EPM participants. They stated that while CMS partially predicated
its AMI model transfer episode initiation and attribution proposal on
public input on the CJR model that beneficiaries often prefer to
receive follow up care after hospital discharge in their community, the
AMI and CABG models are sufficiently different from the CJR model that
this perspective may not apply to the proposed models. In the AMI and
CABG models, the commenters emphasized that beneficiaries would be more
likely to require emergent care and, therefore, have less of an
opportunity to seek care from a facility located outside of their
region. Thus, the commenters believe that many AMI model beneficiaries
experiencing a chained anchor hospitalization during their initial
hospital treatment for AMI would remain in the same region as the i-i
transfer hospital for post-acute care services, in contrast to
primarily elective LEJR under the CJR model where procedures may be
planned in advance and involve farther travel for the surgery. Thus,
the commenters reasoned that the initial treating hospital and the i-i
transfer hospital caring for a beneficiary in an AMI episode would be
likely to be in the same region as one another and the beneficiary's
home community. Thus, they concluded that CMS' interest in AMI model
attribution policy for inpatient-to-inpatient transfers that could
support beneficiary follow up in their own community following
discharge could be met equally well through AMI episode attribution to
the i-i transfer hospital as to the initial treating hospital.
Therefore, for inpatient-to-inpatient transfer scenarios for AMI
model beneficiaries, many commenters who disagreed with CMS' proposal
recommended CMS to adopt the first alternative considered for i-i
transfers once an AMI episode is initiated at the initial treating
hospital. Consistent with CMS' discussion of this alternative
considered in the proposed rule (81 FR 50838), the commenters
encouraged CMS to cancel the AMI episode initiated at the initial
treating hospital every time an inpatient-to-inpatient transfer occurs,
and base any AMI or CABG episode initiation on the MS-DRG for the final
i-i transfer hospital admission in the chained anchor hospitalization
if the i-i transfer is an AMI or CABG model participant. This would
place financial responsibility for the episode on the i-i transfer
hospital if the beneficiary went on to be discharged from acute care at
that hospital and the hospital was an AMI or CABG model participant.
The commenters claimed this approach would greatly simplify the
initiation, attribution, and pricing methodologies under the AMI and
CABG models.
The commenters favoring AMI episode initiation and episode
assignment to the i-i transfer hospital contended that CMS' proposal to
assign AMI episode responsibility to the initial treating hospital
could encourage the initial treating hospital to either prematurely
transfer patients who present to the emergency department with symptoms
of AMI or not transfer AMI patients at all to retain control of the
episode and its associated costs. The commenters speculated that while
these hospital responses could be clinically appropriate, it is unclear
whether this would be the best approach for beneficiaries and whether
long-term this type of transfer policy within the AMI model could
reduce the capacity of small and rural hospitals to effectively manage
care for cardiac patients, while creating an overreliance on larger
hospitals.
The commenters stated that CMS' proposal placed too much importance
on the role of the local hospital and physicians associated with the
initial AMI treatment and too little importance on the role of the
hospital providing the majority of the AMI care. They maintained that
the i-i transfer hospital would be more likely to influence the post-
discharge plan and post-acute care the beneficiary receives and would
be in a better position to retain financial responsibility for the
beneficiary and assume final risk for the EPM episode. The commenters
claimed that it is the
[[Page 278]]
discharging i-i transfer hospital that would develop the discharge
plan; make recommendations on the type of post-acute care services
necessary and make arrangements with specific post-acute care
providers; schedule follow up appointments; educate the beneficiary and
caregivers about the beneficiary's clinical condition; and communicate
post-discharge instructions.
In addition, several commenters pointed out that the initial
treating hospital may not know the beneficiary's final MS-DRG until
days after discharge from the i-i transfer hospital. They stated that
this time lag makes it problematic to assign episode responsibility to
the initial treating hospital because that hospital would not be able
to identify and intervene with AMI model beneficiaries prior to their
discharge from acute care, a care redesign strategy that the commenters
believe is important for AMI model success. Some commenters stated that
CMS failed to appreciate the complexity of accurate beneficiary
identification and its impact on facilitating effective post-acute care
services in the proposed AMI model transfer policy.
A number of commenters recognized CMS' intent to link transferring
hospitals with larger, tertiary hospitals through the AMI model
transfer episode initiation and attribution proposal in order to
strengthen the quality and efficiency of health care within
communities. The commenters agreed that there needs to be increased
communication and collaboration among these hospitals in order to
achieve better patient outcomes, yet they also believe that ongoing
challenges with the timely communication of beneficiary information
among providers and the current competitive healthcare landscape are
not conducive to this type of collaboration.
In general, many commenters expressed concern that the complexity
of the AMI model's proposed transfer attribution policies and the
potential resulting confusion about beneficiary notification and
hospital episode responsibility in an environment that lacks
established electronic tracking programs that can communicate among
many hospitals in different systems. Several commenters believe the
proposed policy could focus an AMI model participant's limited
resources on administrative issues that do not actually improve care
and reduce episode costs for AMI beneficiaries. They stated that
hospital time and resources would be better spent improving care,
developing sharing arrangements among providers, and tracking
beneficiary outcomes. The commenters emphasized that this is especially
true since transfers are expected to occur in a small minority of AMI
episodes.
The majority of commenters also expressed various concerns about
potential beneficiary harm due to AMI model transfer policies under an
EPM, whether those proposed or recommended by some of the commenters,
that would establish new financial incentives for hospitals around
transfers for beneficiaries with AMI in the absence of clear best
transfer practices for hospitals with varying levels of cardiac care
capacity. The commenters claimed that CMS' proposal did not include
sufficient protections against EPM participants engaging in adverse
patient selection to improve quality and cost performance in each type
of transfer scenario (no transfer, outpatient-to-inpatient, and
inpatient-to-inpatient). The commenters believe that inappropriate
transfers and cost-shifting among competitors in a geographic market
could occur under the AMI model, and they recommended to CMS to provide
robust patient protections and transfer methodologies in the final
rule.
Most commenters expressed support for CMS' proposal to initiate AMI
episodes upon admission to the o-i transfer hospital in an outpatient-
to-inpatient transfer scenario, as well as attribute responsibility for
the episode to the o-i transfer hospital. The commenters agreed with
CMS that this approach would not require potentially flawed assumptions
about the relatedness of services preceding the hospital admission and,
therefore, would result in clearly defined AMI episodes. However,
several commenters recommended CMS to address the operational issues
identified in the proposed rule (81 FR 50839) related to outpatient-to-
inpatient transfers that would not allow CMS to begin AMI episodes when
an initial treating hospital provides only outpatient emergency care
prior to transfer to an o-i transfer hospital. The commenters believe
it would be important to mitigate these concerns in order to avoid the
potential unintended consequences of unnecessary and medically
inappropriate outpatient-to-inpatient beneficiary transfers.
Due to the complexity of transfer scenarios and the lack of clarity
about the best approaches to caring for beneficiaries with AMI under an
EPM in communities with varying cardiac care capacity distributed among
hospitals in the region, several commenters further recommended that
CMS gather clinical expert advice through an advisory panel or other
dialogue with stakeholders to further explore the AMI model transfer
policy consequences on hospitals' willingness to transfer patients.
Finally, many commenters recommended CMS to provide clarification and
ongoing guidance and support to AMI model participants related to
transfers and episode attribution and monitor for any unintended
consequences of the final AMI model transfer episode initiation and
attribution policies.
Response: We appreciate the variety of perspectives of the
commenters on the proposed AMI model transfer episode initiation and
attribution policies. We agree with the commenters that this area of
policy is both complex and significant under the AMI model, given the
variety of care patterns experienced by beneficiaries with AMI and the
variation in cardiac care capacity among hospitals. The transfer policy
has substantial implications for AMI and CABG model participants with
varying cardiac care capacity, beneficiaries who experience transfers
during emergency treatment of AMI, and CMS due to the potential for the
AMI model transfer policy to result in changes in transfer patterns
that do not improve the quality or efficiency of care for beneficiaries
with AMI, both those beneficiaries included the model and those whose
care is not included in the AMI model. We recognized the importance of
considering the potential advantages and disadvantages of various
approaches to AMI model transfer episode initiation and attribution for
beneficiaries and hospitals in our extensive discussion in the proposed
rule (81 FR 50838 through 50840) about alternatives considered for
outpatient-to-inpatient and inpatient-to-inpatient transfer scenarios.
We also continue to believe that collaboration among community
hospitals and referral hospitals with more advanced cardiac care
capacity is important to improving the quality and efficiency of health
care in communities, especially for beneficiaries with conditions
requiring emergency evaluation and treatment such as AMI.
We considered the analysis provided by some commenters and the
commenters' different perspectives on the proposed AMI model transfer
episode initiation and attribution proposal and the alternatives
considered, including the potential for unintended consequences under
any transfer policy we would establish for the AMI model. At this point
in time, we appreciate that there are important advantages and
disadvantages to each of the potential AMI model transfer
[[Page 279]]
episode initiation and attribution policies that require ongoing
consideration over the longer-term during AMI model implementation in
order to optimize the interests of beneficiaries, hospitals, and CMS,
while limiting the risk of unintended consequences that could create
problems for beneficiaries, hospitals, and CMS. For example, several
commenters stressed that changes to current AMI transfer patterns under
transfer policies of the AMI model that encourage the initial treating
hospital to either more quickly transfer patients who present to the
emergency department with symptoms of AMI or not transfer AMI patients
at all to retain control of the episode and its associated cost could
be clinically appropriate but also could reflect premature transfers
that were not medically necessary or a care pattern that poses a risk
to beneficiaries' health. Thus, while we are finalizing a policy now to
address transfer situations under the AMI model to allow for
implementation of the model, we are also coupling this policy with
heightened monitoring and evaluation of transfers of Medicare AMI
beneficiaries to and from AMI and CABG model participants and may
propose refinements to the policy or payment adjustments in the future
depending on our findings.
With respect to the policy for outpatient-to-inpatient transfers of
beneficiaries with AMI, we proposed to begin AMI and CABG episodes upon
the first inpatient admission to a treating hospital that is an AMI or
CABG model participant, rather than in the outpatient department of the
initial treating hospital that did not admit the beneficiary. In the
proposed rule (81 FR 50839), we also considered an overarching
alternative policy that could begin every AMI and CABG episode at the
first AMI or CABG model participant at which the beneficiary was either
admitted for an AMI MS-DRG, PCI MS-DRG with an AMI ICD-CM diagnosis
code, or CABG MS-DRG or presented to the emergency department for
initial AMI care (including observation status) before being
transferred to an o-i transfer hospital. However, we are not beginning
AMI or CABG episodes with care furnished by an AMI or CABG model
participant when the beneficiary is not admitted as an inpatient to
that hospital. Given the commenters' concerns about our proposal to
begin AMI episodes at the initial treating hospital under the
circumstance of an inpatient-to-inpatient transfer, we believe that
beginning AMI episodes at a hospital furnishing only emergency AMI care
could interfere with the hospital's focus on emergency stabilization
and transfer of the beneficiary. It could also place an undue burden on
the initial treating hospital for long-term responsibility for the AMI
episode in which the initial treating hospital had a role that was
limited to stabilization prior to transfer for AMI treatment. We would
not expect the initial treating hospital in these circumstances to be
substantially involved in the beneficiary's AMI treatment after the
initial emergency care. The commenters confirmed our concerns, as
discussed in the proposed rule (81 FR 50839), that this approach would
be complex, challenging to operationalize, and require assumptions
about the relationship of care to the AMI based solely on
administrative claims data that would be insufficient to ensure we
could accurately identify related care.
Thus, we have concluded that it remains problematic to define the
services to be included in AMI episodes if those services precede an
inpatient hospitalization that would otherwise initiate the AMI or CABG
episode. As we discuss in section III.C.4.a.(1) of this final rule, we
are not beginning an EPM episode prior to the anchor hospitalization
because of the clinical variability leading up to all EPM episodes and
the challenge of identifying unrelated services prior to the inpatient
hospitalization. Thus, we will not make an exception for transfers from
the emergency department or observation status of the initial treating
AMI or CABG model participant when the beneficiary with AMI is not
admitted to that hospital. As discussed in sections III.G.4. through 6.
and IV. of this final rule, we will be engaged in monitoring and
evaluation specifically as they relate to the risks associated with
this policy of adverse patient selections that could result in
increased transfers of complex beneficiaries with AMI to other
hospitals so that an AMI model participant can avoid high-cost
episodes. Should we observe concerning outpatient-to-inpatient transfer
patterns, we may engage in future rulemaking to refine the AMI episode
initiation policy or to make a payment adjustment for this scenario.
With respect to the proposed policy for inpatient-to-inpatient
transfers, we appreciate the detailed comments on the proposal as well
as on the two alternatives considered in the proposed rule (81 FR
50838). In response to the commenters who contended that the proposal
to assign AMI episode responsibility to the initial treating hospital
in an inpatient-to-inpatient transfer scenario could increase premature
transfers, we are unclear that this would be the case since we also
proposed not to initiate AMI episodes based only on care in the
outpatient department. Thus, we believe it would be more likely
expected that AMI model participants pursuing early transfer would
transfer the beneficiary prior to admission to the hospital. However,
we are concerned that the proposal to assign AMI episode responsibility
to the initial treating hospital could lead to beneficiaries not being
transferred in circumstances where they need a higher level of cardiac
care, as a number of commenters claimed.
We appreciate the support of the commenter for the second
alternative we discussed in the proposed rule (81 FR 50838) for
inpatient-to-inpatient transfer, which would assign AMI or CABG episode
responsibility to the hospital in the chained anchor hospitalization
discharging the beneficiary under the most resource-intensive MS-DRG
according to a hierarchy of CABG, PCI, and AMI MS-DRGs in descending
order of inpatient hospital resource-intensity. While we continue to
believe that this alternative could have merit by placing AMI episode
responsibility on the hospital that furnished the most intensive
treatment to the AMI beneficiary during the chained anchor
hospitalization, we are not adopting this policy due to concerns about
the episode attribution complexity that it would present. Many
commenters pointed out significant challenges for AMI model
participants that would arise under our proposal to assign AMI episode
responsibility consistently to the initial treating hospital that
admitted the beneficiary regarding the ability of AMI model
participants to meet the requirements of the model, such as timely
beneficiary notification. They also raised concerns about the
timeliness of the responsible hospital's identification of model
beneficiaries especially if the hospital is not the one discharging the
beneficiary from acute care and stated that a delay in beneficiary
identification could seriously impede the hospital's ability to
intervene with AMI and CABG model beneficiaries to begin coordinating
care prior to hospital discharge. Thus, we believe that an inpatient-
to-inpatient transfer policy that assigns AMI episode responsibility in
some cases to the initial treating hospital and in other cases to the
i-i transfer hospital depending on the different MS-DRGs during the
chained anchor hospitalization would be even more
[[Page 280]]
complex and could lead to even greater hospital confusion than our
proposal.
We also considered the potential for making a payment adjustment
while holding the initial treating hospital accountable for the AMI
episode as recommended by a number of commenters, in order to put
hospitals with lesser cardiac care capacity that more frequently need
to transfer AMI beneficiaries on a more level playing field with
hospitals that can themselves furnish comprehensive cardiac care. While
this recommendation from the commenters would be operationally feasible
and address some of the concerns raised by commenters about the
transfer incentives inherent in our proposal, while maintaining the
responsible hospital for the AMI episode in an inpatient-to-inpatient
transfer scenario as the initial treating hospital that would be most
likely to be in the beneficiary's community, this recommendation would
add even greater complexity to the AMI model pricing methodology,
already an area of significant concern to the commenters. This
refinement also would not address the challenges for the initial
treating hospital raised by other commenters related to timely
beneficiary identification and notification. Therefore, we are not
adopting this recommendation for the AMI model. However, we note that
because we are changing the responsible hospital for AMI and CABG
episodes that involve inpatient-to-inpatient transfers in our final
policy as discussed later in this section, we believe the commenters'
interest in creating a more level playing field among AMI model
participants that transfer beneficiaries to variable degrees is
addressed through that final policy.
Most commenters favored the first alternative we discussed in the
proposed rule (81 FR 50838) for AMI model transfer episode initiation
and attribution in the inpatient-to-inpatient transfer scenario.
Specifically, this policy would cancel the AMI episode initiated at the
initial treating hospital that is an AMI model participant when any
inpatient-to-inpatient transfer occurs. The beneficiary would initiate
a new AMI or CABG episode at the i-i transfer hospital if that hospital
is an AMI or CABG model participant and the MS-DRG for that
hospitalization is an AMI MS-DRG, PCI MS-DRG with AMI ICD-CM diagnosis
code, or CABG MS-DRG. If the i-i transfer hospital is not an AMI or
CABG model participant, then the beneficiary would not be included in
any AMI or CABG episode regardless of the MS-DRG assigned. This
approach would place financial responsibility for the AMI or CABG
episode on the i-i transfer hospital if the beneficiary went on to be
discharged from acute care at that hospital. Episode initiation and
attribution in this way addresses the concerns of commenters about
establishing a level playing field for AMI model participants that more
frequently transfer beneficiaries for AMI treatment because it would
not hold those hospitals accountable for AMI episodes with inpatient-
to-inpatient transfers that are, on average, higher-cost than AMI
episodes without transfers.
This approach also addresses the commenters' significant concerns
about the potential burden our proposal would have placed on the
initial treating hospital to track beneficiaries transferred to the i-i
transfer hospital and determine if they were discharged from the i-i
transfer hospital under an MS-DRG that would assign the beneficiary to
an AMI episode for which the initial treating hospital would be
responsible. The resources necessary for the initial treating hospital
to coordinate with the i-i transfer hospital that was actually
discharging the beneficiary around the discharge and follow up plan
could be substantial, given that the i-i transfer hospital would hold
the discharge planning responsibility for that beneficiary. It is not
clear that the opportunity for the initial treating hospital to enter
into financial arrangements to share upside and/or downside risk with
the i-i transfer hospital as discussed in section III.I. of this final
rule would have been sufficient to incentivize the degree of timely
collaboration and coordination by the i-i transfer hospital that would
be needed by the responsible initial treating hospital.
Therefore, we believe the most prudent final AMI model transfer
episode initiation and attribution policy at this time is to cancel the
AMI episode initiated at the initial treating hospital whenever an
inpatient-to-inpatient transfer occurs, and base any new AMI or CABG
episode initiation on the MS- DRG for the i-i transfer hospital
admission if the i-i transfer hospital is an AMI or CABG model
participant. This attribution approach is simple and unambiguous. It
eliminates the need for us to adopt the concept of chained anchor
hospitalization altogether, as well as the complex policy that would
have established a price MS-DRG that could be different from the MS-DRG
that was assigned to the hospitalization that initiates the AMI
episodes as discussed in section III.D.4.b.(2)(a) of this final rule.
We do not believe there is a need to make any additional pricing
adjustments for inpatient-to-inpatient transfer scenarios that include
more than one IPPS payment for continuous acute care services in the
beginning of AMI episodes in order to ensure a level playing field for
hospitals that more commonly transfer beneficiaries for AMI treatment.
By making the hospital ultimately discharging the beneficiary from
acute care responsible for the AMI or CABG episode and beginning the
episode at that hospital, we reduce the hospital's uncertainty as much
as possible around identifying beneficiaries in the model. In the
inpatient-to-inpatient transfer scenario, the uncertainty about
identification of beneficiaries who were transferred is no different
than if all the care for the beneficiary occurred at a single hospital.
We also do not hold a hospital financially responsible for inpatient or
outpatient hospital and Part B services that precede the beneficiary's
admission to the responsible hospital, services the responsible
hospital would be unable to influence according to the commenters.
While we are finalizing this AMI model transfer episode initiation
and attribution policy at this time for the AMI model that differs from
our proposal for the reasons discussed, we continue to have some
concerns about the care patterns that could be perpetuated and changes
that could be incentivized by the policy. First, we recognize that this
policy does not encourage any efficiencies in the transfer patterns of
beneficiaries with AMI, while we know that episodes which include
inpatient-to-inpatient transfers in the beginning of AMI care are
costly for the Medicare program. A recent analysis by DataGen of 90-day
episodes of care for AMI found that nationally, Medicare payments (that
is, costs to the program) for AMI acute care transfers (not just those
receiving PCI) were second only to the costs for patients going to
long-term care.\71\ This analysis is consistent with information
provided by the commenters that AMI episodes that include inpatient-to-
inpatient transfers are significantly more costly than AMI episodes
that do not include such transfers. The analysis identified three
scenarios for AMI care as follows:
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\71\ The Truth Behind Variation in Episode Payments; May 5,
2014. Accessed October 18, 2016 at https://www.beckershospitalreview.com/finance/the-truth-behind-variation-in-episode-payments.html.
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In hospitals that are licensed to perform PCIs, a patient
who is admitted with AMI and needs a PCI receives his or her full
treatment at that hospital. This results in one MS-DRG assignment and
payment for the PCI.
[[Page 281]]
In hospitals not licensed to perform PCIs, a patient
admitted with an AMI who needs a PCI is assigned an AMI MS-DRG at the
initial treating hospital and then transferred to an i-i transfer
hospital for the PCI. This results in two MS-DRG payments, one for the
AMI care and one for the PCI. In this case, the inpatient acute care
costs for the initial AMI treatment are substantially higher. The
analysis found that the average length-of-stay at the initial treating
hospital was 3 days, but it was not possible to determine from
administrative claims whether that relatively long length-of-stay was
due to patient stabilization or the need to wait for the PCI to be
scheduled at the i-i transfer hospital.
In hospitals that are licensed to perform PCIs, a patient
who is admitted with an AMI and needs a PCI receives some care at the
initial treating hospital and then is transferred to an i-i transfer
hospital for the PCI. This also results in two MS-DRG payments and
substantially higher inpatient acute care costs for the initial AMI
treatment
In summary, medically unnecessary or inappropriate inpatient-to-
inpatient transfers lead to inefficiencies in initial AMI treatment,
yet both the second and third scenarios may provide opportunities for
care redesign. However, the final AMI model transfer episode initiation
and attribution policy is not able to test such opportunities at this
time.
In addition to not creating incentives for transfer efficiency, the
final AMI model policy may create additional incentives for an AMI
model participant to transfer complex beneficiaries or beneficiaries
with potentially avoidable complications resulting from AMI treatment
who would be expected to result in high-cost episodes to i-i transfer
hospitals. Transfers could occur to i-i transfer hospitals that are
also participants in the AMI model where the costs of care at the
initial treating hospital would not be included in the AMI episode
initiated at the i-i transfer hospital or to hospitals outside the MSA
that would not be participants in the AMI model. Such transfer patterns
could ultimately result in either complex beneficiaries or those with
complications resulting from the initial AMI treatment
disproportionately not being the financial responsibility of the
initial AMI model treating hospital or not being included in the AMI
model at all.
Given these concerns about the potential missed opportunities and
unintended consequences due to the final AMI model transfer episode
initiation and attribution policy, we will be examining AMI transfers
to and from AMI model participants very closely through our monitoring
and evaluation activities as discussed in sections III.G.4. through 6.
and IV. of this final rule, both of beneficiaries that ultimately are
included in AMI episodes and those that are not. We may revisit the
transfer policy or propose payment adjustments through future
rulemaking if we see reduced AMI transfer efficiency; opportunities to
increase transfer efficiency; disproportionate transfers of complex AMI
beneficiaries suggesting that AMI model participants are engaging in
adverse patient selection; high rates of transfers of beneficiaries
with potentially avoidable complications of AMI treatment at the
initial treating hospital; inordinate loss of beneficiaries from the
AMI model due to transfer outside of the MSAs where the AMI and CABG
models are being tested; or other patterns of concern.
The final policies for initiation and attribution of AMI and CABG
episodes that involve no transfer, outpatient-to-inpatient transfer, or
inpatient-to-inpatient transfers at the beginning of AMI care are
summarized in Table 8.
Comment: One commenter requested that CMS establish a transfer
attribution policy for the SHFFT model as well, because beneficiaries
with SHFFT are occasionally transferred from the initial treating
hospital to another hospital for SHFFT surgery. The commenter
recommended that the SHFFT episode be attributed to the transfer
hospital, that is, the hospital receiving the beneficiary upon transfer
from the initial treating hospital.
Response: We appreciate the commenter's suggestion. However, we do
not believe it is necessary to establish a specific transfer policy for
the SHFFT model. A SHFFT episode would only be initiated in the
hospital where the beneficiary had SHFFT surgery and where a SHFFT
model MS-DRG is first assigned to the beneficiary's hospitalization.
The initial treating hospital would only assign a SHFFT model MS-DRG to
the beneficiary if the beneficiary received SHFFT surgery at that
hospital and the transfer hospital could not assign a SHFFT model MS-
DRG unless the beneficiary had surgery on the other hip, an unlikely
scenario. Therefore, under the circumstances described by the
commenter, without any special policies beyond the standard rules of
SHFFT episode initiation, the SHFFT episode would be initiated at the
transfer hospital, which would be responsible for the SHFFT episode. We
note that if the SHFFT surgery was performed at the initial treating
hospital where an episode was initiated and then the beneficiary was
transferred to another hospital for additional care, the SHFFT episode
would continue under the responsibility of the initial treating
hospital. We note that we would apply the SHFFT model exclusion list to
the transfer hospital MS-DRG to determine whether those inpatient
services were included in the SHFFT episode.
Final Decision: After consideration of the public comments
received, we are not finalizing our proposal to attribute AMI episodes
to the initial treating hospital when an inpatient-to-inpatient
transfer occurs during the anchor hospitalization. Instead, we are
adopting a final policy to cancel the AMI episode initiated at the
initial treating hospital when an inpatient-to-inpatient transfer
occurs, and base any AMI or CABG episode initiation on the MS-DRG for
the final i-i transfer hospital admission if the i-i transfer hospital
is an AMI or CABG model participant. If the i-i transfer hospital is
not an AMI or CABG model participant, the beneficiary's care is not
included in any AMI or CABG episode. We are not using the terms chained
anchor hospitalization and price MS-DRG in the final episode definition
and pricing policies for the AMI model as discussed in sections
III.C.4.a.(5) and III.D.4.b.(2)(a) of this final rule. Instead, the
episode definition and pricing is determined only by the anchor MS-DRG
for the AMI or CABG model episode.
The proposal for AMI episode attribution in circumstances that
involve inpatient-to-inpatient transfers of beneficiaries with AMI was
included in proposed Sec. 512.240(a)(2). We no longer need a specific
attribution provision for the AMI model because attribution of AMI and
CABG episodes occurs in the usual manner to the AMI or CABG model
participant that discharges the beneficiary under an AMI MS-DRG, PCI
MS-DRG with AMI ICD-CM diagnosis code, or CABG MS-DRGs that initiates
the AMI or CABG episode at that hospital. Therefore, we are renumbering
proposed Sec. 512.240(a)(3) (Cancellation of an AMI model episode) to
Sec. 512.240(a)(2), and revising proposed Sec. 512.240(a)(3)(iii)
which has been renumbered Sec. 512.240(a)(2)(iii) to specify that an
AMI model episode is canceled if the beneficiary is transferred during
the anchor hospitalization to another hospital for inpatient
hospitalization.
The final policies for initiation and attribution of AMI and CABG
episodes that involve no transfer, outpatient-to-inpatient transfer, or
inpatient-to-inpatient transfers at the beginning of AMI care are
summarized in Table 8.
[[Page 282]]
Table 8--Final Initiation and Attribution of AMI and CABG Episodes That
Involve No Transfer, or Outpatient-to-Inpatient or Inpatient-to-
Inpatient Transfers at the Beginning of AMI Care
------------------------------------------------------------------------
Final episode initiation and
Scenario attribution policy
------------------------------------------------------------------------
No transfer (participant): Beneficiary Initiate AMI or CABG episode
admitted to an initial treating based on anchor
hospital that is a participant in the hospitalization MS-DRG.
AMI or CABG model for an AMI MS-DRG, Attribute episode to the
PCI MS-DRG with AMI ICD-CM diagnosis initial treating hospital.
code, or CABG MS-DRG.
No transfer (nonparticipant): No AMI or CABG episode is
Beneficiary admitted to an initial initiated.
treating hospital that is not a
participant in the AMI or CABG model
for an AMI MS-DRG, PCI MS-DRG with AMI
ICD-CM diagnosis code, or CABG MS-DRG.
Inpatient-to-inpatient transfer Initiate AMI or CABG episode
(nonparticipant to participant): based on the MS-DRG at i-i
Beneficiary admitted to an initial transfer hospital.
treating hospital that is not an AMI Attribute episode to the i-i
or CABG model participant and later transfer hospital.
transferred to an i-i transfer
hospital that is an AMI or CABG model
participant for an AMI MS-DRG, PCI MS-
DRG with AMI ICD-CM diagnosis code, or
CABG MS-DRG.
Inpatient-to-inpatient transfer Cancel AMI episode. No other
(participant to nonparticipant): AMI or CABG episode is
Beneficiary admitted to an initial initiated.
treating hospital that is an AMI or
CABG model participant for an AMI MS-
DRG or PCI MS-DRG with AMI ICD-CM
diagnosis code and later transferred
to an i-i transfer hospital for an
AMI, PCI, or CABG MS-DRG, where the i-
i transfer hospital is not an AMI or
CABG model participant.
Inpatient-to-inpatient transfer Cancel AMI episode at the
(participant to participant): initial treating hospital.
Beneficiary admitted to an initial Initiate an AMI or CABG
treating hospital that is an AMI or episode at the i-i transfer
CABG model participant for an AMI MS- hospital. Attribute episode to
DRG or PCI MS-DRG with AMI ICD-CM the i-i transfer hospital.
diagnosis code later transferred to an
i-i transfer hospital for an AMI, PCI,
or CABG MS-DRG, where the i-i transfer
hospital is an AMI or CABG model
participant.
Outpatient-to-inpatient transfer Initiate AMI or CABG episode
(nonparticipant to participant or based on anchor
participant to participant): hospitalization MS-DRG at o-i
Beneficiary transferred without transfer hospital. Attribute
admission from the initial treating episode to the o-i transfer
hospital, regardless of whether the hospital.
initial treating hospital is an AMI or
CABG model participant, to a o-i
transfer hospital that is an AMI or
CABG model participant and is
discharged from the o-i transfer
hospital for an AMI MS-DRG, PCI MS-DRG
with AMI ICD-CM diagnosis code, or
CABG MS-DRG.
Outpatient-to-inpatient transfer No AMI or CABG episode is
(participant to nonparticipant): initiated.
Beneficiary transferred without
admission from the initial treating
hospital that is an AMI or CABG
participant to an o-i transfer
hospital that is not an AMI or CABG
model participant.
------------------------------------------------------------------------
b. Middle of EPM Episodes
Similar to the CJR model, we proposed that once an EPM episode
begins, it would continue until the end of the episode as described in
the following section, unless certain circumstances arise during the
episode (80 FR 73318). When an EPM episode was canceled, we proposed
that the services furnished to beneficiaries prior to and following the
EPM episode cancellation would continue to be paid by Medicare as usual
but there would be no actual EPM episode spending calculation that
would be reconciled against the EPM quality-adjusted target price.
Specifically, we proposed that the following circumstances
occurring during an EPM episode would cancel the EPM episode:
The beneficiary ceases to meet any of the general
beneficiary inclusion criteria described in section III.C.4.a.(1) of
the proposed rule (81 FR 50834), except the three criteria regarding
inclusion in other episode payment model episodes.
The beneficiary dies during the anchor hospitalization.
The beneficiary initiates any BPCI model episode.
For purposes of cancellation of EPM episodes for beneficiary
overlap with other episode payment models, we proposed that if a
beneficiary in an EPM episode would initiate any BPCI model episode,
the EPM episode would be canceled. We refer to section III.D.6.c.(1) of
the proposed rule (81 FR 50868) for further discussion of our proposals
addressing potential overlap of beneficiaries in the EPMs with the BPCI
initiative. We also refer to section III.D.6.c.(3) of the proposed rule
(81 FR 50869 through 50871) for discussion of our proposal to cancel
EPM episodes for beneficiaries who become assigned to specified ACOs
during EPM episodes.
Our proposal to only cancel the EPM episode if a beneficiary dies
during the anchor hospitalization differs from the final CJR model
policy that cancels an episode if a beneficiary dies any time during
the episode (80 FR 73318). As discussed in the CJR Final Rule for LEJR
episodes, we believe that it also would be appropriate to cancel an
episode in the AMI, CABG, and SHFFT models when a beneficiary dies
during the anchor hospitalization as there would be limited incentives
for efficiency that could be expected during the anchor hospitalization
itself (80 FR 73318). We agreed with commenters on the CJR model
proposed rule that we should cancel CJR episodes for death any time
during those episodes, because beneficiary deaths following LEJR would
be uncommon and expected to vary unpredictably, leading to extremely
high or low episode spending that was not typical for a LEJR episode. A
recent analysis that pooled results from 32 studies showed the
incidence of mortality during the first 30 and 90 days following hip
replacement to be 0.30 percent and 0.65 percent, respectively,
confirming our expectation of low mortality rates during LEJR
episodes.\72\
[[Page 283]]
In contrast, the 30-day national CABG and AMI mortality rates as
displayed on Hospital Compare are significantly higher at approximately
3 percent and 14 percent respectively.\73\ Several CMS programs use 30-
day mortality measures for CABG and AMI as measures of hospital
quality, and these measures were proposed for use in the pay-for-
performance methodology for the CABG and AMI models as discussed in
section III.E.3.f. of the proposed rule (81 FR 50880). Similarly, a
2009 study shows a 30-day hip fracture mortality rate for Medicare
beneficiaries of approximately 5 percent, significantly higher than the
mortality rate following LEJR procedures.\74\ Thus, we would expect
that deaths during SHFFT episodes would be more common than in CJR
episodes. Because beneficiaries in AMI, CABG, and SHFFT episodes would
be at significant risk of death during these episodes that we proposed
to extend 90 days post-hospital discharge, we considered mortality to
be a harmful beneficiary outcome that should be targeted for
improvement through care redesign incentivized by the EPMs for these
clinical conditions. Therefore, in the proposed rule (81 FR 50841) we
discussed our belief that it would not be appropriate to exclude
beneficiaries from AMI, CABG, or SHFFT episodes who die any time during
the episode like we do in the CJR model. Instead, we proposed to
maintain beneficiary episodes in the EPMs even if death occurred during
the episodes, meaning we would calculate actual EPM episode spending
when beneficiaries die following discharge from the anchor
hospitalization but within the 90-day post-hospital discharge episode
duration and reconcile it against the quality-adjusted target price. We
believed this proposal would encourage EPM participants to actively
manage EPM beneficiaries to reduce their risk of death, especially as
death would often be preceded by expensive care for emergencies and
complications. Because of the higher mortality rates for all of the EPM
episodes than for LEJR episodes in the CJR model, we did not consider
mortality following hospital discharge to be atypical and, therefore,
we proposed to cancel EPM episodes only for death during the anchor
hospitalization.
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\72\ Berstock JR, Beswick AD, Lenguerrand E, Whitehouse MR, Blom
AW. Mortality after total hip replacement surgery: A systematic
review. Bone & Joint Research. 2014; 3(6):175-182. doi:10.1302/2046-
3758.36.2000239.
\73\ https://www.medicare.gov/hospitalcompare/search.html.
\74\ Brauer CA, Coca-Perraillon M, Cutler DM, Rosen AB.
Incidence and Mortality of Hip Fractures in the United States. JAMA.
2009;302(14):1573-1579. doi:10.1001/jama.2009.1462.
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We further proposed that the following circumstances also would
cancel an AMI episode in the circumstances of a chained anchor
hospitalization when the beneficiary was discharged from acute care
under an MS-DRG from the final transfer hospital in the chained anchor
hospitalization that could not, itself, initiate an AMI or CABG
episode, regardless of whether the final transfer hospital was an AMI
or CABG model participant (that is, the episode would be canceled if
the final transfer hospital MS-DRG was any MS-DRG other than an AMI MS-
DRG, PCI MS-DRG, or CABG MS-DRG).
While we proposed to begin an AMI episode with the first
hospitalization in the chained anchor hospitalization that would
initiate an episode as discussed in section III.C.4.a.(5) of the
proposed rule (81 FR 50836 through 50840), we also proposed to cancel
AMI episodes under the circumstances when a beneficiary in an AMI
episode was discharged from acute care under an MS-DRG from the final
i-i transfer hospital in the chained anchor hospitalization that was
not an AMI, PCI, or CABG MS-DRG that could initiate an AMI or CABG
episode (that is, the episode would be canceled if the final transfer
hospitalization MS-DRG was any MS-DRG other than an AMI, PCI, or CABG
MS-DRG). Overall, this proposal treated the hospital that initiated the
AMI episode and then transferred the beneficiary most similarly to a
hospital that furnished all of the beneficiary's inpatient care itself,
with respect to whether or not the beneficiary's care was ultimately
included as an episode in the AMI model.
Finally, we did not propose to cancel an AMI episode altogether for
a CABG readmission during the 90-day post-hospital discharge period or
cancel the AMI episode and initiate a CABG episode because planned CABG
readmission following an anchor hospitalization that initiates an AMI
episode may be an appropriate clinical pathway for certain
beneficiaries. Instead, we proposed to provide an adjusted AMI model-
episode benchmark price that includes a CABG readmission in such
circumstances so as not to financially penalize participant hospitals
for relatively uncommon, costly, clinically appropriate care patterns
for beneficiaries in AMI episodes. We refer to section III.D.4.b.(2)(c)
of the proposed rule (81 FR 508520 for discussion of the adjusted AMI
model-episode benchmark price that would apply in the case of CABG
readmission during an AMI episode.
The proposals for cancellation of EPM episodes were included in
proposed Sec. Sec. 512.240(a)(3), (b)(2), and (c)(2). We sought
comment on our proposals for cancellation of EPM episodes.
The following is a summary of the comments received and our
responses.
Comment: With the exception of the proposal for cancellation of EPM
episodes for death only during the anchor hospitalization, many
commenters expressed support for the other proposed EPM episode
cancellation policies, especially the proposal to cancel EPM episodes
in the circumstances of a chained anchor hospitalization when the
beneficiary is discharged from acute care under an MS-DRG from the
final transfer hospital in the chained anchor hospitalization that
could not, itself, initiate an AMI or CABG episode. The commenters
pointed out that when a transfer results in discharge from the final
hospital in the chained anchor hospitalization under an MS-DRG that
could not initiate an AMI or CABG episode, those episodes are
disproportionately likely to reflect high-cost episodes that would not
be conducive to care redesign due to beneficiary complexity and the
need for atypical beneficiary care. Several commenters encouraged CMS
to monitor cancellation circumstances because EPM participants could
engage in gaming by discharging a dying patient from the hospital to
garner a low-cost episode or encouraging beneficiaries to enroll in a
Medicare Advantage plan.
A few commenters requested that CMS cancel EPM episodes when a
beneficiary has an excluded readmission because the Part A and Part B
services furnished following that readmission would be related to the
clinical condition that was the basis for the readmission, and not the
condition that was the focus of the EPM.
Response: We appreciate the support for our proposals to cancel an
EPM episode when a beneficiary initiates an EPM episode but then fails
to meet the general beneficiary care inclusion criteria sometime during
the episode, which include enrollment in Medicare Part A and Part B;
eligibility for Medicare not on the basis of end-stage renal disease;
not enrolled in any managed care plan; not covered under a United Mine
Workers of American health plan; have Medicare as their primary payer;
and not to an ACO in the Next Generation ACO model or an ACO in a track
of the Comprehensive ESRD Care Model incorporating downside risk for
financial losses. In addition, we appreciate the support for our
proposals to cancel an AMI episode when a beneficiary initiates any
BPCI episode and when an AMI model beneficiary is discharged from the
final hospital in a
[[Page 284]]
chained anchor hospitalization under an MS-DRG that is not an AMI, PCI,
or CABG MS-DRG, regardless of whether the final transfer hospital is an
AMI or CABG model participant. As discussed in section III.C.4.a.(5) of
this final rule, we are finalizing this proposal, but with modification
to cancel all AMI episodes that begin at an initial treating hospital
when an inpatient-to-inpatient transfer occurs after the AMI episode
has begun.
In response to those commenters requesting that we cancel EPM
episodes for the occurrence of an excluded readmission, we do not agree
that all Part A and Part B services furnished following discharge from
the excluded readmission but within the original 90-day post-discharge
period for the EPM episode would be unrelated to the clinical condition
that is the focus of the EPM. Instead, we believe care during that
period would also be furnished for EPM beneficiary management and
recovery following the AMI, CABG, or SHFFT hospitalization that
initiated the EPM episode. The application of our exclusion list for
readmissions and Part B services continues to identify those
readmissions and Part B services that would be excluded from the EPM
episode definition throughout the full post-discharge episode duration,
regardless of the occurrence of an excluded readmission during the EPM
episode.
Additionally, as discussed in sections III.G.4. through 6. of this
final rule, we plan to monitor EPM participants' claims data and audit
EPM participants' and their EPM collaborators medical records and
claims as we deem appropriate and will include canceled EPM episodes in
this monitoring to ensure that we do not observe patterns of
cancellation suggestive of gaming of the EPM episode cancellation
policies.
Comment: Several commenters expressed support for CMS' proposal to
cancel EPM episodes for death during the anchor hospitalization but not
for death during the 90-day post-discharge episode period. These
commenters agreed that death during the inpatient hospitalization would
be atypical and should result in EPM episode cancellation, whereas
death within the 90 days following hospital discharge would not be rare
for the clinical conditions in the EPMs and could appropriately be
targeted for improvement through EPM care redesign. The commenters
pointed out that CMS' proposals to use AMI and CABG mortality rates in
the AMI and CABG model pay-for-performance methodologies was consistent
with the opportunities for EPM care redesign to reduce mortality rates
in the 30 days following discharge from the anchor hospitalization for
AMI and CABG. A few commenters suggested that CMS should not cancel EPM
episodes for any death once they are initiated, even for death during
the anchor hospitalization, arguing that such cancellations could skew
episode costs and that some in-hospital deaths may be preventable,
which the EPMs should provide incentives to prevent.
However, many commenters, including MedPAC, recommended that CMS
adopt the same policy as the CJR model and cancel episodes for death at
any time during the EPM episode, including during the 90 days post-
hospital discharge. Some of the commenters stated that episodes during
which a beneficiary dies usually involve atypical courses of care,
which may include extensive end-of-life care that hospitals should not
be penalized for providing. MedPAC speculated that on the one hand,
stays during which the EPM beneficiary dies could be exceptionally
high-cost if the patient lives for most of the 90 days and receives
end-of-life care. On the other hand, if the EPM beneficiary dies
shortly after discharge from the hospital, the patient may receive
little post-acute care services or end-of-life care, resulting in
unusually low-cost episodes. They concluded that in either case, the
episode spending would not be typical and, therefore, these stays
should be excluded from calculating the target price and reconciliation
payment for the EPM participant. They stated that excluding these
episodes would make the spending data less ``noisy'' and better reflect
the typical spending for the EPM participant's episodes. MedPAC also
claimed that CMS has better tools than including in the EPMs
beneficiaries who die in the 90 days following hospital discharge that
encourage lower mortality rates, such as use of the AMI and CABG
mortality rates in the HVBP Program, and care coordination, such as the
Medicare Spending Per Beneficiary (MSPB) measure in the HVBP Program
and the HRRP.
Some commenters further contended that the proposal to cancel SHFFT
episodes only for death during the anchor hospitalization compared to
CJR model episode cancellation for beneficiary death any time during a
LEJR episode leads to a lack of consistency between hip fracture
beneficiaries included in the CJR and SHFFT models. Under CMS'
proposal, hip fracture beneficiaries treated with a SHFFT would be
subject to one set of rules, while those treated with a hip replacement
would be subject to another set, leading to confusion among the
hospitals that would be participants in both the CJR and SHFFT models
and inequitable treatment of beneficiaries with the same clinical
condition of hip fracture. The commenters also believe that CMS'
rationale for not canceling SHFFT episodes for beneficiaries who die
following discharge from the anchor hospitalization due to a higher
risk of death for hip fracture patients than patients receiving LEJR
ignored the fact that a substantial portion of the hip fracture
population is treated with a LEJR. These commenters concluded that this
overlap of fracture beneficiaries between SHFFT and LEJR confounded the
comparison CMS was trying to make between the higher mortality rate of
beneficiaries following SHFFT versus LEJR and led to questions about
its validity.
Response: While we appreciate that there may be some opportunities
to reduce in-hospital deaths for beneficiaries treated with CABG or
SHFFT, we believe that there are limited efficiencies that could be
expected during the anchor hospitalization itself. Furthermore, we note
that there are three separate MS-DRGs for beneficiaries who die during
a hospitalization for AMI (MS-DRG 283 Acute Myocardial Infarction,
Expired with MCC; MS-DRG 284 Acute Myocardial Infarction, Expired with
CC; MS-DRG 285 Acute Myocardial Infarction, Expired without CC/MCC),
and we did not propose that these MS-DRGs would initiate AMI episodes.
Thus, there would be no situations when AMI episodes were canceled for
death during an anchor hospitalization. Thus, we do not believe it
would be appropriate to include beneficiaries who die during the anchor
hospitalization in any of the EPMs.
While beneficiary deaths in the 90-days post-discharge from the
anchor hospitalization would be expected to be more common in AMI,
CABG, and SHFFT episodes than in the LEJR episodes included in the CJR
model, we agree with the commenters that the costs of such episodes are
likely to vary unpredictably across EPM participants. We also agree
with the commenters' argument about the importance of policy
consistency in similar episode payment models for deaths because
adopting different cancellation policies for death under the CJR model
than we proposed for the EPMs could be confusing for those hospitals
that are participants in both the SHFFT and CJR models. While we
continue to believe that reductions in mortality following discharge
from a hospitalization for AMI, CABG, or SHFFT are a harmful
[[Page 285]]
beneficiary outcome that should be targeted for improvement through
care redesign incentivized by the EPMs for these clinical conditions,
we agree with the commenters that it would be appropriate to cancel all
EPM episodes for beneficiary death any time during the episode. We note
that our use of 30-day AMI and CABG mortality measures in the pay-for-
performance methodologies of the AMI and CABG models, respectively, as
discussed in sections III.E.2.b. and c. of this final rule encourages
AMI and CABG model participant to actively manage AMI and CABG
beneficiaries to reduce this risk of death, to supplement existing
incentives in other CMS programs that encourage lower mortality rates.
Comment: Several commenters requested that CMS clarify its
administrative policies for identifying and informing EPM participants
about beneficiaries whose episodes are initiated and then canceled. The
commenters stated that CMS should inform EPM participants in a timely
manner when an episode is canceled for any reason, with one commenter
specifying at least quarterly notification. The commenters pointed out
that an EPM participant's awareness of episode cancellation is
important for several reasons, including the EPM participant's
simultaneous calculation of EPM episode spending; beneficiary
notification; provision of beneficiary engagement incentives; and
determination of beneficiary eligibility for certain Medicare program
rule waivers which is discussed further in section III.J. of this final
rule. The commenters claimed that while the EPM participant is in the
best position to know when the triggering procedures or services they
have been providing will result in a MS-DRG that would initiate an EPM
episode, the EPM participant will not always know when a patient meets
certain exclusion criteria throughout the course of the EPM episode.
The commenters emphasized that it is important for the EPM participant
to know if beneficiaries they expect to be part of the EPM episode are
going to be part of the EPM episode on a timely basis for cancellations
or events that would serve to disqualify the beneficiary from a given
hospital's attribution of an episode. Therefore, the commenters
recommended that CMS inform EPM participant and CJR participant
hospitals timely when an episode is canceled for any reason.
Response: We appreciate the interest of the commenters in
conducting timely analysis of EPM episode spending, as well as ensuring
that the requirements of the EPM are met in their treatment of Medicare
beneficiaries. Given our plans for providing and updating episode
claims data to EPM participants upon request as frequently as quarterly
as discussed in section III.K.5 of this final rule, we will explore
adding indicators to the beneficiary-identifiable claims data supplied
to EPM participants that provide information about circumstances that
could result in EPM episode cancellation, such as admission of a
beneficiary to a hospital that initiates episodes under a BPCI model
for care that could potentially cancel an EPM episode. To the extent
adding such indicators to the claims data is feasible, providing this
information through the claims data to EPM participants would ensure
that EPM participants are informed as frequently as quarterly about
beneficiary circumstances that could result in EPM episode
cancellation. This information would not be real-time, however, and
while our best estimate, would likely be incomplete even based on the
best available information at the time. At a minimum, it would always
reflect the time lag for the EPM episode claims to be submitted and
processed and then reported back to the EPM participant in the updated
claims data. We note that at reconciliation, complete information would
be provided to EPM participants that have requested beneficiary-level
claims data or summary beneficiary claims data reports about those
episodes that were ultimately included in the EPM participant's
reconciliation report as discussed in section III.D.5. of this final
rule.
We note that we expect EPM participants to be actively managing all
of their beneficiaries with conditions characterized by AMI, CABG, or
SHFFT based on their care pathways developed for such beneficiaries,
regardless of the model or program that may ultimately apply to the
beneficiary under the uncommon circumstances of EPM episode
cancellation. We also emphasize the importance of strong, ongoing
communication among providers in a given geographic area caring for
beneficiaries in similar models or programs where provider interests in
delivering high quality, efficient health care should align.
Final Decision: After consideration of the public comments
received, we are finalizing the proposals in Sec. Sec. 512.240(a)(2),
(b)(2), and (c)(2) for cancellation of EPM episodes, with modification
to also cancel EPM episodes if the beneficiary dies during the episode.
We are canceling EPM episodes for the following circumstances:
The beneficiary ceases to meet any of the general
beneficiary inclusion criteria described in section III.C.4.a.(1) of
this final rule, except the three criteria regarding inclusion in other
episode payment model episodes.
The beneficiary dies.
The beneficiary initiates any BPCI model episode.
Additionally, in the AMI model we are canceling the AMI episode
when a beneficiary is transferred during the anchor hospitalization for
inpatient hospitalization at another hospital as discussed in section
III.C.4.a.(5) of this final rule.
Because we are not finalizing the proposed AMI model transfer
episode initiation and attribution policy, as discussed in section
III.C.4.a.(5) of this final rule, we are not adopting the policy
included in proposed Sec. 512.240(a)(2). Therefore, we are renumbering
proposed Sec. 512.240(a)(3) to Sec. 512.240(a)(2) to specify the
final AMI episode cancellation policy. This includes renumbering
proposed Sec. 512.240(a)(3)(iii) to final Sec. 512.240(a)(2)(iii) and
revising the provision to specify the final inpatient-to-inpatient
transfer policy that cancels an AMI model episode if the beneficiary is
transferred during the anchor hospitalization for inpatient
hospitalization at another hospital.
c. End of EPM Episodes
(1) AMI and CABG Models
We proposed a 90-day post-hospital discharge episode duration for
AMI episodes. AMI in general, whether managed medically or with
revascularization, has a lengthy recovery period, during which the
beneficiary has a higher than average risk of additional cardiac events
and other complications, as well as higher utilization of diagnostic
testing and related cardiac procedures. AMI frequently serves as a
sentinel event that marks the need for a heightened focus on medical
management of coronary artery disease and other beneficiary risk
factors for future cardiac events, cardiac rehabilitation over multiple
months, and beneficiary education and engagement. Given the broad
episode definition for AMI episodes that includes beneficiaries
receiving both medical and PCI management for an acute event, we do not
believe that an episode longer than 90 days would be feasible due to
the higher risk of including unrelated services in the episode beyond
several months after hospital discharge. However, we believe that 90-
day post-hospital discharge episodes would provide substantial
[[Page 286]]
incentives for aggressive medical management, cardiac rehabilitation,
and beneficiary education and engagement, whereas a shorter episode
duration would have less effect. We acknowledge that ongoing disease
management for beneficiaries with cardiovascular disease must extend
long after the conclusion of the AMI episodes. However, we believe the
90-day post-hospital discharge episode duration remains appropriate for
an episode payment model focused around a hospitalization. We expect
that the medical management and care coordination during AMI episodes
would continue to be provided as beneficiaries transition out of AMI
episodes, potentially into a primary care medical home or other model
or program with accountability for population health, such as an ACO.
We further note based on analysis of historical episodes that about
10 percent of beneficiaries hospitalized with AMI who received a CABG
received the CABG between 2 and 90 days post-discharge from the anchor
hospitalization (these beneficiaries would be in AMI episodes), while
the remaining 90 percent of CABGs for beneficiaries hospitalized with
AMI were provided during the initial hospitalization (these
beneficiaries would in CABG episodes). In contrast, fewer than 3
percent of those AMI model beneficiaries who received an inpatient or
outpatient PCI during an AMI episode received the PCI between 2 and 90
days post-discharge from the anchor hospitalization, while more than 97
percent received the PCI during the anchor hospitalization.\75\ We
refer to section III.D.4.b.(2)(c) of this final rule for further
discussion of pricing adjustments and alternatives considered for
setting EPM-episode benchmark prices for AMI episodes where PCI or CABG
occurs during the AMI episode but post-discharge from the anchor or
chained anchor hospitalization.
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\75\ Episodes for AMI beneficiaries initiated by all U.S. IPPS
hospitals and constructed using standardized Medicare FFS Parts A
and B claims, as proposed in the proposed rule, that end in CY 2014.
---------------------------------------------------------------------------
Finally, for similar reasons, we believe CABG episodes should
extend 90 days post-hospital discharge. About one-third of CABG
procedures are performed in the context of a hospital admission for
AMI, leading to the same considerations discussed previously in this
section around the appropriate episode duration for beneficiaries with
AMI. The remaining CABG model beneficiaries are likely to have
significant ischemic heart disease, making the occurrence of CABG
itself a sentinel event, like AMI, that marks the need for a heightened
focus on medical management of CAD and other beneficiary risk factors
for future cardiac events, cardiac rehabilitation over multiple months,
and beneficiary education and engagement. Moreover, CABG procedures
have 90-day global periods under the Physician Fee Schedule, consistent
with the lengthy period of recovery associated with major chest
surgery. Thus, a 90-day post-hospital discharge episode duration is
consistent with the recovery period from CABG surgery. We acknowledge
that ongoing disease management for beneficiaries with cardiovascular
disease must extend long after the conclusion of the CABG episodes.
However, we believe the 90-day post-hospital discharge episode duration
remains appropriate for an episode payment model focused around a
hospitalization. We expect that the medical management and care
coordination during CABG episodes would continue to be provided as
beneficiaries transition out of CABG episodes, potentially into a
primary care medical home or other model or program with accountability
for population health, such as an ACO.
As in the CJR model, we proposed that the day of discharge from the
anchor hospitalization counts as day 1 of the post-hospital discharge
period (80 FR 73324). Since the post-hospital discharge period is
intended to extend 90 days for recovery following hospital discharge,
we believe it is appropriate under these circumstances to begin the 90-
day count when the beneficiary is ultimately discharged from acute care
for the first time during the AMI episode. However, the hospital that
initiated the AMI episode in the chained anchor hospitalization would
continue to be responsible in the AMI model for the episode discussed
previously in section III.C.4.a.(5) of this final rule.
The proposals for the end of AMI and CABG episodes were included in
proposed Sec. Sec. 512.240(a)(1) and (b)(1), respectively. We sought
comment on our proposals to end AMI and CABG episodes.
We received a number of comments on the proposed episode duration
for the AMI and CABG models, although most commenters provide similar
rationale and recommendations for the three proposed EPMs. Thus, we
refer to the next section for a discussion of the comments regarding
the proposed ending of EPM episodes, including SHFFT as well as AMI and
CABG episodes.
(2) SHFFT Model
We believe that SHFFT model beneficiaries are similar to CJR model
beneficiaries who undergo hip replacement for fracture. We believe that
the same episode duration as the CJR model of 90 days is appropriate
for SHFFT episodes in order to include the full time for recovery of
function for these beneficiaries, which extends beyond 60 days based on
patterns of post-acute care provider use (80 FR 73319 through 73324).
Therefore, we proposed a 90-day post-hospital discharge duration for
SHFFT episodes.
The proposal for the end of SHFFT episodes was included in proposed
Sec. 512.240(c)(1). We sought comment on our proposal to end SHFFT
episodes.
The following is a summary of the comments received and our
responses.
Comment: A number of commenters expressed support for the proposed
90-day post-discharge episode duration for the AMI, CABG, and SHFFT
models. These commenters reasoned that 90 days following discharge from
an inpatient hospitalization was the most clinically appropriate length
for the proposed conditions and would enhance the commitment of EPM
participants and their collaborators to caring for patients over time.
They added that this duration would be sufficiently long to capture
many complications of treating EPM clinical conditions and engage
multiple providers in inpatient, outpatient, and post-acute care
provider settings. The commenters believe that the proposed episode
length would move providers closer to achieving long-term population
health management. Several commenters pointed out that hospitals are
well-prepared to assume responsibility for EPM episodes that continue
for 90 days after hospital discharge.
Other commenters stated that the proposed 90-day EPM episode
duration was too long, especially in the context of the proposals to
include a broad array of related items services in EPM episodes. In
general, the commenters who stated for a shorter episode duration
believe that during the early stages of required bundled payment
models, it would be more reasonable for hospitals to assume episode
performance risk for 30 days post-discharge than 90 days as proposed
and that CMS should adopt 30-days post-discharge as the standard EPM
episode duration permanently or temporarily, such as for the first two
model years, and then reevaluate.
Several commenters contended that in using an episode definition
that
[[Page 287]]
includes 90-day post-discharge, CMS was, in effect, making hospitals
managers of population health. These commenters believe that hospitals
lack the resources, skill sets, and infrastructure to engage in the
mission of managing population health, and stated that the requirements
are much different and more complex and demanding than what is need for
episode payments. Several commenters reasoned that since the proposed
quality metrics for the EPMs were 30 days after discharge and they
believe that hospitals are more effective managing the first 30 days of
an episode, the episode duration should be shortened to 30 days so the
quality and performance metrics would be aligned.
A number of commenters requested that CMS shorten the episode
duration to 30 days because 30 days is a more appropriate duration for
exacerbations of existing, unrelated chronic conditions to the
condition that is the focus of the episode. Some commenters claimed
that a post-surgical or post-event episode duration under the AMI,
CABG, and SHFFT models longer than 30 days poses a greater risk for
variability due to medical events outside the intended scope of the
model and control of the hospital. They stated that this is
particularly true for ill patients who are likely to have major
complications or comorbidities when admitted and are at higher risk for
developing new complications post-discharge. The commenters stated that
because all the proposed models are urgent or emergent, rather than
elective or time-sensitive, this danger poses greater concern than
under other Innovation Center episode payment models, such as the CJR
model and OCM. While such comorbidities contributing to all-cause
readmission can be reasonably controlled in the immediate and 30-day
post-operative or post-event period, the commenters contended that the
most complex patients develop complications after discharge, which are
highly varied and predominantly unrelated to the quality of care they
receive. Therefore, they concluded that care for chronic conditions and
other non-anchor MS-DRG-related conditions becomes much more prevalent
in days 31 to 90 following hospital discharge. One commenter observed
based on experience in its hospitals that after 30 days, an over 30
percent increase in readmissions to a hospital other than the original
facility occurred, creating a need for additional strategies to
coordinate episode care after 30 days. The commenters stated that
hospitals do not have the time, money, skill set or recourse to develop
the infrastructure to support episode care management during the 31- to
90-day post-discharge period. Finally, several commenters observed that
Medicare beneficiaries may have more than one residence during the
year, creating challenges with follow up for an episode that extends 90
day following hospital discharge.
Response: We appreciate the support of many commenters for the
proposed 90-day post-hospital discharge EPM episode duration. We agree
with the commenters that the episode duration should capture the
majority of health care services that are related to the episode and be
sufficiently long to include many complications and follow-up care to
the anchor hospitalization. We believe that hospitalization is often a
sentinel event for Medicare beneficiaries, representing an opportunity
for increased care coordination and, in the case of the EPMs, improved
care management of chronic conditions that may have led to the
hospitalization for the cardiac event or cardiac or orthopedic surgery.
This episode duration provides EPM participants with a substantial
period of time in which to work to improve the quality and efficiency
of EPM episode performance for beneficiaries who are hospitalized for
the targeted conditions.
We have substantial BPCI Model 2 experience in testing AMI, PCI,
CABG, and SHFFT episodes that include beneficiaries who are most
similar to those who would be included in the proposed EPMs. Almost all
BPCI Model 2 Awardees testing these episodes have selected the 90-day
episode duration, compared to the 30-day and 60-day alternative
durations that are available in BPCI Model 2. Ninety days post-hospital
discharge is also the episode duration in the CJR model. Our goal in
the EPMs is to incentivize efficient, high quality care that returns
beneficiaries to the community in the best health possible, and we
believe that a 90-day post-discharge duration reflects a full continuum
of clinical services and transition of care for average SHFFT, AMI, and
CABG model beneficiaries, at which time the beneficiary's functional
recovery and stabilization of medical conditions are relatively
complete so the beneficiary is able to resume most usual activities of
daily living.
Similar to LEJR episodes under the CJR model, in our analysis of
episode spending for the EPMs we observed the concentration of Medicare
post-discharge episode spending in the earlier part of the episode
following discharge from the anchor hospitalization in all the
EPMs.\76\ Specifically, in the first 30 days following anchor
hospitalization discharge in AMI episodes, excluding those AMI episodes
with readmissions for CABG for which we make a payment adjustment under
the AMI model as discussed in section III.D.4.b.(2)(c) of this final
rule, we found 61 percent and 54 percent of post-discharge episode
spending for AMI MS-DRG-anchored and PCI MS-DRG-anchored AMI episodes,
respectively. Similarly, in the 30 days following discharge, we
observed 68 percent and 69 percent of post-discharge episode spending
for CABG and SHFFT episodes. For all of the EPMs, about 60 to 70
percent of the remaining post-discharge spending occurred in days 31-60
post-discharge, and one-third in days 61-90 post-discharge. Thus, while
the 90-day post-discharge episode duration increases the EPM
participant's financial risk somewhat compared to episodes that extend
only 30 days, because we found that significant services related to the
clinical condition that is the focus of the models occurred during days
31-90 post-discharge, we believe there are significant opportunities
for improved quality and efficiency in EPM episodes after 30 days and
extending through 90 days post-discharge from the anchor
hospitalization. If, as some commenters speculated, a post-surgical or
post-event episode duration under the AMI, CABG, and SHFFT models
longer than 30 days posed a significant risk of variability primarily
due to medical events that are unrelated to the clinical condition that
is the focus of the EPM episode, we would have expected to see an equal
percentage of post-discharge episode spending in the periods of time
from days 31-60 and 61-90. That was not the case in our analysis,
because we continued to see EPM episode spending as a proportion of
post-discharge spending drop off in relation to increasing time after
discharge, suggesting that the EPM episode definitions are capturing
related episode spending that declines, as would be expected, over the
period of time post-discharge as the beneficiary recovers and returns
to the community.
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\76\ Episodes for AMI, CABG, and SHFFT beneficiaries initiated
by all U.S. IPPS hospitals not in Maryland and constructed using
standardized Medicare FFS Parts A and B claims, as proposed in the
proposed rule, that began in CY 2012-2014.
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While we understand that uncommon events during the 90-day post-
discharge episode duration may occur for an individual beneficiary,
resulting in an unanticipated or unavoidable need for costly health
care services, we believe
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that our EPM episode definitions that exclude unrelated items and
services and our payment policies, namely the adjustment for high
payment episodes and stop-loss policies discussed in sections
III.D.3.d., III.D.7.b.(1), and III.D.7.d. of this final rule, provide
sufficient protections for EPM participants from undue financial
responsibility for the care of unrelated clinical conditions as well as
for unusual circumstances. We also believe that shorter episode
durations may incur a higher clinical risk for beneficiaries if EPM
participants delay services beyond the EPM episode, and the risk to
beneficiaries of this response by providers to episode payment can be
minimized by the longer 90-day episode duration that we proposed for
the EPMs. We refer to sections III.G.4. through 6. of this final rule
for discussion of our plans to monitor for access to care, quality of
care, and delayed care.
In response to the commenters recommending a shorter episode
duration in the earlier stages of bundled payment, as noted previously
we have several years of experience with BPCI Model 2 where the
majority of Awardee have selected a 90-day episode duration for
episodes of a similar design to the EPMs that target the same clinical
conditions. While entities choose to participate in the BPC models, we
have also established a 90-day episode duration in the CJR model, which
is the first episode payment model which has a geographic basis. Thus,
we do not believe that it is necessary to adopt a shorter episode
duration for the EPMs either permanently or temporarily.
Regarding those commenters who believe that the 90-day post
discharge episode duration and broad episode definitions would make
hospitals responsible for population health, we note that the EPMs are
not total cost-of-care models. As discussed in section III.C.3.b of
this final rule, we exclude items and services that are unrelated to
EPM episodes, namely those that are not directly related to the EPM
episode or the quality or safety of the EPM episode care that is
included in the EPM episode; for chronic conditions that are generally
not affected by the EPM episode care; and for acute clinical conditions
not arising from existing EPM episode-related chronic clinical
conditions or complications of EPM episode care. We agree with the
commenters in favor of the proposed 90-day post-discharge episode
duration for the EPMs who stated that the proposed EPMs of this episode
duration move providers closer to long-term population health
management. Given the diversity of commenters' views on hospitals'
readiness to assume responsibility for episodes of the proposed
duration, we appreciate that EPM participants in models where
participation is required are in various stages of readiness for
managing the quality and cost performance of episode, based on their
prior experience, resources, and infrastructure. We believe that all
EPM participants have substantial opportunities to increase their
capacity to manage the quality and cost of EPM episodes and achieve
significant financial rewards from good performance, regardless of
their starting point. We note that many of the EPM policies such as
data sharing, financial arrangements, the phase-in of two-sided risk,
and stop-loss limits afford hospitals the opportunity to learn about
EPM episode care patterns, collaborate with others who have expertise
in care redesign, and implement their initial EPM care plans for their
beneficiaries in an initial environment of limited financial risk.
We do not believe that the measurement period for the quality
measures and the duration of the EPM episodes must necessarily align,
although we note that we sought comment in the EPM proposed rule about
potentially using quality measures that examine patient outcomes over a
period that extends at least as long as the EPM episode (81 FR 50901).
We proposed to use existing AMI and CABG outcome measures that assess
outcomes over a 30-day period following discharge, at least initially,
because they are in wide use and have gained acceptance among hospitals
and because the AMI and CABG mortality measures have been reviewed and
endorsed by the National Quality Forum. However, we believe that 90
days is a period over which hospitals have substantial ability to
influence the quality and efficiency of care that EPM beneficiaries
receive. Rather than shorten EPM episodes to align with the existing
30-day quality measure timeframe as some commenters recommended, we
believe it would be more appropriate to seek to adapt the existing
measures or to develop new related measures to assess outcomes over a
longer timeframe, including timeframes at least as long as the EPMs. We
refer to section III.E.4 of this final rule for further discussion of
our plans regarding future quality measures that could be incorporated
into the EPM pay-for performance methodologies.
Finally, we appreciate the perspective of the commenters who
believe that a 30-day episode duration would be more appropriate
because a longer episode duration poses a greater risk for variability
due to events outside the intended scope of the model and control of
the hospital, including readmissions to a different hospital, and that
this risk is higher for the EPMs than other Innovation Center bundled
payment models due to the urgent or emergent clinical conditions
included in the EPMs. We agree with the commenters that the EPMs test
different clinical scenarios than the CJR model that targets LEJR,
which is primarily elective, and that the complexity of many EPM
beneficiaries requires new approaches to redesigning and coordinating
care for the 90 days post-hospital discharge. While EPM beneficiaries
may be more likely to develop a variety of complications requiring more
related services following discharge than those in the CJR model, we
continue to believe that complications most commonly have patterns and
bear a significant relationship to the quality of care and
effectiveness of care coordination following hospital discharge. Even
though some EPM beneficiaries may be medically complex and fragile, we
continue to believe there are substantial opportunities to improve the
quality and efficiency of their care under the EPMs where EPM
participants have quality and cost performance responsibility for
episodes that extend 90-day post-discharge from the anchor
hospitalization. We also agree with the commenters that EPM
participants who are required to participate in the EPMs be protected
from undue financial risk. We refer to section III.D.4.b.(2) of this
final rule for further discussion of risk adjustment under the EPMs.
Final Decision: After consideration of the public comments
received, we are finalizing the proposals in Sec. Sec. 512.240(a)(1),
(b)(1), and (c)(1) for the end of AMI, CABG, and SHFFT episodes,
respectively, based on an EPM episode duration that extends 90 days
following discharge from the anchor hospitalization, with modification
to revise Sec. 512.240(a)(1) to eliminate proposed paragraphs
(a)(1)(i) and (ii) and incorporate the 90-day post-discharge episode
duration in the general provision. We no longer need to specify the
episode duration separately for an AMI episode that includes an
inpatient-to-inpatient transfer after an AMI episode has been initiated
because we are not adopting the proposed policies for chained anchor
hospitalizations. As discussed in section III.C.4.a.(5). of this final
rule, we are not finalizing the AMI model transfer episode initiation
and attribution proposal that would have required us to
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identify chained anchor hospitalizations.
D. Methodology for Setting EPM Episode Prices and Paying EPM
Participants in the AMI, CABG, and SHFFT Models
1. Background
a. Overview
We proposed that the AMI, CABG, and SHFFT models would provide
incentives for EPM participants to work with other health care
providers and suppliers to improve the quality and efficiency of care
for Medicare beneficiaries by paying EPM participants or holding them
responsible for repaying Medicare based on EPM participants'
performance with respect to the quality and spending for AMI, CABG, and
SHFFT episodes in a manner similar to the CJR model. Given the general
similarity between the design of the CJR model and these EPMs, there is
precedent for adopting the general payment and pricing parameters used
under the CJR model, with modification to appropriately pay for EPM
episodes that include the different clinical conditions treated in AMI,
CABG, and SHFFT model episodes. The following sections describe our
proposals for the:
Performance year, retrospective episode payments, and two-
sided risk EPMs.
Adjustments to actual EPM-episode payments and to
historical episode payments used to set episode prices.
EPM episode price-setting methodologies.
Process for reconciliation.
Adjustments for overlaps with other Innovation Center
models and CMS programs.
Limits or adjustments to EPM participants' financial
responsibility.
b. Key Terms for EPM Episode Pricing and Payment
For purposes of ease of understanding of the technical discussion
that follows around EPM episode pricing and payment, our proposed rule
provided the following definitions of terms that were used in sections
that precede their technical definition and cross-references to other
sections of the proposed rule for more detailed discussion of the
policies associated with these terms.
Anchor hospitalization--hospitalization that initiates an
EPM episode and has no subsequent inpatient-to-inpatient transfer
chained anchor hospitalization.
Chained anchor hospitalization--an anchor hospitalization
that initiates an AMI model episode and has at least one subsequent
inpatient-to-inpatient transfer.
Anchor MS-DRG--MS-DRG assigned to the first
hospitalization discharge, which initiates an EPM episode.
Price MS-DRG--for EPM episodes without a chained anchor
hospitalization, the price MS-DRG is the anchor MS-DRG. For AMI model
episodes with a chained anchor hospitalization, the price MS-DRG is the
MS-DRG assigned to the AMI model episode according to the hierarchy
that was described in III.D.4.b.(2)(i) of the proposed rule.
Episode benchmark price--dollar amount assigned to EPM
episodes based on historical EPM-episode data (3 years of historical
Medicare payment data grouped into EPM episodes according to the EPM
episode definitions as discussed in sections III.C.3. and III.C.4. of
the proposed rule) prior to the application of the effective discount
factor, as described throughout sections III.D.4.b through e. of the
proposed rule.
CABG readmission AMI model episode benchmark price--
episode benchmark price assigned to certain AMI model episodes with
price MS-DRG 280-282 or 246-251 and with a readmission for MS-DRG 231-
236, as described in sections III.D.4.b.(2)(c) and III.D.4.e. of the
proposed rule.
Quality-adjusted target price--dollar amount assigned to
EPM episodes as the result of reducing the episode benchmark price by
the EPM participant's effective discount factor based on the EPM
participant's quality performance, as described in sections
III.D.4.b.(10) and III.E.3.f. of the proposed rule.
Excess EPM-episode spending--dollar amount corresponding
to the amount by which actual EPM-episode payments for all EPM episodes
attributed to an EPM participant exceed the quality-adjusted target
prices for the same EPM episodes, as discussed in section III.D.2.c. of
the proposed rule.
2. Performance Years, Retrospective Episode Payments, and Two-Sided
Risk EPMs
a. Performance Period
Consistent with the methodology for the CJR model, we proposed 5
performance years (PYs) for the EPMs, which would include EPM episodes
for the periods displayed in the following Table 9:
Table 9--Proposed Performance Years for EPMs
----------------------------------------------------------------------------------------------------------------
Performance year (PY) Calendar year EPM episodes included in performance year
----------------------------------------------------------------------------------------------------------------
1............................................ 2017 EPM episodes that start on or after July 1, 2017
and end on or before December 31, 2017.
2............................................ 2018 EPM episodes that end between January 1, 2018 and
December 31, 2018, inclusive.
3............................................ 2019 EPM episodes that end between January 1, 2019 and
December 31, 2019, inclusive.
4............................................ 2020 EPM episodes that end between January 1, 2020 and
December 31, 2020, inclusive.
5............................................ 2021 EPM episodes that end between January 1, 2021 and
December 31, 2021, inclusive.
----------------------------------------------------------------------------------------------------------------
As displayed in Table 9, some EPM episodes that would begin in a
given calendar year may be captured in the following performance year
due to some EPM episodes ending after December 31st of a given calendar
year. For example, EPM episodes beginning in December 2017 and ending
in March 2018 would be part of performance year 2. As we noted in our
proposed rule, we believe that the proposed period of time for the
EPMs, which generally aligns with the performance period for other
Innovation Center models, for example, the CJR and Pioneer ACO models,
should be sufficient to test and gather the data needed to evaluate the
EPMs (80 FR 73325). In contrast, we were concerned whether an EPM with
fewer than 5 performance years would be sufficient for these purposes.
We considered extending the first PY, for example, to 18 months. As
discussed further in section III.D.2.c. of the proposed rule, however,
we instead proposed to delay the requirement for participants to begin
accepting downside risk until the second quarter of PY2. As such, EPM
participants would have a comparable transition period to that of CJR
participants with respect to when they must accept downside risk while
still allowing us to make timely reconciliation payments to EPM
participants as well as to most effectively align EPM reconciliation
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with the reconciliation processes for other models and programs with
which the EPMs overlap (for example, the Shared Savings Program,
Pioneer ACO model, Comprehensive Primary Care Initiative, and Oncology
Care Model). As stated in our proposed rule, we believe that it is
important to synchronize the timing of reconciliation for EPMs with
other efforts that need this information when making their financial
calculations. We sought comment on this proposal.
The following is a summary of the comments received and our
responses.
Comment: Many commenters requested that CMS delay implementation of
the models; typically, for at least 6 months to a year--or a year from
the final rule's issuance--so that participants would have a sufficient
time to prepare for the new models. Some commenters recommended
delaying the models entirely until CMS had additional time to consider
evaluation results for BPCI or the CJR model. Other commenters
recommended a phased-in approach for implementing the models, for
example, by (1) first implementing the SHFFT model no sooner than
January 1, 2018 and then implementing the cardiac EPM models no sooner
than 6 months later as well as additional time if the final rule is
delayed beyond January 1, 2018 or (2) conversely delaying the SHFFT
model, given that hospitals are in the early stages of building
infrastructure for the CJR model and having to do so for the SHFFT
model as well could be too great a burden. A commenter recommended that
CMS delay the start date to January 1, 2018 as it would better align
with private payers' regulatory and business models, which are also
developing and rolling out bundled payment models. In their view, this
synchronization would reduce burden by simplifying record keeping
requirements, performance metric submission, and financial tracking by
both CMS and private payers.
Among the reasons cited for a delay, some commenters expressed
concern with the rapid pace of implementing additional models--
particularly, geographic-based models, which a number of commenters
have said they oppose. For example, commenters expressed concerns that
CMS was moving forward with new models in the absence of empirical
results from the CJR model or promising results from BPCI.
Specifically, results from the evaluation of year 2 results for BPCI
showed no statistically significant difference in Medicare payments and
an increase in mortality for the cardiovascular surgical episodes
between the BPCI participants (which were voluntary), and comparison
groups. Further, while there was a significant reduction in utilization
of institutional post-acute care settings, there were instances where
BPCI patients exhibited less functional improvement. As one commenter
noted, CMS has not yet been able to ensure that the quality of care and
beneficiary outcomes under the model are at least equivalent, if not
better than, those in traditional fee-for-service Medicare.
Commenters also pointed to the pre-implementation efforts that
would be needed for participants to be successful with episode payment
bundles, which they believe would take more time than would be granted
under the proposal. For example, hospitals need more time than proposed
to better understand the models' requirements and clinical and
financial risk of their patient populations; build the clinical, legal,
financial and quality infrastructure; analyze and understand the
clinical and cost factors that affect their performance; and identify
changes to care pattern to be successful. Moreover, there is
considerable variation in hospital preparedness and capabilities to
implement these models without a delay as well as challenges in doing
so while simultaneously fulfilling the requirements of multiple models
including the CJR model, MACRA, and the end of the grace period for
ICD-10.
A commenter noted that, given the broad-based clinical experience
with continuity-of-care across episodes, appropriate workforce capacity
and technology infrastructure, and significant investment by both the
public and private sectors needed to be successful, the cardiac models
could be particularly challenging. Further, these challenges could be
especially acute for small hospitals that often have limited financial
resources, have low case volume across which to spread financial
experience, have high amounts of uncompensated care or are located in
lower income geographic regions, do not yet have experience with
episode-based payments, or lack existing networks with physicians and
other providers. In addition to provider readiness, a commenter
questioned whether CMS has the administrative and personal resources to
manage the complexities of the newly proposed and expanded models in a
way that would meet hospitals' needs to be successful under the models.
Another commenter believed that, despite CMS proposing certain waivers
under the models, insufficient protections existed with regard to
regulatory and legal risk.
Response: We appreciate the concerns commenters expressed on our
proposed start date as well as their requests to delay the proposed
models. Our general goals for the proposed models are to improve care
quality for Medicare beneficiaries and efficiency in service delivery
to better control growth in Medicare spending. Hence, we wish to move
forward in implementing the proposed models as quickly as is reasonably
possible. Many commenters expressed concerns about their readiness to
participate in the models under our proposal; particularly, with the
requirement to assume downside risk within 6 months of the models being
implemented. We understand these concerns and share in hospitals'
desire to be successful in improving care and increasing efficiencies
under the models so that they earn reconciliation payments and Medicare
and its beneficiaries realize improvements in care and efficiency.
Thus, while we are not proposing to delay implementation of the models,
as discussed in section III.D.2.c. of this final rule, we are modifying
our proposal requiring participants to assume downside risk in the
second quarter of PY2 so that they would have an additional 9 months of
experience in the models without assuming downside risk. EPM
participants would not be required to assume downside risk for episodes
until PY3, but could voluntarily elect to do so in PY2. We believe that
delaying the requirement for participants to assume downside risk under
the models appropriately balances our interests in implementing the
models in a timely way with the concerns and interests of participants
with respect to their readiness to participate successfully in the
models as well as accommodate to the proposed requirements in
conjunction with other requirements under the Medicare program. As
such, we do not believe it is also necessary to further delay or phase-
in the models. Likewise, we do not believe it is necessary to delay our
models so that they are better aligned with private payer models. We
would further note that, beginning in PY2, our proposed models would
already follow the period suggested for this alignment to occur.
We do not agree with commenters that the models should be delayed
until additional BPCI or CJR model results are considered or in light
of the BPCI year 2 results. The currently proposed models will test
geographic-based bundled payments with a broader, more diverse, and
different group of participants or episodes than is the case
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with BPCI or the CJR model, which will expand our understanding of
these models with a broader and more complex array of conditions and
procedures. We also do not believe that the unique challenges that
could be presented under the cardiac models is a reason to delay the
models. Rather, among other things, we would expect these models to
assist us in empirically identifying what challenges there may be as
well as the steps needed to overcome them. We also share commenters'
concerns that smaller hospitals be successful under the models.
Accordingly, our proposed rule included additional protections to limit
financial risk for certain hospitals, including rural hospitals and
sole community hospitals, through more generous stop loss thresholds,
which we finalized in section III.D.7.c.(1) of this final rule. Also,
as discussed further in section III.D.7.c.(1) of this final rule, we
are extending these protections to hospitals determined to have a low
volume of episodes under an EPM.
We appreciate the comment on whether CMS is prepared
administratively and with respect to personnel resources to implement
the models, and note that the proposed models would not be implemented
in the absence of our readiness to do so. Finally, we have considered
and made final a range of waivers of program rules and provisions for
financial arrangements that we believe are necessary and sufficient to
facilitate participation in the models through allowing additional
flexibilities in care delivery and giving participants to the tools to
align the financial incentives of other providers, suppliers, and ACOs
with the goals of the EPMs (see sections III.I. and III.J. of this
final rule).
Final Decision: After consideration of the public comments
received, we are finalizing the proposal, without modification, to
establish five performance years beginning with EPM episodes that start
on or after July 1, 2017 as displayed in Table 10.
Table 10--Final Performance Years for EPMs
----------------------------------------------------------------------------------------------------------------
Performance year (PY) Calendar year EPM episodes included in performance year
----------------------------------------------------------------------------------------------------------------
1............................................ 2017 EPM episodes that start on or after July 1, 2017
and end on or before December 31, 2017.
2............................................ 2018 EPM episodes that end between January 1, 2018 and
December 31, 2018, inclusive.
3............................................ 2019 EPM episodes that end between January 1, 2019 and
December 31, 2019, inclusive.
4............................................ 2020 EPM episodes that end between January 1, 2020 and
December 31, 2020, inclusive.
5............................................ 2021 EPM episodes that end between January 1, 2021 and
December 31, 2021, inclusive.
----------------------------------------------------------------------------------------------------------------
b. Retrospective Payment Methodology
Consistent with the CJR model (80 FR 73329), we proposed to apply a
retrospective payment methodology to the proposed EPMs (81 FR 50844).
Under this proposal, all providers and suppliers caring for Medicare
beneficiaries in EPM episodes would continue to bill and be paid as
usual under the applicable Medicare payment systems. After the
completion of an EPM performance year, Medicare claims for services
furnished to EPM beneficiaries would be grouped into EPM episodes and
aggregated, and EPM participants' actual EPM episode-payments would be
compared to quality-adjusted target prices (which account for the level
of EPM episode quality), as described in section III.D.5.a. of the
proposed rule (81 FR 50864 through 50865). Based on an EPM
participant's performance (taking into account quality and spending),
we would determine if Medicare would make a payment to the participant
(reconciliation payment), or if the participant owes money to Medicare
(resulting in Medicare repayment).
We considered an alternative option of paying for EPM episodes
prospectively by paying one lump sum amount to the EPM participant for
the expected spending for the EPM episode which extends 90 days post-
hospital-discharge. However, as was the case when we established
regulations for the CJR model (80 FR 73329), we believed that such an
option would be challenging to implement at this time given the payment
infrastructure changes for both EPM participants and Medicare that
would need to be developed to pay and manage prospective episode
payments under these EPMs. Moreover, we continued to believe that a
retrospective payment approach can accomplish the objective of testing
episode payments in a broad group of hospitals, including financial
incentives to streamline care delivery around that episode, without
requiring core billing and payment changes by providers and suppliers,
which would create substantial administrative burden.
We sought comment on this proposal. The following is a summary of
the comments received and our responses.
Comment: Most of the comments supported CMS' proposal to use a
retrospective payment methodology. Commenters agreed with CMS' view
that this would be the most administratively feasible and
straightforward payment option since it uses the existing payment
system infrastructure and processes. Some of these commenters reported
that alternatively applying a prospective payment methodology, which
would make one lump sum payment to the hospital for the episode, would
be challenging to implement given the administrative and infrastructure
changes it would entail for hospitals, other participating providers
and Medicare. One commenter expressed concern that our proposed models
would, in fact, require all payments be made to the responsible
hospital so that other providers would have to submit bills for
services they provided under an EPM episode to that hospital, which the
commenter believed could result in both decreased access to care and
increased administrative complexity.
Response: We appreciate the comments we received that were in
support of our proposed retrospective payment methodology, and concur
with commenters' views on some of the benefits of this model. We would
clarify that, as stated previously in this section, all providers and
suppliers caring for Medicare beneficiaries in EPM episodes would
continue to bill and be paid as usual under the applicable Medicare
payment systems. As such, providers would submit claims for payment as
they always have and would not submit claims to the responsible
hospital.
Comment: While not opposing the proposal, a commenter expressed the
view that a retrospective model should be viewed as a stepping stone
toward rather than the destination to requiring greater levels of
financial risk. In their view, disadvantages of a retrospective model
include their potential to reduce spending within an episode of care
but not the volume of the episodes themselves, which could encourage a
greater number of bundled procedures;
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fragmentation of care delivery due to the existence of multiple bundled
payment programs designed around different disease states or
procedures; and the potential that the considerable cost and effort
expended to organize people and systems around each bundled episode
could cause the total cost of these programs combined to be higher than
the cost associated with operating a single program covering the full
population and the full spectrum of care. As such, the commenter
supported the proposed bundled payments for a limited time and for the
purpose of stimulating efforts to full population based efforts.
Response: We understand the commenter's view that bundled payments
could be a stepping stone toward other models that establish greater
risk for providers and recognize the various limitations of a fee-for-
service system with respect to higher volume of services and less
coordinated delivery of care. In contrast to the commenter, however, we
believe in and hence are empirically testing within our proposed models
the potential to improve upon these dimensions as well as assist in
lowering the cost of services within a fee-for-service rather than
capitated framework.
Comment: Some commenters opposed the proposed retrospective
methodology. For example, a commenter reported their view that the
proposed retrospective payment model would limit the possibility for
real, innovative care redesign because it (1) offered no upfront
incentive dollars to invest in new care delivery models and services
that could deliver true value and (2) confined innovation care redesign
by what the FFS structure will reimburse. That is, while participants
would be held financially accountable for ensuring that care is
delivered below the quality-adjusted target price, they could do little
to affect the costs for the episode within their own setting as they
continue to receive a MS-DRG payment for the diagnosis regardless of
whether the patient stays a longer or shorter period of time,
additional services are offered, or care coordination is provided.
Thus, if a participant seeks to reduce costs, it is limited to reducing
readmissions, improving care transitions, or reducing post-acute care
costs--either by reducing the length of stay within a SNF (as it is
paid on a per diem) or through substitutions of care (for example,
directly discharging the patient home with or without services). In
this commenter's view, significant care redesign would be better
facilitated through providing a group of provider partners with a
prospective payment.
Similarly, a commenter suggested that participants are impeded in
their ability to plan for the delivery of services if they do not know
how much money will be available to support those services. As such,
participants should have a risk-adjusted budget for the condition or
episode in advance rather than after care has already been delivered.
Further, payment amounts should be based on the actual costs of all of
the services being delivered, not just the amounts that would have been
paid under the fee-for-service system for the subset of services that
would have been separately billable. As such, the commenter recommended
that participants and their collaborators be paid for high-value
services that are not currently billable as part of condition-based and
episode-based payment models if providers have agreed to be accountable
for overall spending related to a condition or episode.
Another commenter recommended that CMS determine payment benchmarks
through negotiated rates or competitive bids (rather than fee-for-
service claims) as it would foster more rapid transformation in cost
and resource use as well as encourage competition among providers to
achieve the best outcomes for the lowest cost. In their view, a
prospective negotiated rate would offer providers more opportunity to
innovate in how they deploy professional staff, choose technology, and
engage with outpatient and home-based services. Also, a prospectively
negotiated case rate would foster collaboration among all clinicians
involved in patient care and provide predictable pricing.
Response: We appreciate the concerns and challenges raised by these
commenters, but are not persuaded to change our methodology. Rather, we
believe that participants are capable of innovative care redesign in
the absence of upfront incentives dollars and within the constraints of
fee-for-service Medicare payment requirements. While our proposal did
not provide participants with an up-front budget or a capitated payment
amount, we would be providing them detailed information on their
benchmark and likely quality-adjusted target prices as well as their
financial performance both historically and during their participation
in the models (see section III.K. of this final rule). We believe this
information should be sufficient to enable participants' abilities to
assess their performance as well as determine and plan changes in their
practices to make them successful. Also, where appropriate, we have
offered participants improved flexibilities under the models by waiving
certain Medicare requirements and allowing for financial arrangements,
which should facilitate their participation under the models (see
sections III.I. and III.J. of this final rule). To the extent, we
identify additional adjustments, we could consider them through future
rulemaking. Finally, while we wish to explore and test a range of
payment models, which could include capitated or competitive bidding
models, the purpose of the proposed models is to examine ways in which
to improve health care quality and reduce costs in a fee-for-service
framework.
Final Decision: After consideration of the public comments
received, we are finalizing the proposal, without modification to
implement a retrospective payment methodology. Also, we would like to
clarify that when referring to Medicare claims data for services
furnished to EPM beneficiaries, as we have stated immediately here and
throughout this section, we mean any payment from the Part A or Part B
trust fund on behalf of a beneficiary that is not specifically excluded
as specified in section III.C. or III.D.6 of this final rule.
Consistent with this, we have made conforming changes to our regulatory
text--specifically, to our definition of actual episode payments as
well as to Sec. 512.305(c)(1) and Sec. 512.307(a)(1).
c. Two-Sided Risk EPMs
As we did for the CJR model (80 FR 73229 through 7333), we proposed
to establish two-sided risk for EPM participants (81 FR 50844). Under
this proposal, for each of performance years 1 through 5, we would make
EPM-episode reconciliation payments to EPM participants that achieve
reduced actual EPM payments relative to their quality-adjusted target
prices. Likewise, beginning with episodes ending in the second quarter
of performance year 2 and extending through each of performance years 3
through 5, we would hold EPM participants responsible for repaying
Medicare when their actual EPM-episode payments exceed their quality-
adjusted target prices. As such, our proposal differed from CJR in that
we proposed a modestly shorter period in which EPM participants would
accept downside risk in order to allow them a comparable transition
period to that of CJR participants in which to do so. Accordingly, we
referred to the two portions of performance year 2 as either having no
downside risk (NDR) or having downside risk (DR); specifically--
Performance Year 2 (NDR) or PY 2 (NDR) for the first
quarter, that is
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January 1, 2018 to March 31, 2018, in which EPM participants assume no
downside risk and therefore would have no Medicare repayment
responsibility; and
Performance Year 2 (DR) or PY 2 (DR) for the second, third
and fourth quarters, that is April 1, 2018 to December 31, 2018, in
which EPM participants assume downside risk and would have Medicare
repayment responsibility.
Our proposed rule noted our continued belief that our proposal to
establish two-sided risk would provide appropriate incentives for EPM
participants to improve their care quality and efficiency under the
EPMs, and that we would diminish these incentives if we instead
proposed to establish one-sided risk, in which an EPM participant could
qualify for a reconciliation payment but not be held responsible for
Medicare repayments. In recognition that EPM participants may need to
make infrastructure, care coordination and delivery, and financial
preparations for the EPMs, which can take several months or longer to
implement, we thought that it was reasonable to delay EPM participant
responsibility for repaying excess EPM-episode spending in performance
year 1 to more strongly align EPM-participant incentives with care
quality. Thus, similar to what we did for the CJR model, we proposed to
phase-in this repayment responsibility beginning in the second quarter
of EPM performance year 2 as displayed in Table 11 (81 FR 50844 through
50845).
Table 11--Proposed Stop-Loss Thresholds and Discount Percentage Ranges for Medicare Repayments by PY
--------------------------------------------------------------------------------------------------------------------------------------------------------
Performance year PY1 PY2 (NDR) PY2 (DR) (%) PY3 (%) PY4 (%) PY5 (%)
--------------------------------------------------------------------------------------------------------------------------------------------------------
Stop-loss threshold..................................... n/a as no downside risk in PY1 5 10 20 20
or first quarter of PY2
Discount percentage (range) for Repayment, Depending on 0.5-2.0 0.5-2.0 1.5-3.0 1.5-3.0
Quality Category.......................................
--------------------------------------------------------------------------------------------------------------------------------------------------------
* Stop-loss thresholds for certain hospitals, including rural and sole-community hospitals are 3% for PY2 (DR) and 5% for PY3-PY5.
We refer to section III.E.3.f. of this final rule for additional
information on the effective discount factors used to calculate
quality-adjusted target prices, as well as the quality categories that
determine an EPM participant's effective discount factor that would be
applied to the EPM benchmark episode price at reconciliation to
calculate the repayment amount during the phase-in period under the
models.
We sought comment on this proposal. The following is a summary of
the comments received and our responses.
Comment: A number of commenters supported CMS' proposal to phase-in
downside risk noting that doing so would allow providers with little or
limited experience and who were not ready to take on risk additional
time to prepare to do so. However, nearly all of the commenters on this
proposal urged CMS to extend the period of time during which
participants would not be subject to downside risk as 6 months would
not be an adequate timeframe in which to begin managing episodes that
will be subject to downside risk. A number of commenters noted that
because of the way that episodes are defined during a performance year,
participants would actually have only 6 months before episodes that
will incur downside risk begin. This is because the models would begin
on July 1, 2017 and downside risk would begin for episodes ending April
1, 2018 and later. However, episodes that end April 1, 2018 would have
begun over 90 days earlier, or prior to January 1, 2018. Therefore,
participants would actually only have from July 1, 2017 until about
January 1, 2018 before episodes that will incur downside begin.
Most of the commenters requested a 12-month period during which
participants would not be required to assume downside risk with some
commenters requesting longer periods, for example, up to 2 years. In
some cases, commenters requested that CMS delay the requirement to
assume downside risk, but to allow participants flexibility to assume
risk earlier if they wished to do so. A commenter requested that CMS
stagger downside risk across the models, for example, allow a longer
period without downside risk for AMI episodes than for CABG episodes as
the commenter believed there was greater complexity and uncertainty
associated with the former than the latter. Additionally, several
commenters opposed the proposal to require downside risk altogether or
asking that CMS make this requirement contingent upon also further
risk-adjusting target prices and financial performance data.
The reasons offered for delaying downside risk often paralleled
those for delaying the models in general--that is, additional time is
needed to develop infrastructure and expertise with the models. Some
commenters raised concerns about the effects of the proposal on
beneficiary access; particularly, for smaller hospitals and academic
medical centers. As such, a commenter expressed support for CMS' plans
to monitor access and recommended that CMS publish data and consider
alternatives if this is found among complicated AMI or CABG cases.
A commenter suggested that CMS completely waive downside risk for
certain protected hospitals such as SCHs, MDHs, RRCs, and low-volume
hospitals. Another commenter stated that participants should not have
to take on additional risk given they are already facing payment
reductions through other efforts such as those for the HRRP. If
participants must face downside risk through the proposed models, the
commenter requested that CMS exclude conditions under the model from
the HRRP. Some commenters pointed to delays in receiving performance
data from CMS as well as time need to review these data needed to
assist them in assessing and adjusting care patterns. Commenters also
noted that because not all participants have had experience with
bundled payment models, they are likely not ready to assume downside
risk.
In addition to comments requesting that CMS delay downside risk,
commenters also requested that EPM participants be permitted to
voluntarily adopt downside risk sooner, for example, to fulfill one of
the requirements to qualify as participating in an Advanced APM.
Response: We appreciate comments supporting our proposal to phase-
in downside risk. We are also persuaded by commenters that delaying the
date by which participants would be required to
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assume downside risk would improve participants' ability to
successfully achieve the goals of the models. Accordingly, we are
revising our proposal so that participants in the proposed models would
not be required to assume downside risk until PY3--that is, episodes
ending on or after January 1, 2019, with anchor discharges that occur
on or after October 4, 2018. We believe that this delay period
appropriately balances participants' desire for additional experience
under the models in the absence of downside risk with our desire to
establish appropriate incentives for improved care quality and cost
control. Given we believe this delay period is sufficient for all
models, we do not believe it necessary to stagger downside risk
separately by model. We also disagree with comments opposing our
proposal to require downside risk or asking that CMS make this
requirement contingent upon our also further risk-adjusting target
prices and financial performance data. First, we believe downside risk
is necessary for purposes of establishing appropriate provider
incentives. Second, as discussed in section III.D.4.b.(2). of this
final rule, we plan to explore additional risk-adjustment options that
could be implemented beginning in PY3 and would thus apply to episodes
that would be subject to downside risk for all participants.
While we are delaying the requirement to assume downside risk under
the models, we have decided to allow EPM participants, including those
seeking to qualify as participating in an Advanced APM, to voluntarily
begin to assume downside risk for episodes ending on or after January
1, 2018, with anchor discharges that occur on or after October 4, 2017.
Table 12 presents our final policies for phasing-in downside risk for
all participants, along with associated stop-loss limits and discount
percentages, for participants that voluntarily assume risk on this
accelerated schedule.
We appreciate the concerns raised on the potential effects of our
proposal on beneficiary access to care, and would note that we have
made final a range of quality measures (see section III.E. of this
final rule), monitoring activities (see section III.G. of this final
rule), and compliance efforts (see section III.F. of this final rule)
that would address beneficiary access issues. We disagree with the
suggestions to waive downside risk for certain protected hospitals such
as SCHs, MDHs, RRCs, and low-volume hospitals or given that hospitals
are already facing payment reductions through other efforts. We believe
that the additional protections we included, which limit total
financial risk under the models for these protected hospitals, are
sufficient (see section III.D.7.c.(2). of this final rule). We also
recognize that while a participant could experience payment reductions
under both the proposed models and the HRRP, we disagree that they
should be held harmless from either of these potential reductions. The
payment reductions participants would potentially face under the
proposed models are not dissimilar to the potential reductions
hospitals already simultaneously face for programs such as the HRRP,
HAC, and EHR incentives without exemption.
Final Decision: After consideration of the public comments
received, we are finalizing the proposal, with modification, to phase-
in downside risk. Accordingly, we are delaying the requirement to
assume downside risk by 9 months so that episodes ending on or after
January 1, 2019 would assume downside risk as compared to our proposal
that would have required this for episodes that ended on or after April
1, 2018 and beyond. Also, we are allowing participants to voluntarily
elect downside risk for episodes ending on or after January 1, 2018.
Table 12 presents our final policies on this in conjunction with
modified stop-loss thresholds and discount percentages by performance
year. These final policies are further discussed in sections
III.D.7.b.(1), III.D.7.c.(1) and III.E.3.f of this final rule,
respectively.
Table 12--Final Stop-Loss Thresholds and Discount Percentage Ranges for Medicare Repayments by PY
----------------------------------------------------------------------------------------------------------------
PY1 PY2 (%) PY3 (%) PY4 (%) PY5 (%)
----------------------------------------------------------------------------------------------------------------
Downside Risk for All Participants--DR effective for episodes ending on or after 1/1/2019
(anchor discharges occurring on or after 10/4/2018)
----------------------------------------------------------------------------------------------------------------
Stop-loss threshold............. n/a as no downside risk in PY1 5 10 20
and PY2 without election of
voluntary downside risk for
PY2
Stop-loss threshold for certain 3 5 5
hospitals *....................
Discount percentage (range) for 0.5-2.0 0.5-2.0 1.5-3.0
Repayment, Depending on Quality
Category.......................
----------------------------------------------------------------------------------------------------------------
Voluntary Downside Risk--DR effective for episodes ending on or after 1/1/2018
(anchor discharges occurring on or after 10/4/2017)
----------------------------------------------------------------------------------------------------------------
Stop-loss threshold............. n/a as no 5 5 10 20
downside risk
in PY1
Stop-loss threshold for certain .............. 3 3 5 5
hospitals *....................
Discount percentage (range) for .............. 0.5-2.0 0.5-2.0 0.5-2.0 1.5-3.0
Repayment, Depending on Quality
Category.......................
----------------------------------------------------------------------------------------------------------------
* Including rural and sole-community hospitals, rural referral centers, Medicare Dependent Hospitals and
hospitals determined to be EPM volume protection hospitals within an EPM.
[[Page 295]]
3. Adjustments to Actual EPM-Episode Payments and to Historical Episode
Payments Used To Set Episode Prices
a. Overview
Using Medicare payments for Parts A and B claims for services
included in the EPM episode definitions, we proposed to calculate
historical episode payments (3 years of historical Medicare payment
data grouped into EPM episodes), EPM-quality-adjusted target prices,
and actual EPM-episode payments according to the EPM episode
definitions as discussed in sections III.C.3. and III.C.4. of the
proposed rule (81 FR 50829 through 50843) as we did for the CJR model.
As was the case for the CJR model (80 FR 73330 through 73336), we also
proposed to include certain payment adjustments in the EPMs for: (1)
Special payment provisions under existing Medicare payment systems; (2)
payments for services that straddle episodes; and (3) high payment
episodes (81 FR 50846). We also proposed to additionally include an
adjustment for reconciliation payments and Medicare repayments when
updating EPM participant episode benchmark and quality-adjusted target
prices (81 FR 50847). We refer to section III.D.6. of the proposed rule
for discussion of adjustments for overlaps with other Innovation Center
models and CMS programs (81 FR 50867 through 50872).
b. Special Payment Provisions
Many of the existing Medicare payment systems have special payment
provisions that have been created by regulation or statute to improve
quality and efficiency in service delivery. IPPS hospitals are subject
to incentives under the HRRP, the HVBP Program, the Hospital-Acquired
Condition (HAC) Reduction Program, and the HIQR Program and Outpatient
Quality Reporting (OQR) Program. IPPS hospitals and CAHs are subject to
the Medicare Electronic Health Record (EHR) Incentive Program.
Additionally, the majority of IPPS hospitals receive additional
payments for Medicare Disproportionate Share Hospital (DSH) and
Uncompensated Care, and IPPS teaching hospitals can receive additional
payments for Graduate Medical Education (GME) and Indirect Medical
Education (IME). IPPS hospitals that meet certain requirements related
to low volume Medicare discharges and distance from another hospital
receive a low volume add-on payment. Also, some IPPS hospitals qualify
to be sole community hospitals (SCHs) or Medicare Dependent Hospitals
(MDHs), and they may receive enhanced payments based on cost-based
hospital-specific rates for services; whether a SCH or MDH receives
enhanced payments may vary year to year, in accordance with Sec.
419.43(g) and Sec. 412.108(g), respectively.
Medicare payments to providers of post-acute care services,
including IRFs, SNFs, IPFs, HHAs, LTCHs, and hospice facilities, are
conditioned, in part, on whether the provider satisfactorily reports
certain specified data to CMS: Inpatient Rehabilitation Facility
Quality Reporting Program (IRF QRP); Skilled Nursing Facility Quality
Reporting Program (SNF QRP); Inpatient Psychiatric Facility Quality
Reporting Program (IPF QRP); Home Health Quality Reporting Program (HH
QRP); Long-Term Care Hospital Quality Reporting Program (LTCH QRP); and
Hospice Quality Reporting Program. Additionally, IRFs located in rural
areas receive rural add-on payments, IRFs serving higher proportions of
low-income beneficiaries receive increased payments according to their
low-income percentage (LIP), and IRFs with teaching programs receive
increased payments to reflect their teaching status. SNFs receive
higher payments for treating beneficiaries with human immunodeficiency
virus (HIV). HHAs located in rural areas also receive rural add-on
payments.
Ambulatory Surgical Centers (ASCs) have their own Quality Reporting
Program (ASC QRP). Physicians also have a set of special payment
provisions based on quality and reporting: Medicare EHR Incentive
Program for Eligible Professionals; Physician Quality Reporting System
(PQRS); and Physician Value-based Modifier Program.
Consistent with how we determine payments under the CJR model (80
FR 73333), we proposed to adjust both the actual and historical EPM-
episode payments used to set EPM-episode benchmark and quality-adjusted
target prices by excluding these special payments from EPM-episode
calculations using the CMS Price Standardization methodology (81 FR
50846). Our proposed rule noted our view that in applying this
methodology to exclude these payments from our calculations, we would
best maintain appropriate incentives for both the EPMs and the existing
incentive programs. Also, not excluding add-on payments based on the
characteristics of providers caring for EPM beneficiaries, such as more
indigent patients, having low Medicare hospital volume, being located
in a rural area, supporting greater levels of physician training, and
having a greater proportion of beneficiaries with HIV, from actual EPM-
episode payments could inappropriately result in certain EPM
participants that receive more add-on payments having worse episode
payment performance compared to quality-adjusted target prices than
what their performance would otherwise have been. Additionally, not
excluding enhanced payments for MDHs and SCHs could result in higher or
lower quality-adjusted target prices just because EPM participants
received their enhanced payments in 1 historical year but not the
other, regardless of actual utilization. We also noted that excluding
special payments would ensure an EPM participant's actual episode
payment performance is not artificially improved or worsened because of
payment reduction penalties or incentives or enhanced or add-on
payments, the effects of which we were not intending to test under the
models. In addition to the various incentives, enhanced payments, and
add-on payments, we noted that sequestration came into effect for
Medicare payments for discharges on or after April 1, 2013, per the
Budget Control Act of 2011 and delayed by the American Taxpayer Relief
Act of 2012. Sequestration applies a 2-percent reduction to Medicare
payment for most Medicare FFS services.
For more information on the CMS Price (Payment) Standardization
Detailed Methodology, we referred to the QualityNet Web site at https://www.qualitynet.org/dcs/ContentServer?c=Page&pagename=QnetPublic%2FPage%2FQnetTier4&cid=1228772057350 and to 80 FR 73331. Accordingly, we proposed to exclude these
special payments from EPM-episode calculations using the CMS Price
Standardization methodology at Sec. 512.300(e)(2). We sought comment
on our proposal to exclude special payments using the CMS Price
Standardization methodology.
The following is a summary of the comments received and our
responses.
Comment: Commenters generally supported the proposal to adjust
actual and target spending amounts for various special payments such as
IME and DSH.
Response: We appreciate the comments we received supporting our
proposal to exclude special payments from EPM-episode calculations
using the CMS Price Standardization methodology. We wish to clarify
that like CJR, we will follow the CMS Price Standardization methodology
with modifications as necessary to be consistent with our episode
definition in section III.C of this final rule and to ensure timely
reporting of reconciliation
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results, for the performance year reconciliations, which begin 2 months
after the conclusion of a performance year. We will account for the
information available at the time due to claims run-out, payment system
updates, and the calculations necessary to fully implement the
standardization methodology. We will utilize the methodology,
consistent with our episode definition, for the target price
calculations and subsequent reconciliation calculations 14 months after
the conclusion of the performance year, in which we incorporate full
claims run-out and further account for overlap with other models. This
approach will provide feedback and reconciliation payments, as
available, to hospitals in a timely manner and as accurately as
feasible, while ensuring the standardization approach is utilized for
the subsequent reconciliation calculation for a performance year.
Comment: Commenters requested more clarity on whether IPPS capital
payments are included, and requested that we exclude these costs. A
commenter noted that these capital costs are not included under the
BPCI models, hospitals need stability in capital cost reimbursement to
plan for major capital expenditures, and thus these costs should not be
placed at risk because of models affecting only cardiovascular and
orthopedic services.
Response: To clarify, as is the case with CJR, IPPS capital
payments will be included in EPM-episode calculations. As we stated in
the CJR Final Rule (80 FR 73333), these payments are included in
Medicare FFS payments, which we use to calculate benchmark and actual
expenditures. Further, including IPPS capital payments affords
participants an opportunity to achieve greater reconciliation payments
if they are able to achieve efficiencies for the costs that the capital
portion of IPPS payments would cover, which may or may not actually be
capital costs.
Comment: A commenter requested that CMS exclude outlier payments
EPM-episode calculations. The commenter expressed concern that because
CMS proposed a limited risk-adjustment methodology, hospitals that
treat the least healthy beneficiaries such as academic medical centers
would be penalized for longer lengths of stay that result in receiving
outlier payments for the index admission, particularly as financial
targets transition to regional pricing.
Response: We disagree that outlier payments should be excluded from
our calculation. First, we expect the models to encourage more
efficient care that should result in lower costs and potentially the
frequency for which outlier payments are needed. Second, as discussed
in section III.D.3.d. of this final rule, we are finalizing policies to
cap high-cost episodes with payments 2 standard deviations or more
above the mean calculated at the regional level for purposes of
determining benchmark prices and actual expenditures, which should
assist in protecting participants from higher costs associated with
outlier payments. Third, as discussed in section III.D.4.b.(2). of this
final rule, we will be exploring options to further risk-adjust costs
and payments under the models with the goal of making them effective
for episodes ending after January 1, 2019, with anchor discharges
occurring on or after October 4, 2018. These further adjustments for
risk would offer additional financial protections to participants with
high-cost episodes.
Comment: Several commenters recommended that costs for chronic care
management, cardiac rehabilitation, and intensive cardiac
rehabilitation services be excluded from payment calculations. With
regard to the former, the commenter noted that chronic care management
services were not paid under Medicare until January of 2015 and
therefore was not a payable service during two of the years used to set
target prices for the first two performance year. Further, in this
commenter's view, many physicians currently are not billing for these
services, but the commenter anticipates the volume will increase. With
regard to the latter, commenters noted that if the proposed efforts to
encourage CR utilization are successful, spending for CR/ICR services
in AMI and CABG episodes would increase and could cause participants'
spending to exceed their targets making them either ineligible to
receive reconciliation payments or at risk for making Medicare
repayments. As such, this would penalize hospitals for improving CR/ICR
utilization, which would impede, if not completely defeat, CMS' efforts
to encourage CR and ICR utilization. Accordingly, these commenters
recommended that the cost of CR and ICR services be excluded from
episode payment calculations.
Response: As we noted in section III.C.3.b. of this final rule, we
do not believe that it would be appropriate to exclude other specific
Part B services, including chronic are management services, cardiac
rehabilitation, intensive cardiac rehabilitation services that are
related to the clinical conditions that are the basis for EPM episodes,
just because they are underrepresented in the baseline period upon
which benchmark episode prices are set. Likewise, we do not believe it
is appropriate to exclude the costs of these included services from our
financial calculations. To the extent that care redesign under the EPMs
increases utilization of these services to improve episode quality and
efficiency, periodic updates to the 3 years of historical data used to
establish EPM-episode benchmark prices, as is discussed in section
III.D.4.b.(3) of this final rule, would result in greater
representation of these services that reflect more recent care
patterns.
Final Decision: After consideration of the public comments
received, we are finalizing the proposal, without modification, to
exclude certain special payments from EPM-episode calculations using
the CMS Price Standardization methodology. Our final policy for
excluding special payments is included in Sec. 512.300(e)(2).
c. Services That Straddle Episodes
A service that straddles an EPM episode is one that begins before
the start of or continues beyond the end of an EPM episode that extends
90 days post-hospital discharge. Under the CJR model, we prorate
payments so that they include only the portion of the payment that is
included in the CJR model episode, using separate approaches to prorate
payments under each payment system, for example, IPPS, non-IPPS and
other inpatient services, and home health services (80 FR 73333 through
73335). We proposed to apply the CJR model methodologies for prorating
payments when calculating actual EPM-episode payments and when
calculating historical EPM-episode payments used to set EPM-episode
benchmark and quality-adjusted target prices (81 FR 50846). We believed
these methodologies would most accurately account for spending within
EPM episodes under the EPMs. The methodologies for prorating payments
under the EPMs were included in Sec. 512.300(f). We sought comment on
our proposed methodologies for prorating payments.
The following is a summary of the comments received and our
responses.
Comment: We received comments requesting greater clarity on how we
would prorate payments for services that straddle episodes. We also
received a comment requesting greater clarity for ``prorated'' payments
for ``straddled'' episodes with the presence of an AMI diagnosis
treated with CABG.
Response: Following are the steps we use for the CJR model that we
proposed to apply when prorating payments under the proposed EPMs, and
that were specifically cited in our proposed rule (80 FR 73333 through
73335).
[[Page 297]]
These steps have been updated to reflect our methodology as applied to
an AMI episode involving a CABG.
In general, assuming we have a beneficiary in an EPM episode who is
admitted to a SNF for 15 days, beginning on Day 86 post-discharge from
the anchor EPM hospitalization, the first 5 days of the admission would
fall within the episode, while the subsequent 10 days would fall
outside of the episode. Under our proposal, to the extent that a
Medicare payment for included episode services spans a period of care
that extends beyond the episode, these payments would be prorated so
that only the portion attributable to care during the episode is
attributed to the episode payment when calculating actual Medicare
payment for the episode.
For non-IPPS inpatient hospital (for example, CAH) and inpatient
post-acute care (for example, SNF, IRF, LTCH, IPF) services, we would
prorate payments based on the percentage of actual length of stay (in
days) that falls within the episode window. Prorated payments would
also be similarly allocated to the 30-day post-episode payment
calculation in section III.D.7.e. of this final rule. In the previous
example, one-third of the days in the 15-day length of stay would fall
within the episode window, so under the proposed approach, one-third of
the SNF payment would be included in the episode payment calculation,
and the remaining two-thirds (because the entirety of the remaining
payments fall within the 30 days after the episode ended) would be
included in the post-episode payment calculation.
For HHA services that extend beyond the episode, the payment
proration would be based on the percentage of days, starting with the
first billable service date (``start of care date'') and through and
including the last billable service date, that fall within EPM episode.
Prorated payments would also be similarly allocated to the 30-day post-
episode payment calculation in section III.D.7.e. of this final rule.
For example, if the patient started receiving services from an HHA on
day 86 after discharge from the anchor hospitalization and the last
billable home health service date was 55 days from the start of home
health care date, the HHA claim payment amount would be divided by 55
and then multiplied by the days (5) that fell within the EPM episode.
The resulting, prorated HHA claim payment amount would be considered
part of the EPM episode. Services for the prorated HHA service would
also span the entirety of the 30 days after the EPM episode spends, so
the result of the following calculation would be included in the 30-day
post-episode payment calculation: HHA claim payment amount divided by
55 and then multiplied by 30 days (the number of days in the 30-day
post-episode period that fall within the prorated HHA service dates).
There may also be instances where home health services begin prior
to the EPM episode start date, but end during the EPM episode. In such
instances, we would also prorate HHA payments based on the percentage
of days that fell within the episode. Because these services end during
the EPM episode, prorated payments for these services would not be
included in the 30-day post-episode payment calculation discussed in
section III.D.7.e. of this final rule. For example, if the patient's
start of care date for a home health 60-day claim was February 1, the
anchor hospitalization was March 1 through March 4 (with the EPM
episode continuing for 90 days after March 4), and the patient resumed
home care on March 5 with the 60-day home health claim ending on April
1 (that is, April 1 was the last billable service date), we would
divide the 60-day home health claim payment amount by 60 and then
multiply that amount by the days from the EPM admission through April 1
(32 days) to prorate the HHA payment. This proposed prorating method
for HHA claims is consistent with how partial episode payments (PEP)
are paid for on home health claims.
For IPPS services that extend beyond the episode (for example,
readmissions included in the episode definition), we would separately
prorate the IPPS claim amount from episode target price and actual
episode payment calculations as was made final in the final CJR rule
(80 FR 73334 through 73335), called the normal MS-DRG payment amount
for purposes of this final rule. The normal MS-DRG payment amount would
be pro-rated based on the geometric mean length of stay, comparable to
the calculation under the IPPS post-acute care transfer policy at Sec.
412.4(f) and as published on an annual basis in Table 5 of the IPPS/
LTCH PPS Final Rules. Consistent with the IPPS post-acute care transfer
policy, the first day for a subset of MS-DRGs (indicated in Table 5 of
the IPPS/LTCH PPS Final Rules) would be doubly weighted to count as 2
days to account for likely higher hospital costs incurred at the
beginning of an admission. If the actual length of stay that occurred
during the episode is equal to or greater than the MS-DRG geometric
mean, the normal MS-DRG payment would be fully allocated to the
episode. If the actual length of stay that occurred during the episode
is less than the geometric mean, the normal MS-DRG payment amount would
be allocated to the episode based on the number of inpatient days that
fall within the episode. If the full amount is not allocated to the
episode, any remainder amount would be allocated to the 30 day post-
episode payment calculation discussed in section III.D.7.e. of this
final rule. The proposed approach for prorating the normal MS-DRG
payment amount is consistent with the IPPS transfer per diem
methodology.
More specifically, if a beneficiary has a readmission for MS-DRG
234--coronary bypass with cardiac catheterization without major
complications or comorbidities--into an IPPS hospital on the 89th day
after discharge from an EPM anchor hospitalization, and is subsequently
discharged after a length of stay of 5 days, Medicare payment for this
readmission would be prorated for inclusion in the episode. Based on
Table 5 of the IPPS/LTCH PPS Final Rule for FY 2017, the geometric mean
for MS-DRG 234 is 8 days, and this MS-DRG is indicated for double-
weighting the first day for proration. This readmission has only 2 days
that falls within the episode, which is less than the MS-DRG 234
geometric mean of 8 days. Therefore, the normal MS-DRG payment amount
associated with this readmission would be divided by 8 (the geometric
mean) and multiplied by 3 (the first day is counted as 2 days, and the
second day contributes the third day), and the resulting amount is
attributed to the episode. The remaining five-eighths would be captured
in the post-episode spending calculation discussed in section
III.D.7.e. of this final rule. If the readmission occurred on the 82nd
day after discharge from the EPM anchor hospitalization, and the length
of stay was 10 days, the normal MS-DRG payment amount for the admission
would be included in the episode without proration because length of
stay for the readmission falling within the episode (9 days) is greater
than or equal to the geometric mean (8 days) for the MS-DRG. We would
also clarify that, consistent with how we would prorate payments for
services that extend beyond the episode when establishing benchmark
prices for an AMI episode without a CABG, in instances of an AMI
episode with CABG readmissions, we would establish the benchmark price
based on prorated amounts for both the AMI episode and the CABG
readmission.
Final Decision: After consideration of the public comments
received, we are finalizing the proposal, without
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modification, to prorate payments for services that straddle episodes.
Our final policy for prorating payments is included in Sec.
512.300(f).
d. High-Payment EPM Episodes
For the CJR model, we defined a high-payment episode as an episode
with payments 2 standard deviations or more above the mean calculated
at the regional level (80 FR 73336 through 73337). As with the CJR
model, we proposed to apply a high-payment episode ceiling when
calculating actual EPM-episode payments and when calculating historical
EPM-episode payments used to set EPM-episode benchmark and quality-
adjusted target prices (81 FR 50846). We proposed to apply the ceiling
according to the following groupings that align with our proposed EPM
price-setting methodology.
First, for SHFFT model episodes, we proposed to calculate and apply
the ceiling separately for each SHFFT price MS-DRG at the regional
level.
Second, for AMI model episodes with price MS-DRGs 280-282 or 246-
251 without readmission for CABG MS-DRGs, we proposed to calculate and
apply the ceiling separately for each price MS-DRG at the regional
level.
Third, for CABG model episodes, we proposed to apply ceilings
separately to the payments that occurred during the anchor
hospitalization of the CABG model episode and to the payments that
occurred after the anchor hospitalization. For the anchor
hospitalization portion of CABG model episodes, we proposed to
calculate and apply the ceiling separately by each price MS-DRG in 231-
236 at the regional level. For the post-anchor hospitalization portion,
we proposed to calculate and apply the ceiling separately for the
following groupings at the regional level:
With AMI ICD-CM diagnosis code on the anchor inpatient
claim and price MS-DRG with major complication or comorbidity (231,
233, or 235).
With AMI ICD-CM diagnosis code on the anchor inpatient
claim and price MS-DRG without major complication or comorbidity (232,
234, or 236).
Without AMI ICD-CM diagnosis code on the anchor inpatient
claim and price MS-DRG with major complication or comorbidity (231,
233, or 235).
Without AMI ICD-CM diagnosis code on the anchor inpatient
claim and price MS-DRG without major complication or comorbidity (232,
234, or 236).
Fourth, for AMI model episodes with price MS-DRG 231-236, we
proposed to apply ceilings separately to the payments that occurred
during the chained anchor hospitalization and to the payments that
occurred after the chained anchor hospitalization. For the anchor
hospitalization portion of the episode, we proposed to apply the
regional level ceiling calculated for the anchor hospitalization
portion of a CABG model episode for the corresponding price MS-DRG, as
described previously. For the post-anchor hospitalization portion of
the episode, we proposed to apply the regional level ceiling calculated
for the post-anchor hospitalization portion of a CABG model episode for
the corresponding price MS-DRG with AMI diagnosis.
Fifth, for AMI model episodes with price MS-DRG 280-282 or 246-251
and with readmission for CABG MS-DRGs, we proposed to apply the ceiling
separately to the payments during the CABG readmission and all other
payments during the episode. For payments during the CABG readmission
portion of the AMI model episode we proposed to apply the regional
level ceiling calculated for the anchor hospitalization portion of a
CABG model episode for the corresponding CABG readmission MS-DRG, as
described previously. For all other payments during the AMI model
episode, we proposed to apply the regional level ceiling calculated for
AMI model episodes with price MS-DRG 280-282 or 246-251 and without
readmission for CABG MS-DRGs corresponding to the AMI price MS-DRG.
We believed that the proposed ceiling would protect EPM
participants from variable repayment risk for especially-high payment
EPM episodes where the clinical scenarios for these cases each year may
differ significantly and unpredictably.
The proposal for capping high payment EPM episodes were included in
Sec. 512.300(e)(1). We sought comment on our proposal to cap high
payment EPM episodes.
The following is a summary of the comments received and our
responses.
Comment: Commenters supported the proposal for capping high payment
episodes. A commenter noted that the proposal does not separately
address an episode where Medicare accepts a beneficiary's appeal of
Medicare Provider Non-Coverage after the discharging physician
determined not to certify that patient for care. The commenter noted
that under such a scenario, in contradiction with the hospital's
clinical judgment on appropriate level of care, the proposed policy
would not cap spending unless it reached the proposed threshold. The
commenter recommended that CMS create additional flexibilities or
protections for hospitals where a Medicare appeal overturns a
hospital's decision that is based on clinically-directed, evidence-
based discharge criteria.
Response: We appreciate comments in support of our proposal to cap
high payment EPM episodes. We disagree with the suggestion to include
protections in addition to what we have proposed to address scenarios
where a Medicare appeal contradicting a hospital's discharge decision
increases the costs of an episode. We believe our proposal offers
sufficient protection under such circumstances. Further, if a
hospital's discharge decision was overturned upon appeal, we would have
to believe the final decision was correct and any additional costs that
resulted from the appeal would be appropriately included as an episode
cost.
Final Decision: After consideration of the public comments
received, we are finalizing the proposal, with modification, to cap
high payment EPM episodes. Specifically, we are not finalizing our
proposal to apply ceilings separately to the payments that occurred
during the chained anchor hospitalization and to the payments that
occurred after the chained anchor hospitalization with respect to AMI
model episodes with MS-DRG 231-236, and instead will simply apply
ceilings separately for each MS-DRG at the regional level as we would
with MS-DRGs 280-282 or 246-251 without readmission for CABG MS-DRGs.
Our final policy for capping high payment EPM episodes is included in
Sec. 512.300(e)(1).
e. Treatment of Reconciliation Payments and Medicare Repayments When
Calculating Historical EPM-Episode Payments To Update EPM-Episode
Benchmark and Quality-Adjusted Target Prices
For the CJR model, we exclude CJR model reconciliation payments and
Medicare repayments from the expenditure data used to update historical
claims when calculating CJR model target prices, although we received
comments on the proposed rule encouraging us to include these payments.
For example, commenters supported their inclusion because CJR-
participating hospitals otherwise would be providing care coordination
services that would not be paid directly or accounted for under
applicable Medicare FFS payments systems and thus might be funded
through reconciliation payments. Further, by
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excluding reconciliation payments from the calculations, commenters
suggested that we may underestimate their actual resource costs when
updating target prices for the care necessary during episodes. The CJR
Final Rule discussed our view that including reconciliation payments
would have the effect of Medicare paying CJR model participant
hospitals their target prices, regardless of whether such participant
was below, above, or met their episode target price. We also noted that
we had not discussed any alternatives in the CJR model proposed rule,
and that we might consider including these payments in updating
historical claims through future rulemaking (80 FR 73332).
After further consideration, we proposed to include both
reconciliation payments and Medicare repayments when calculating
historical EPM-episode payments to update EPM-episode benchmark and
quality-adjusted target prices (81 FR 50847). We concurred with the
views expressed by commenters on the CJR model proposed rule that
including these payments would more fully recognize the total resource
costs of care under an EPM than would their exclusion. As indicated in
section V.B. of the proposed rule (81 FR 50950 through 50951), we also
proposed to modify our policy for the CJR model to also include
reconciliation payments and Medicare repayments when updating target
prices under that model. We also considered an option where we would
include only reconciliation payments when updating but not Medicare
repayments; however, we believed this option would not achieve our
intention of more fully capturing the costs of care under the EPM. We
further noted that the inclusion of both reconciliation payments and
Medicare repayments could have differential effects on an EPM
participant's benchmark and quality-adjusted target prices based on
whether or not it received a reconciliation payment or made a Medicare
repayment. For example, all else equal, including an EPM reconciliation
payment when updating an EPM participant's EPM-episode benchmark and
quality-adjusted target prices would modestly increase the quality-
adjusted target prices in performance years 3 through 5 in comparison
to not including the reconciliation payment. Conversely, all else
equal, including a Medicare repayment when updating an EPM
participant's EPM-episode benchmark and quality-adjusted target prices
would reduce the next performance year's quality-adjusted target price
in comparison to not including the Medicare repayment. Following
analogous logic, we also proposed to include BPCI Net Payment
Reconciliation Amounts in our calculations when updating EPM-episode
benchmark and quality-adjusted target prices. We noted, however, that
the effects of these proposals would largely be confined to PY3 of the
EPMs and diminish as EPM-participant historical EPM-episode updates are
eventually determined based on regional payments in subsequent years of
the EPMs. This is because the net sum of EPM reconciliation payments,
Medicare repayments, and BPCI Net Payment Reconciliation Amounts would
represent a small portion of the total historical EPM-episode payments
captured in regional pricing.
When updating EPM-episode benchmark and quality adjusted target
prices for CABG model episodes, we proposed to apportion EPM
reconciliation payments and BPCI Net Reconciliation Payment Amounts
proportionally to the anchor hospitalization and post-anchor
hospitalization portions of CABG model historical episodes. We also
proposed to calculate the proportions based on regional average
historical episode payments that occurred during the anchor
hospitalization portion of CABG model episodes and regional average
historical episode payments that occurred during the post-anchor anchor
hospitalization portion of CABG model episodes that were initiated
during the 3 historical years. This aligns with the general proposal to
calculate the CABG model-episode benchmark price as the sum of the
corresponding CABG anchor hospitalization benchmark price and the
corresponding CABG post-anchor hospitalization benchmark price, as
discussed in III.D.4.b.(2)(ii) and III.D.4.d. of the proposed rule.
The proposal to include both reconciliation payments and Medicare
repayments when calculating historical EPM-episode payments to update
EPM-episode benchmark and quality-adjusted target prices was included
in Sec. 512.300(c)(8). We sought comment on our proposal to include
both reconciliation payments and Medicare repayments when calculating
historical EPM-episode payments to update EPM-episode benchmark and
quality-adjusted target prices.
The following is a summary of the comments received and our
responses.
Comment: Multiple commenters supported the proposal to include
reconciliation payments when calculating target prices in order to more
fully recognize the costs of care under the models. A number of
commenters expressed the view that the proposal will help avoid
participants from constantly competing against their prior success and
better ensure that target prices decrease at a slower rate, which is
critical for those providers that are already efficient, allow more
viable financial targets for the participating providers that are
better aligned with effective patient care. A commenter requested that
CMS include these reconciliation payments and repayments in PY2 rather
than PY3. Another commenter requested that CMS exclude Medicare
repayments given that the targets would fall for hospitals that
increased their spending to improve care, which then caused them to
exceed their target prices.
Response: We appreciate the comments supporting our proposal to
include reconciliation and Medicare repayments when calculating
historical EPM-episode payments to update EPM-episode benchmark and
quality-adjusted target prices. We disagree with comments suggesting
that we accelerate their inclusion to PY2 or to exclude Medicare
repayments for these purposes. We would further note that since the
historical data for determining PY1 and PY2 benchmarks is based on 2013
to 2015 expenditure data, the effects of a reconciliation determination
for PY1, which is based on 2017 expenditure data, would not pertain to
the data used to determine target prices for PY2. Moreover, given that
reconciliation determinations are made 2 months after the completion of
a performance year, it would not be possible to apply the PY1
reconciliation results to the PY2 benchmark data even if we were to
adjust our timeframe for determining historical payments.
Final Decision: After consideration of the public comments
received, we are finalizing the proposal, without modification, to
include both reconciliation payments and Medicare repayments when
calculating historical EPM-episode payments to update EPM-episode
benchmark and quality-adjusted target prices. The final policy for
including reconciliation payments and Medicare repayments is included
in Sec. 512.300(c)(8).
4. EPM-Episode Price-Setting Methodologies
a. Overview
Whether an EPM participant receives a reconciliation payment or is
made responsible to repay Medicare under the EPM is based on the EPM
participant's actual EPM-episode payments relative to quality-adjusted
target prices, as well
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as the EPM participant's eligibility for reconciliation payment based
on acceptable, good, or excellent quality performance. While our
proposals for relating EPM participant quality performance to EPM
payments were further discussed in section III.E.3.f of the proposed
rule (81 FR 50887 through 50893), this section of the proposed rule
discussed the approach to establishing EPM-episode benchmark and
quality-adjusted target prices (81 FR 50847 through 50864).
For the purposes of price-setting, any references in our proposed
rule to AMI ICD-CM diagnosis codes meant those ICD-9-CM and ICD-10-CM
diagnosis codes for historical EPM episodes or ICD-10-CM diagnosis
codes for EPM episodes during the EPM performance years that can be
found in the specific EPM episode definitions parameters spreadsheet.
Also, for the purposes of price-setting, any references in the proposed
rule to intracardiac ICD-CM procedure codes meant those ICD-9-CM
procedure codes for historical EPM episodes that can be found in the
specific EPM episode definitions parameters spreadsheet. The EPM
episode definitions parameters spreadsheets are posted on the CMS Web
site at https://innovation.cms.gov/inititatives/epm.
We proposed to establish EPM-episode benchmark and quality-adjusted
target prices for each EPM participant based on the following MS-DRGs
and diagnoses included in the AMI, CABG, and SHFFT models as discussed
in sections III.C.3 and III.C.4. of the proposed rule:
(1) AMI model
AMI MS-DRGs --
++ 280 (Acute myocardial infarction, discharged alive with MCC);
++ 281 (Acute myocardial infarction, discharged alive with CC);
++ 282 (Acute myocardial infarction, discharged alive without CC/
MCC); and
PCI MS-DRGs, when the claim includes an AMI ICD-CM
diagnosis code in the principal or secondary position on the inpatient
claim and when the claim does not include an intracardiac ICD-CM
procedure code in any position on the inpatient claim--
++ 246 (Perc cardiovasc proc with drug-eluting stent with MCC or 4+
vessels/stents);
++ 247 (Perc cardiovasc proc with drug-eluting stent without MCC);
++ 248 (Perc cardiovasc proc with non-drug-eluting stent with MCC
or 4+ vessels/stents);
++ 249 (Perc cardiovasc proc with non-drug-eluting stent without
MCC);
++ 250 (Perc cardiovasc proc without coronary artery stent with
MCC); and
++ 251 (Perc cardiovasc proc without coronary artery stent without
MCC).
(2) CABG model DRGs--
231 (Coronary bypass with PTCA with MCC);
232 (Coronary bypass with PTCA without MCC);
233 (Coronary bypass with cardiac cath with MCC);
234 (Coronary bypass with cardiac cath without MCC);
235 (Coronary bypass without cardiac cath with MCC); and
236 (Coronary bypass without cardiac cath without MCC).
(3) SHFFT model DRGs--
480 (Hip and femur procedures except major joint with
MCC);
481 (Hip and femur procedures except major joint with CC);
and
482 (Hip and femur procedures except major joint without
CC or MCC).
We proposed to generally apply the CJR model methodology to set
EPM-episode benchmark and quality-adjusted target prices (80 FR 73337
through 73338), with the addition of some adjustments based on the
specific clinical conditions and care patterns for EPM episodes
included in the AMI, CABG, and SHFFT models. The price-setting
methodology incorporated the following features:
Set different EPM benchmark and quality-adjusted target
prices for EPM episodes based on the assigned price MS-DRG in one of
the included MS-DRGs to account for patient and clinical variations
that impact EPM participants' costs of providing care. Inpatient claims
with PCI MS-DRGs 246-251 that contain an intracardiac ICD-CM procedure
code in any position would not anchor an historical episode, nor be
considered when assigning a price MS-DRG. This is because beginning in
FY 2016, inpatient claims containing an intracardiac ICD-10-CM
procedure code in any position no longer map to MS-DRGs 246-251.
Adjust EPM benchmark and quality-adjusted target prices
for certain EPM episodes involving chained anchor hospitalizations,
specific readmissions, or the presence of an AMI ICD-CM diagnosis code
for CABG MS-DRGs.
Use 3 years of historical Medicare FFS payment data
grouped into EPM episodes according to the EPM episode definitions in
sections III.C.3 and III.C.4. of the proposed rule, termed historical
EPM episodes and historical EPM-episode payments. The specific set of 3
historical years would be updated every other performance year.
Apply Medicare payment system (for example, IPPS, OPPS,
IRF PPS, SNF, MPFS.) updates to the historical EPM-episode data to
ensure we incentivize EPM participants based on historical utilization
and practice patterns, not Medicare payment system rate changes that
are beyond such participants' control. Because different Medicare
payment system updates become effective at two different times of the
year, we would calculate one set of EPM-benchmark and quality-adjusted
target prices for EPM episodes initiated between January 1 and
September 30 and another set for EPM episodes initiated between October
1 and December 31.
Blend together EPM-participant hospital-specific and
regional historical EPM-episode payments, transitioning from primarily
hospital-specific to completely regional pricing over the course of the
5 performance years, to incentivize both historically-efficient and
less-efficient EPM participants to furnish high quality, efficient care
in all years of the EPM Regions would be defined as each of the nine
U.S. Census divisions.
Normalize for hospital-specific wage-adjustment variations
in Medicare payment systems when combining hospital-specific and
regional historical EPM episodes.
Pool together EPM episodes by groups of price MS-DRGs to
allow a greater volume of historical cases and allow us to set more
stable prices.
Apply an effective discount factor on EPM-episode
benchmark prices to serve as Medicare's portion of reduced expenditures
from the EPM episode, with any remaining portion of reduced Medicare
spending below the quality-adjusted target price potentially available
as reconciliation payments to the EPM participant where the anchor
hospitalization occurred.
Further discussion on each of the features and sequential
steps to calculate EPM-episode benchmark and quality-adjusted target
prices can be found in sections III.D.4.b through e. of both our
proposed rule and this final rule.
We also proposed to calculate and communicate EPM-episode benchmark
and quality-adjusted target prices to EPM participants prior to the
performance period in which the prices apply (that is, prior to January
1, 2018, for prices covering EPM episodes that start between January 1,
2018, and September 30, 2018; prior to October 1, 2018, for prices
covering EPM episodes that start between October 1, 2018, and December
31, 2018). We stated our belief that prospectively communicating
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EPM-episode benchmark and quality-adjusted target prices to EPM
participants would help them make infrastructure, care coordination and
delivery, and financial refinements they may deem appropriate to
prepare for the new episode target prices under the model.
The proposal to prospectively communicate quality-adjusted target
prices was included in Sec. 512.300(c)(9). We sought comment on our
proposal to prospectively communicate these prices.
The following is a summary of the comments received and our
responses.
Comment: Commenters supported the proposal to establish and
prospectively communicate benchmark and quality-adjusted target prices.
Commenters also expressed concerns about how far in advance the
information would be made available and the level of detail that would
be included in the information. Commenters indicated that knowing the
target price prior to the relevant performance period is essential for
participants to be able to implement efficient care redesigns linked
explicitly to established payment rates. As such, commenters requested
that CMS provide this information 60 to 90 days prior to the start of
the relevant performance period. Other commenters requested that CMS
make all of the components necessary to calculate the target price for
both the CJR model and proposed EPMs available to participants so they
can verify that CMS accurately calculated the target price as some CJR
participants have reported an inability to replicate the target price
calculation due to CMS' use of ``black box'' inputs for certain
national factors.
Response: We appreciate the comments and support we received for
our proposal to prospectively communicate benchmark and quality-
adjusted target prices, agree with commenters on the importance of
having this information in advance of each performance year, and intend
to make as much information available as we deem appropriate to
participants as far in advance of the models' implementation as is
possible.
Comment: Several commenters recommended that CMS annually
reevaluate and update the price-setting assumptions through a notice
and comment process. One of these commenters reported that the proposal
to make historical claims data available before implementation of the
models would still not give hospitals an opportunity to comment on
problems with the methodology until after the models had begun. Another
commenter based their request on significant and unexplained changes in
prices reported under BPCI and the Pioneer ACO model.
Response: We appreciate these comments and suggestions. We believe
the information we provided in both our proposed and this final rule is
sufficiently detailed for participants to understand our assumptions
and methodology for setting target prices. In the event we intend to
materially change our price-setting assumptions or methodology, we
would make those proposed changes available through a notice and
comment process.
Final Decision: After consideration of the public comments
received, we are finalizing the proposal, without modification, to
prospectively communicate quality-adjusted target prices.
b. EPM-Episode Benchmark and Quality-Adjusted Target Price Features
(1) Risk-Stratifying EPM-Episode Benchmark Prices Based on MS-DRG and
Diagnosis
To account for some of the clinical and resource variations that
would be expected to occur under the EPMs, we proposed generally to
apply the episode pricing methodology that was applied to the CJR model
to develop the EPM-episode benchmark prices, which we referred to as
the standard EPM-episode benchmark price (81 FR 50848). In addition,
for each EPM participant, we proposed to risk-stratify and establish
special EPM-episode benchmark prices for episodes in different pricing
scenarios as described in this section, as well as sections III.D.4.c.
through e. of the proposed rule (81 FR 50848 through 50864). For
purposes of the proposed rule, risk-stratification meant the
methodology for developing the EPM-episode benchmark price that
accounts for clinical and resource variation in historical EPM episodes
so that the quality-adjusted target price (calculated from the EPM-
episode benchmark price) can be compared to actual EPM episode payments
for EPM beneficiaries with similar care needs to those in historical
EPM episodes.
For the SHFFT model, we proposed to set the price MS-DRG equal to
the anchor MS-DRG. We proposed to calculate standard SHFFT model-
episode benchmark prices based on price MS-DRGs following the general
payment methodology that was applied to the CJR model (80 FR 73337
through 73358) with risk stratification according to the anchor MS-DRG.
Similarly, for AMI model episodes without chained anchor
hospitalizations and without readmissions for CABG MS-DRGs, we proposed
to set the price MS-DRG equal to the anchor MS-DRG. We proposed to
calculate standard AMI model-episode benchmark prices based on price
MS-DRGs following the general payment methodology that was applied to
the CJR model (80 FR 73337 through 73358) with risk stratification
according to the anchor MS-DRG. We proposed to apply the CJR model
payment methodology separately to AMI model episodes with anchor AMI
MS-DRGs 280 through 282 and anchor PCI MS-DRGs 246 through 251 with a
corresponding AMI ICD-CM diagnosis code on the inpatient claim for the
anchor hospitalization and without an intracardiac ICD-CM procedure
code in any position on the inpatient claim for the anchor
hospitalization.
For episodes in the AMI model with chained anchor hospitalizations
and no readmissions for CABG MS-DRGs, we proposed to set the price MS-
DRG based on the hierarchy described in section III.D.4.b.(2)(a) and to
calculate AMI model-episode benchmark prices based on price MS-DRGs as
described in sections III.D.4.b.(2)(a) and III.D.4.c. of the proposed
rule.
For AMI model episodes without chained anchor hospitalizations and
with readmissions for CABG MS-DRGs, we proposed to set the price MS-DRG
as the anchor MS-DRG and to calculate CABG readmission AMI model-
episode benchmark prices as described in sections III.D.4.b.(2)(b),
III.D.4.b.(2)(c), and III.D.4.e of the proposed rule.
For AMI model episodes with chained anchor hospitalizations that do
not include CABG MS-DRGs and with readmissions for CABG MS-DRGs, we
proposed to set the price MS-DRG based on the hierarchy described in
section III.D.4.b.(2)(a) and to calculate CABG readmission AMI model-
episode benchmark prices as described in sections III.D.4.b.(2)(b),
III.D.4.b.(2)(c), and III.D.4.e. of the proposed rule.
For CABG model episodes, we proposed to set the price MS-DRG as the
anchor MS-DRG and to calculate CABG model-episode benchmark prices as
the sum of the CABG anchor hospitalization portion price and the CABG
post-anchor hospitalization portion price, which would be calculated by
applying the general payment methodology that was applied to the CJR
model (80 FR 73337 through 73358) separately to the expenditures that
occurred during the anchor hospitalization of the CABG model episode
and to the expenditures that occurred after the anchor hospitalization
as discussed in sections III.D.4.b.(2)(b) and III.D.4.d. of the
proposed rule.
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Finally, we proposed that after assigning an EPM-episode benchmark
price to each EPM episode, the EPM-episode quality-adjusted target
price would be the EPM-episode benchmark price reduced by the effective
discount factor for the corresponding EPM that corresponds to the EPM
participant's quality category, as discussed in sections III.D.4.b.(10)
and III.E.3.f. of the proposed rule.
The following is a summary of the comments received and our
responses.
Comment: One commenter commended CMS for attempting to create a
target price methodology that accounts for the variations in episode
spending that are characteristic of these specific clinical scenarios
while other commenters noted that the complexity of the proposals made
it difficult to evaluate them. Several commenters disagreed with the
proposal to base prices on MS-DRGs or anticipated that they could
result in unintended consequences. For example, commenters noted
concerns that it would be challenging to generate sufficient savings
where a sizeable portion of episode costs are embedded in the MS-DRG
costs attributed to the initial hospitalization and cannot be changed
by hospitals' performance. Other commenters noted that the higher
payments associated with higher-weighted MS-DRGs could serve as a
disincentive to participants from making quality improvements or to
reduce complications because they would be paid more when there are
complications that raise the MS-DRG, but paid less when quality
improvements they made resulted in a lower cost MS-DRG where only CMS
rather than the hospital benefitted from the reduced costs. Likewise,
several commenters claimed that participant coding behavior could
result in similar unintended consequences. As such, several commenters
recommended that CMS consider a price-setting methodology that removes
the MS-DRG payment from the target price or mitigates coding effects
from the calculations or differentially weights cost components that
would be ``locked in'' to the episode spending.
Response: The purpose of our models is to test EPMs within the
existing parameters and payment systems of FFS Medicare. As we noted in
section III.A.1.c. of this final rule, issues such as those commenters
raised are generally present for every episode payment model that sets
a price Medicare will pay for an episode-of-care. While our models are
not intended to change these existing FFS payment systems, we intend
that by incorporating both the MS-DRG payment and Part B services
furnished during the anchor inpatient hospitalization, the EPMs will
create incentives for increased care coordination and efficient care
delivery from the time of inpatient admission through 90 days after
discharge. Moreover, we hope the EPMs can identify the effectiveness of
a bundled payment model within those parameters as well as the factors
that could impede success. As discussed further in sections III.G.4.
through III.G.6. of this final rule, we will monitor access to care,
the quality of care, and delayed care under the EPMs and may take
actions against EPM participants if we find evidence that supports
concerns in these areas. In addition, the evaluation as discussed in
section IV. of this final rule will analyze beneficiary outcomes and
their relationship to clinical pathways under the EPMs.
Comment: Several commenters addressed EPM payments under the SHFFT
model. One commenter noted that the proposed SHFFT model would include
beneficiaries discharged under hip and femur procedures except major
joint replacement MS-DRGs (480-482), representing IPPS admissions for
hip fixation procedures in the setting of hip fractures. As these
procedures are emergent rather than elective, they would have more risk
to manage than would an elective LEJR and would more often require a
SNF stay and non-weight bearing status for weeks, which results in
higher costs than for an elective procedure. The commenter questioned
whether such non-elective procedures would have a higher benchmark
price and expressed concerns that bundled payment models are
potentially less successful for non-elective procedures which they
believe require more time for planning and rehabilitation.
Other commenters suggested that the differences in severity and
fracture type for episodes under the SHFFT model are not adequately
represented by the three MS-DRGs we proposed. One of these commenters
requested additional separate target prices as CMS had done for the CJR
model, which would serve as a rough form of risk-adjustment and would
make it easier for hospitals to devise protocols and strategies best
suited to fracture type. Another commenter suggested that since
patients who experience SHFFT episodes often require lengthier and more
complicated care, and typically require longer post-acute care than
those receiving joint replacement, the calculation of target prices
should also take into account the proportion of SHFFT episodes included
in the bundle in order to most accurately capture the risk of SHFFT
episodes. One commenter recommended that CMS adopt transfer mechanisms
within the SHFFT model, including price adjustments, which are similar
to those proposed for inpatient-to-inpatient hospital transfers under
the AMI model but that the receiving hospital would bear the risk if a
SHFFT patient is transferred to that hospital.
Response: We proposed to set prices based on anchor MS-DRGs, which
implicitly adjust payments based on their relative weights with respect
to the IPPS resources required for that MS-DRG. For example, average
episode expenditures for historical SHFFT episodes increases from
roughly $36,000 in episodes with anchor MS-DRG 482 to more than $52,000
for episodes with anchor MS-DRG 480.\77\ Further, our benchmark prices
would reflect the historic costs of post-acute care associated with
these MS-DRGs. If historic post-acute care costs for the emergent MS-
DRG are higher than those for a similar elective MS-DRG, then those
higher resources would be reflected in and produce a larger increase in
the benchmark amount than would be the case for the elective procedure.
We would also note that as discussed in section III.D.4.b.(2) which
follows, we will be exploring additional options to adjust benchmark
prices and performance payments to better account for cost variation
associated with risk. These adjustments, which we intend to be
effective beginning in PY3, should further account for some of the
potential variation in costs across episodes as has been highlighted.
We disagree with the view that a bundled payment would be any less
effective with an emergent than an elective procedure. Our proposed
models are intended to encourage changes and improvements in
participants' care practices, in general, with respect to the episodes
covered under the models, which we believe would apply regardless of
whether the episode is elective or emergent.
---------------------------------------------------------------------------
\77\ Episodes for SHFFT model beneficiaries initiated by all
U.S. IPPS hospitals and constructed using standardized Medicare FFS
Parts A and B claims, as proposed in this rule that began in CYs
2012-2014.
---------------------------------------------------------------------------
As discussed in section III.D.4.b.2.(a), we are not finalizing our
proposal with regard to inpatient-to-inpatient transfers for AMI
episodes. For AMI model episodes alone, we will cancel the AMI episode
that begins at the initial treating hospital when an inpatient-to-
inpatient transfer occurs during the anchor hospitalization. For CABG
and SHFFT model episodes, once the episode begins and an inpatient-to-
inpatient transfer occurs, the episode will continue and
[[Page 303]]
the hospitalization at the transfer hospital will be included or
excluded from the CABG or SHFFFT episode based on whether or not the
MS-DRG for the admission at the transfer hospital is excluded from the
CABG or SHFFT episode definition.
Comment: One commenter stated that the proposed EPMs do not
adequately account for research and teaching functions and that CMS
should adjust payments to account for the overhead associated with
these functions.
Response: We disagree that our proposed models should include
additional payment adjustments for research and teaching function
beyond the payments Medicare already makes for these purposes under the
IPPS. In contrast, we believe that participants should seek improved
care quality and efficiencies as broadly as is possible, including any
that can be attained with research or teaching activities.
Comment: A commenter noted their view that all providers should
have EHR capability, including the ability to share EHR data across
sites of service in order to speed decision-making and eliminate
duplication of effort. The commenter suggested that CMS include
incentive funds to assist post-acute care providers in implementing a
robust EHR system and tools to share the data with other providers.
Similarly, a commenter suggested that the proposed models will require
technology and services for monitoring care during a post-acute care
stay, and that CMS should incentivize the use of such technology and
services. The commenter recommended that CMS should pay for remote
patient monitoring using the CPT-code 94040, which is similar to what
is done in certain state models.
Response: We agree that EHR capability and monitoring technologies
can be useful tools toward improving care coordination and care
quality; however, our models are based on incentives to improve care
quality and efficiency, with a goal of improving control of cost
growth. We do not believe that adding funding to encourage further
adoption of technologies under the models is consistent with our goals.
However, we would note that to the extent a participant establishes
sharing arrangements with post-acute care collaborators under the
models, those collaborators could choose to use such shared funds for
purposes of improving their EHR or monitoring capacities.
Comment: As discussed in section III.C.3.b. of this final rule, one
commenter pointed to evidence demonstrating that the use of drug-
eluting stents (DESs) results in better long-term outcomes in many
patients and fewer repeat procedures for in-stent restenosis than do
less costly non-drug eluting stents. The commenter expressed concern
that while the costs of these more expensive stents would be captured
in the episode cost calculation, the long-term benefit for patients
both in terms of outcomes and costs would not be fully captured in the
90-day post-discharge episode period and hence discourage the
appropriate use of DES by causing fewer patients to receive them,
resulting in poorer outcomes and increased cost growth. The commenter
requested that CMS consider various means so to ensure the 90-day post-
discharge episode target price does not discourage the longer term
outcomes that are better for Medicare beneficiaries and potentially
overall savings for CMS. Another commenter requested an adjustment or
additional financial protection for costs associated with the
implantation of an Implantable Cardioverter Defibrillator (ICD) given
strong empirical support and its Class I recommendation for prevention
of sudden cardiac death for certain patients.
Similarly, another commenter recommended that CMS include a payment
adjustment such as an additional outlier or add-on payment for using
new technology, having higher cost cases, or adopting a breakthrough/
high cost treatment in advance of other providers.
Finally, one commenter recommended that CMS coordinate with the
device industry to create a process wherein the use and associated cost
of new technologies can be added to episodes of care definitions on a
routine basis and modify the proposal to ensure that providers have
financial incentives to provide optimal care for high-risk patients
with severe coronary artery disease even if the initial treatment
episode has a higher cost. The commenter expressed concern that
insufficient data were available at this time to inform a clinical
guideline recommendation with regard to the optimal timing of non-
culprit vessel PCI, and the proposed payment bundles could encourage
procedures that may not provide the best clinical outcomes for Medicare
beneficiaries but instead have financial benefits with respect to the
target price. As guidelines change based on available data, CMS should
consider potential adjustments to reconciliation to the episodes
quality adjusted target prices based on guideline changes.
Response: As we noted in section III.C.3.b. of this final rule,
Medicare payment for coronary stents, whether bare metal or DES, used
during a PCI performed during a hospitalization are included in the
IPPS payment for the inpatient hospitalization. While they are not paid
separately by Medicare, payment for the required resources would be
included in AMI episodes because the IPPS services for the anchor
hospitalization are included in the episodes. We propose to risk-
stratify EPM-episode prices based on MS-DRG as discussed in section
III.D.4.b.(1) of this final rule and there are separate MS-DRGs for
PCIs that use DES (246 and 247) and non-DES (248 and 249) for which
there would be separate AMI episode prices. Therefore, we do not
believe that the financial incentives under the AMI model encourage the
use of any specific coronary stent because the episode prices take into
consideration the IPPS payment for the specific MS-DRG that applies to
the AMI model beneficiary. We do not expect the AMI model to discourage
the appropriate use of DES. We would also note, as stated in section
III.D.4.b.(2), we will be exploring additional mechanisms to risk
adjust payments that should become available beginning in PY3. We
believe that these adjustments will provide participants further
protections that should help mitigate the concerns commenters raised.
Likewise, we do not agree with comments requesting payments in
addition to those currently made available when participants adopt
specific or new technologies, provide services for high-cost cases, or
adopt breakthrough technologies. The purposes of the proposed models
are to improve care quality and efficiency while better controlling
Medicare cost growth within a FFS framework. As such, the models seek
to achieve these goals to the greatest extent possible within the
regulatory framework that applies within FFS Medicare, and are not
intended to create new or substitute payment mechanisms or processes
for establishing new payments under FFS Medicare.
Comment: A commenter recommended that when establishing episode
target payments, price calculations should incorporate clinical
practice guidelines and appropriate use criteria that are endorsed by
all stakeholders to ensure that patients are not receiving inadequate
care.
Response: We disagree with the recommendation that prices should
include clinical practice guidelines as, to the contrary, they are
based on Medicare FFS payments and their historical utilization for
services included in the EPMs, and should not
[[Page 304]]
include specifications reflecting normative criteria regarding clinical
practice guidelines, which could be overly prescriptive for EPM
participants and provides and suppliers treating EPM beneficiaries.
That said, we would assume that EPM participants would be following
clinical practice guidelines as we would expect should also be the case
for services and paid under the Medicare FFS program.
Comment: We received a comment suggesting that CMS make payment
adjustments for cases where a beneficiary receives the majority of
their post-acute care in a different MSA from the MSA in which the
anchor hospitalization occurred. The commenter presented an example
where a beneficiary with an anchor hospitalization in Massachusetts
receives post-acute care in Florida. In their view, the MSA in Florida
could have higher service utilization and spending than the
Massachusetts MSA given different care practices. Further, the
commenter believed it was unlikely that the hospital in Massachusetts
could have influence on a provider in another distant MSA. The
commenter recommended a payment adjustment to both avoid penalizing
hospitals in the initiating MSA and to help in not deterring tertiary
care facilities from accepting patients that could not receive
necessary care in their own distant MSA.
Response: As noted in section III.C.4.a. of this final rule, we
recognize that in occasional circumstances, EPM participants may have
limited ability to coordinate care, but that we generally expect that
much of the subsequent coordination of post-acute care services and
other related services for EPM beneficiaries during the 90 days post-
discharge can be accomplished through telecommunications that do not
require the patient to remain within the geographic proximity of the
hospital responsible for the EPM episode. In that section, we also
noted that the design of the EPMs does not preclude hospitals from
coordinating care with other providers outside of their immediate
service area, that most EPM participants have the tools to engage in
effective remote care coordination that results in high quality episode
care, and that we finalized several waivers of Medicare program rules,
as discussed in section III.J. of this final rule, to facilitate
efficient and effective episode care coordination for beneficiaries in
remote or distant locations outside of the EPM participant's immediate
community. We also finalized policies for financial arrangements in
section III.I. of this final rule that allow EPM participants to share
upside and downside financial risk with a variety of individuals and
entities who collaborate with the EPM participant in redesigning care
and caring for EPM beneficiaries, regardless of the geographic
proximity of these individuals and entities to the EPM participant.
Through financial arrangements, EPM participants could align the
financial incentives of providers in the EPM beneficiary's home
community with the goals of the EPM participant to improve the quality
and reduce the cost of EPM episodes. Therefore, we do not believe it is
necessary to make a payment adjustment when a beneficiary receives
post-acute care in a different MSA from the MSA in which the anchor
hospitalization occurred. However, we plan to monitor these occurrences
and could consider modifying our policy should that be determined
appropriate.
Comment: Several commenters requested that CMS include more
flexibility with respect to payments for post-acute care services under
the models. For example, some commenters noted that while Medicare
payments for inpatient rehabilitation facility or long-term care
hospital services are based on a prospective amount, payments for
skilled nursing facility services are less ``encompassing'' and are
based on a per diem amount. Commenters suggested that these differences
can create an unequal playing field and prevent efficiencies that are
realized from being reflected in payments. As such, commenters
requested that CMS identify flexibilities so that payments among a
broader array of post-acute care providers could more closely reflect
any efficiencies that are realized, for example, through payments on a
per diem basis or at a reduced rate.
Response: We appreciate the suggestions commenters offered to
better align payments across post-acute care providers. We will not be
adopting these suggestions for purposes of these models as, to the
greatest extent possible, we want to test the effects of bundled
payments within the existing FFS Medicare framework. We will consider
the applicability of the suggestions offered, however, as we explore
future models that involve payments for post-acute care services.
(2) Adjustments To Account for EPM-Episode Price Variation
We also considered further adjustments to account for clinical and
resource variation that could affect EPM participants' costs for EPM
episodes. As was the case for the CJR model (80 FR 73338 through
73339), we stated our belief that no standard risk adjustment approach
that is widely-accepted throughout the nation exists for the proposed
EPM episodes. Thus, we did not propose to make risk adjustments based
on beneficiary-specific demographic characteristics or clinical
indicators. Likewise, we questioned whether CMS Hierarchical Condition
Categories (HCC) used to adjust for risk in the Medicare Advantage
program would be appropriate for risk-adjusting EPM episodes as such
categories are used to predict total Medicare expenditures in an
upcoming year for MA plans and may not be appropriate for use in
predicting expenditures over a shorter period of time, such as the EPM
episodes. Further, the validity of HCC scores for predicting Medicare
expenditures for shorter episodes-of-care or specifically for the AMI,
CABG, and SHFFT model episodes that we are proposing has not been
determined. Thus, we did not propose to risk-adjust EPM-episode
benchmark or quality-adjusted target prices using HCC scores for the
EPMs. We referred to the CJR Final Rule for additional discussion of
our assessment of risk-adjustment options for the CJR model, which
informed our views on their appropriateness for the EPMs (80 FR 73338
through 73340).
We also noted, however, that there are circumstances that could
account for spending variation in EPM episodes where certain pricing
adjustments could be appropriate. We identified several scenarios where
increased EPM-episode efficiencies would be limited for certain groups
of EPM beneficiaries and a standard EPM-episode benchmark price based
on the anchor MS-DRG would, therefore, not account for circumstances
where clinically-appropriate care could consistently result in higher
EPM-episode payments. For example, as discussed in section
III.C.4.a.(5) of the proposed rule, variation could arise from the
asymmetric distribution of cardiac care across hospitals, which makes
transfers, either from a hospitalization or from the emergency
department (without inpatient admission) of one hospital to another, a
common consideration in the treatment course for beneficiaries with an
initial diagnosis of AMI, resulting in a chained anchor hospitalization
for inpatient-to-inpatient transfers. We also recognized that certain
episodes involving hospital readmissions for clinically-appropriate
planned follow-up care may have higher episode spending than episodes
with a single hospitalization or with chained anchor hospitalizations
involving transfers that do not have any readmissions. Further, a
beneficiary
[[Page 305]]
who has a CABG in the context of hospitalization for an AMI may have
different spending in the 90 days post-hospital-discharge due to
different health needs than a beneficiary who has an elective CABG.
Accordingly, we proposed specific policies and payment adjustments in
recognition of the systematic, consistent variation in EPM-episode
spending that could result from such circumstances.
The following is a summary of the comments received and our
responses.
Comment: While one commenter supported the proposal to risk-
stratify episode costs based largely on MS-DRGs with additional
adjustments for scenarios including chained anchor hospitalizations,
readmissions, and CABG, many commenters expressed concerns that no
further risk-adjustment was proposed beyond the risk-stratification
inherent in the MS-DRGs and CMS' proposed adjustments for such
scenarios as chained anchor hospitalizations or episodes involving
readmissions or CABG. These commenters noted their views that the
absence of further risk-adjustment would penalize hospitals treating
the sickest, most complicated, and most vulnerable patients for factors
that are beyond the hospitals' control. One commenter reported that
adequate risk-adjustment is especially important as CMS considers
additional clinical groups for bundling programs, such as cardiac care
or SHFFT patients, that are more clinically heterogeneous than CJR
patients. MedPAC noted that it has ``consistently found that chronic
conditions and advanced age play a major role in explaining variation
in spending across beneficiaries. CMS proposes no further risk-
adjustments beyond the DRG/subgroups but provides no data to assess
whether the proposed stratification is sufficient to adjust for
differences in spending across beneficiaries within each episode type.
The Commission urges CMS to evaluate whether additional risk adjustment
strategies, such as comorbidities and age, would improve the accuracy
of the benchmarks.''
Many of the commenters pointed to a recent study noting that the
use of region-based target pricing can lead to reduced reconciliation
payments for hospitals.\78\ However, reconciliation payments would
substantially increase for hospitals that treat patients with high
complexity and be reduced for hospitals that treat patients with low
complexity when CMS-HCC scores are applied. Some commenters cited
additional data in support of their views that the absence of risk-
adjustment ignores the substantial variation in episode payments that
exists, penalizes hospitals for assuming the risk of higher-cost/
higher-risk patients, or potentially impedes access to high quality
care.
---------------------------------------------------------------------------
\78\ Ellimoottil C, Ryan AM, Hou H, et al. Medicare's New
Bundled Payment For Joint Replacement May Penalize Hospitals That
Treat Medically Complex Patients. Health Affairs. 2016: 35(9):1651-
1657. doi: 10.1377/hlthaff.2016.0263.
---------------------------------------------------------------------------
A number of commenters related the absence of further risk-
adjustment to concerns with the proposal to phase-in regionally
determined target prices. For example, commenters noted that the use of
a regional spending component will hold all hospitals in a region to
the same target price, even though they would have different clinical
capabilities and different risk profiles that results in their treating
patient populations with differing levels of severity and costs, which
further buttressed the view that substantial variation in episode
payments exist within each target price category, not just between the
target price categories. Some commenters expressed concerns that
differences in clinical capabilities, and therefore, differing rates of
more costly transfer episodes, could penalize smaller hospitals that do
not have the most sophisticated cardiac care available.
Some commenters expressed the view that the absence of risk
adjustment would particularly affect hospitals that typically treat
more complex patients, for example, tertiary hospitals or hospitals
that are academic medical centers because the absence of risk
adjustment would not account for the complexity of their patients,
which often included multiple co-morbidities, longer lengths of stay,
and higher costs. As hospitals could view these patients as increasing
their financial risk under the EPMs, commenters expressed concerns that
patients who suffer from multiple chronic conditions or comorbidities
may find it more difficult to find participating hospitals willing to
serve them.
Other commenters expressed concern that hospitals serving
communities with a high percentage of lower income patients could be
adversely affected by the absence of risk-adjustment. Moreover, the
lack of further risk-adjustment could create a risk-adverse environment
with the possibility of withholding appropriate care to patients with
moderate to high-risk profiles, for example to women, due to their
older age at cardiac presentation and minorities due to increased
frequency of clinical renal disorder. These commenters noted that such
patients could have higher costs due to their age or presence of
multiple co-morbidities. Further, by not providing an adjustment
factor, there could be a greater chance of transfer abuse whereby
smaller providers might shift risk for these patients to tertiary
providers by transferring emergency room patients that are at greater
risk for complications or readmissions.
Commenters also noted that CMS appeared to be inconsistent and
contradictory in not proposing to apply CMS-HCC scores for the proposed
models or for the CJR model when it does so for similar programs and
applications. Specifically, commenters observed that CMS-HCC scores are
applied to quality measures such as Medicare Spending per Beneficiary
(MSPB), 30-day mortality and readmission, as well as for the quality
measures proposed to be included under the proposed models. Commenters
remarked that this gives the impression of poor harmonization of
efforts within CMS, which leads to fragmented programs.
Thus, the commenters requested that CMS apply some kind of
additional risk-adjustment to the proposed models and the CJR model at
the latest before downside risk begins. One commenter noted that even
if not ideal, further risk-adjustment would be at least as good as CMS'
proposal, but simpler and easier to understand than the 75 different
target prices CMS proposed. Other commenters recommended that CMS
explore and incorporate additional risk- adjustment to address socio-
demographic factors, in addition to clinical factors, to more
accurately reflect the level of risk associated with such beneficiary
characteristics as income and employment status. Further, another
commenter reported that socio-demographic factors such as the
availability of primary care, physical therapy, easy access to
medications and appropriate food, and other supportive services, which
are beyond providers' control, affect hospitals' performance on outcome
measures.
Several commenters recommended that CMS apply the CMS-HCC scores.
In their view, some benefits of these scores is that they capture the
severity of a patient's level of underlying illness, better match
hospital's payment to the complexity of their patients, appropriately
account for the expected increase in utilization of health care
services, reduce the likelihood of a Medicare repayment, and should be
administratively simple to apply given their use for other efforts and
programs under Medicare. One commenter offered that these codes could,
at a minimum, serve as a basis for CMS to begin to construct an
appropriate risk-
[[Page 306]]
adjustment for CJR episodes, as well as for SHFFT episodes if it re-
proposes their implementation in the future. Another commenter
suggested that CMS identify a means to adjust the CMS-HCC codes so that
they could better apply to a 90-day episode. Moreover, while
encouraging further risk-adjustment as soon as possible within the
period of the model, this commenter also suggested that the proposed
models could be an opportunity to obtain the data needed to develop EPM
risk-adjusters.
One commenter encouraged the use of physician-defined patient
condition categories to ensure effective risk stratification in
condition-based payment models. This commenter reported that
alternative payment models that are designed to control overuse need to
incorporate effective risk adjustment or risk stratification components
in order to protect patients against underuse and to avoid penalizing
physicians for delivering and ordering services that patients need. In
their view, CMS-HCCs and other claims-based regression models are not
adequate for risk adjustment in condition-based payment models. Rather,
condition-based payment models must be risk stratified based on the
clinical characteristics and functional status of patients that are
most relevant to the types of conditions being managed.
Some commenters urged CMS to improve the risk-adjustment
methodology by collaborating with the clinical community and relevant
medical specialty societies such as the cardiovascular community that
have experience with the different risks facing patients who will be
treated within these episode models. Other commenters recommended that
CMS review risk adjustment methodologies used by other's bundling
models or to incorporate data from the STS Risk Calculator into the
risk-adjustment methodology or to use multiple model to better predict
the cost of care.
Commenters requested that CMS expand risk-adjustment to other
provider types or measures factors in addition to the patient alone.
For example, one commenter expressed concern that CMS has no risk-
adjustment methodology in place for patients' transitions into the
post-acute and long-term care sector and that many factors contribute
to cost variation in these milieu are outside of the control of the
facilities themselves. The commenter requested CMS to clearly define
risk stratification indices and develop a cost-to-risk algorithm based
on previous utilization data and incorporating specific, patient
characteristics, including functional status, age, and frailty, to
accurately evaluate EPM performance. Another commenter recommended that
CMS examine whether the CMS-HCC model would be an appropriate way to
measure the resource use of geriatricians as well as serve as a risk-
adjustment mechanism. Finally, one commenter urged CMS to modify the
risk-adjustment policy to reflect the relative riskiness of the
procedures as well as the beneficiary-specific demographic
characteristics and clinical indicators.
Response: We appreciate the comment supporting our proposal to
risk-stratify episode costs based largely on MS-DRGs with additional
adjustments for scenarios including chained anchor hospitalizations,
readmissions, and CABG as well as the many comments expressing concerns
about our proposal, data cited in support of these concerns, requests
for additional measures to adjust for risk, and suggestions on
approaches to consider for this purpose. We share commenters' interests
in ensuring that payments under the models are well aligned with costs
and adequately recognize cost variation associated with either the
services provided or beneficiary characteristics so that participants
are encouraged and able to be successful under the models, which
includes providing access to high quality care to Medicare
beneficiaries. In particular, we share commenters' concerns that
episode payments be more closely aligned with costs when all EPM
participants will assume downside risk and have their payments
determined more fully based on regional pricing.
Based on the comments we received, we are persuaded to explore
additional measures with which we could adjust EPM episode payments for
risk to complement our proposals to stratify and adjust episode
payments based on type and combination of anchor MS-DRGs included in an
episode. As such, we plan to examine a range of options such as CMS-HCC
scores, beneficiary factors, clinical factors, pathways including
planned readmissions after discharge for an acute cardiac event, and
other measures that potentially further explain variation in costs,
including socio-demographic factors such availability of primary care
services. As discussed in section III.D.7.c.(2) of this final rule, CMS
will also consider and potentially incorporate results from studies
conducted under the Improving Medicare Post-Acute Care Transformation
``IMPACT'' Act of 2014 (Pub. L. 113-183) with respect to factors,
including socio-demographic factors, that could affect resource use
under Medicare and the EPMs.
While we are optimistic that we will be able to identify factors
that explain more variation in episode expenditures than risk
stratification alone, we acknowledge that no combination of adjustments
will account for all variation in episode expenditures. Still, we
intend to proceed with the models and as discussed elsewhere in this
rule are finalizing other financial protections like an extended period
of no downside risk (see section III.D. 2.c.), capping high payment
episodes (see section III.D.3.d.), and more generous stop-loss
protections for certain hospitals (see III.D.7.c.(1)). We also intend
to engage with and seek input from stakeholders as we examine this
range of options prior to rulemaking.
Our goal is to make our refinements to the pricing methodology to
reflect risk adjustment effective beginning in PY3, which we would
establish based on a notice and comment rulemaking process. As such,
the additional measures would apply to episodes ending on or after
January 1, 2019 and that had anchor discharges occurring after October
1, 2018 and thus be in place at the time downside risk is required.
Final Decision: After consideration of the public comments
received, we are finalizing the proposal, without modification, to
risk-stratify episodes based on adjustments to recognize the
combination of MS-DRGs and pathways associated with an episode. We will
also explore and plan to implement additional adjustments to account
for risk through rulemaking to be effective in PY3.
(a) Adjustments for Certain AMI Model Episodes With Chained Anchor
Hospitalizations
In section III.C.4.a.(5) of the proposed rule, we stated that once
an AMI model episode is initiated at an AMI model participant, the AMI
model episode continues under the responsibility of that specific
participant, regardless of whether the beneficiary is transferred to
another hospital for further medical management of AMI or
revascularization through PCI or CABG during a chained anchor
hospitalization. Given there could be significant differences between
the discharge MS-DRG from the hospital that initiates the AMI episode
and the hospital to which a beneficiary is transferred, as well as the
Medicare payment associated with these different MS-DRGs and the post-
discharge spending for these beneficiaries, we stated that it would be
[[Page 307]]
appropriate to adjust the AMI model-episode benchmark prices for
certain AMI model episodes involving a chained anchor hospitalization.
More specifically, we indicated that it would be appropriate to make an
adjustment when a final hospital discharge MS-DRG in the chained anchor
hospitalization is an anchor MS-DRG under either the AMI or CABG model.
Thus, for episodes involving a chained anchor hospitalization with a
final discharge diagnosis of any of AMI MS-DRG 280-282, PCI MS-DRG 246-
251 without an intracardiac ICD-CM procedure code in any position on
the inpatient claim, or CABG MS-DRG 231-236, we proposed to set a
chain-adjusted AMI model-episode benchmark price or ``price MS-DRG''
based on the AMI, PCI, or CABG MS-DRG in the chained anchor admission
with the highest IPPS weight. If a CABG MS-DRG occurred in a chained
anchor hospitalization that was initiated with an AMI MS-DRG or PCI MS-
DRG without an intracardiac ICD-CM procedure code in any position on
the corresponding inpatient claim, we proposed that the AMI model
episode would begin with and be attributed to the first hospital, and
we proposed to set the price MS-DRG to the CABG MS-DRG in the chained
anchor hospitalization with the highest IPPS weight.
If the price MS-DRG was an AMI or PCI MS-DRG, we proposed to set
the episode benchmark price as the standard AMI model-episode benchmark
price for the price MS-DRG, subject to a possible adjustment for
readmission for CABG MS-DRGs, as described in section III.D.4.b.(2)(c)
of the proposed rule. If the price MS-DRG is a CABG MS-DRG, we proposed
to set the AMI model-episode benchmark price as the CABG model-episode
benchmark price for the corresponding CABG MS-DRG, with no further
adjustment in the event of a readmission for CABG MS-DRGs.
Table 13 displays the weights for CABG, PCI, and AMI MS-DRGs
established in the FY 2016 IPPS final rule, which are subject to change
each FY through the annual IPPS rulemaking (80 FR 49325 through 49886).
Table 13--FY 2016 IPPS Weights for MS-DRGS 231-236, 246-251, and 280-282
----------------------------------------------------------------------------------------------------------------
MS-DRG MS-DRG title Weights
----------------------------------------------------------------------------------------------------------------
231........................................... CORONARY BYPASS W PTCA W MCC.................... 7.8056
232........................................... CORONARY BYPASS W PTCA W/O MCC.................. 5.7779
233........................................... CORONARY BYPASS W CARDIAC CATH W MCC............ 7.3581
234........................................... CORONARY BYPASS W CARDIAC CATH W/O MCC.......... 4.9076
235........................................... CORONARY BYPASS W/O CARDIAC CATH W MCC.......... 5.8103
236........................................... CORONARY BYPASS W/O CARDIAC CATH W/O MCC........ 3.8013
246........................................... PERC CARDIOVASC PROC W DRUG-ELUTING STENT W MCC 3.2494
OR 4 + VESSELS/STENTS.
247........................................... PERC CARDIOVASC PROC W DRUG-ELUTING STENT W/O 2.1307
MCC.
248........................................... PERC CARDIOVASC PROC W NON-DRUG-ELUTING STENT W 3.0696
MCC OR 4 + VES/STENTS.
249........................................... PERC CARDIOVASC PROC W NON-DRUG-ELUTING STENT W/ 1.9140
O MCC.
250........................................... PERC CARDIOVASC PROC W/O CORONARY ARTERY STENT W 2.6975
MCC.
251........................................... PERC CARDIOVASC PROC W/O CORONARY ARTERY STENT W/ 1.6863
O MCC.
280........................................... ACUTE MYOCARDIAL INFARCTION, DISCHARGED ALIVE W 1.6971
MCC.
281........................................... ACUTE MYOCARDIAL INFARCTION, DISCHARGED ALIVE W 1.0232
CC.
282........................................... ACUTE MYOCARDIAL INFARCTION, DISCHARGED ALIVE W/ 0.7557
O CC/MCC.
----------------------------------------------------------------------------------------------------------------
We stated our belief that this proposal could minimize potential
disincentives to AMI model participants from transferring patients when
different or higher levels of care are needed. This is because the AMI
model-episode benchmark prices we set would be more representative of
the AMI spending based on the totality of care furnished during the
chained anchor hospitalization and post-discharge period within the AMI
model episode and for which the AMI model participants would be held
accountable. We also stated our view that our proposal could encourage
AMI model participants that frequently transfer patients after
admission to improve their efficiency and the quality of care by
transferring beneficiaries needing higher levels of care prior to
hospital admission and managing those beneficiaries admitted to reduce
the need for later transfers.
As an alternative, we also considered an approach where we would
set the target price taking into consideration IPPS payments for both
the MS-DRG assigned to the first admission in the chained anchor
hospitalization and the MS-DRG assigned to the final admission in the
chained anchor hospitalization. We could apply this approach to all AMI
model participant hospitals or to only a subset of hospitals based on
special situations that could lead to more common transfer scenarios
that are unavoidable, such as small bed-size, rural location,
interventional or cardiac surgery capacity, or other characteristic of
the hospitals. All AMI model episodes involving chained anchor
hospitalizations would include at least two IPPS payments for the
chained anchor hospitalization, compared to one IPPS payment for most
AMI episodes with only an anchor hospitalization that does not result
in an inpatient-to-inpatient transfer. In our view, the alternative
approach would likely result in a higher AMI-model episode benchmark
price than under our proposal for AMI model episodes including a
chained anchor hospitalization. Therefore, we noted that this
alternative approach could have the effect of further reducing
potential disincentives to hospitals from transferring patients when
different or a higher level of care is needed; however, we were not
convinced this approach would ultimately improve care quality and
efficiency under the AMI model.
First, we were concerned that this alternative approach could serve
as an incentive for hospitals to admit and then transfer patients when
doing so might not be medically necessary, which would neither enhance
care quality nor efficiency. A recent study showed that non-procedure
hospitals, defined as hospitals that lack onsite cardiac
catheterization and coronary revascularization facilities, vary
substantially in their use of the transfer process for Medicare
beneficiaries admitted with AMI.\79\ Beneficiaries
[[Page 308]]
transferred from hospitals that had a high transfer rate experienced
greater use of invasive cardiac procedures after admission to the
transfer hospital than beneficiaries transferred from hospitals with a
low transfer rate. However, higher transfer rates were not associated
with a significantly lower risk-standardized mortality rate at 30 days,
and at one year, there was only a 1.1 percent mortality rate difference
between hospitals with higher and lower transfer rates. As such, we
believed this alternative approach could be appropriate for only a
subset of AMI model participant hospitals based on specific hospital
characteristics that could lead to a higher frequency of unavoidable
transfers for AMI model beneficiaries rather than appropriate for
hospitals overall. In addition, if we were to adopt this alternative
approach, we believed it would also be necessary to incorporate methods
for monitoring changes in the frequency of AMI model participant
hospital patient transfers over the model's performance years, as well
as assessing the appropriateness of those transfers. For example, to
address changes in transfer frequency, we might compare how often an
AMI model participant hospital transferred a beneficiary following an
inpatient admission within each performance year relative to the
frequency of transfers during its initial 3-year historical period. To
address appropriateness of transfers, we might consider reviewing and
comparing a sample of a hospital's transfers within a performance year
as compared to the historical period. Furthermore, we might also
propose future changes to this approach where changes in the frequency
or appropriateness of transfers were identified.
---------------------------------------------------------------------------
\79\ Barreto-Filho J, Wang Y, Rathore SS, et al. Transfer Rates
From Nonprocedure Hospitals After Initial Admission and Outcomes
Among Elderly Patients With Acute Myocardial Infarction. JAMA Intern
Med. 2014;174(2):213-222. doi:10.1001/jamainternmed.2013.11944.
---------------------------------------------------------------------------
Second, in contrast to our proposal, we believed that this
alternative approach would not have the benefit of encouraging AMI
model participant hospitals to make an early decision and transfer
patients prior to rather than following inpatient admission when doing
so prior to admission would be appropriate for the beneficiary's
clinical circumstances and the hospital's capabilities. While we
recognized that in some cases, an AMI model beneficiary admitted to the
initial treating hospital may need to be transferred to a referral
hospital that can provide a different or higher level of care, we noted
our belief it is important that the AMI model's payment methodology
support the goal of rapid decision-making by the AMI model participant
hospital about the AMI model beneficiary's care pathway based on
clinical guidelines that often incorporate a time dimension in the
guidelines for care.
Thus, on balance, we believed that our proposed methodology would
best establish appropriate incentives to improve care quality and
efficiency under the AMI model by encouraging timely decisions about
admission to the initial treating hospital and incentivizing only those
transfers that are necessary to meet AMI model beneficiary's health
care during the course of their hospitalization. Our proposal would
adjust the AMI model-episode benchmark price that applies to the
episode when a chained anchor hospitalization occurs and results in
more costly care at the transfer hospital than would be expected based
on the anchor MS-DRG at the initial treating hospital who would be
accountable for the episode under the AMI model, thus accounting for
the care at the referral hospital.
In contrast, some chained anchor hospitalizations could begin an
episode based on an MS-DRG that anchors an episode in the model such as
an AMI MS-DRGs that subsequently also includes an MS-DRG that does not
anchor an episode under the model (for example, heart failure, renal
failure, or cardiac valve replacement). Some of these non-anchor MS-
DRGs could be related to the AMI episode but are unavoidable, for
example, cardiac valve surgery, while others could potentially reflect
complications resulting from inadequate care management during the
episode (for example, heart or renal failure).
As discussed in section III.C.4.b. of the proposed rule, we
proposed to cancel an AMI model episode when the final MS-DRG in a
chained anchor hospitalization is from an MS-DRG that would not an
anchor MS-DRG under the AMI or CABG model. We believed that, in tandem,
these proposals would allow for appropriate pricing of AMI model
episodes that continue and include chained anchor hospitalizations.
The proposals to establish pricing for AMI model episodes involving
chained anchor hospitalizations were included in Sec.
512.300(c)(7)(i). We sought comment on our proposals for pricing AMI
episodes involving chained anchor hospitalizations and the alternative
proposals we considered. We also sought comment on the alternative
considered that would account for both the MS-DRGs at the first and
last hospitals caring for the AMI model beneficiary during the chained
anchor hospitalization in setting the AMI-model episode benchmark price
for episodes involving a chained anchor hospitalization. In particular,
under such an alternative, we sought comment on the clinical
circumstances in which inpatient-to-inpatient transfers are unavoidable
and whether or not there are hospital characteristics that would lead
us to expect higher frequencies of unavoidable inpatient-to-inpatient
transfers for AMI model beneficiaries than hospitals overall. We also
sought comment on how we could discourage unintended consequences under
this alternative, such as less timely decisions about the most
appropriate hospital to treat the beneficiary and increased beneficiary
transfers that are unnecessary or inappropriate for improved quality of
AMI model episode care.
The following is a summary of the comments received and our
responses.
Comment: As discussed earlier in Section III.C.4.a. of this final
rule, many commenters expressed concerns and opposed the proposal that
once an AMI model episode is initiated at an AMI model participant, the
AMI model episode continues under the responsibility of that specific
participant, regardless of whether the beneficiary is transferred to
another hospital for further medical management of AMI or
revascularization through PCI or CABG during a chained anchor
hospitalization. Similarly, many commenters expressed concerns with
respect to the pricing of episodes in the case of these chained anchor
hospitalizations that generally paralleled the comments discussed in
section III.C.4.a. of this final rule.
Response: As discussed in section III.C.4.a., we were persuaded by
commenters to not finalize our proposal that once an AMI model episode
is initiated at an AMI model participant, the AMI model episode would
continue under the responsibility of that specific participant when a
beneficiary is transferred to another hospital for further medical
management of AMI or revascularization through PCI or CABG during a
chained anchor hospitalization. Instead, we are finalizing a policy
that for an episode involving an inpatient-to-inpatient transfer, the
episode would be attributed to the transfer hospital rather than the
initial hospital.
Accordingly, we are also not finalizing our proposed pricing
methodology for these episodes, which would have set a chain-adjusted
AMI model-episode benchmark price or ``price MS-DRG'' based on the AMI,
PCI, or CABG MS-DRG in the chained-
[[Page 309]]
anchor admission with the highest IPPS weight. Instead, we are
finalizing a policy where an episode's price will be determined only by
the anchor MS-DRG for the AMI or CABG model episode as determined by
the transfer hospital in the same manner as we would for any other AMI
episode that does not involve a transfer.
Since we are not finalizing our original proposal, we also will not
be finalizing the terms ``chained anchor hospitalization'' or ``price
MS-DRG'' as all episodes under the model will be priced based on their
assigned anchor MS-DRG. Accordingly, we will be deleting these terms
from our proposed regulations.
Final Decision: After consideration of the public comments
received, we are not finalizing the proposal to make payment
adjustments for AMI episodes involving a chained anchor
hospitalization, but will instead attribute the episode to the final
hospital and calculate prices for these episodes based on the anchor
MS-DRG for that episode determined by the transfer hospital. As such,
we are replacing the term ``price MS-DRG'' with ``MS-DRG'' and deleting
references to ``chained-anchor hospitalizations.'' Also as discussed in
section III.C.4.a.(5) of this final rule, given our concerns about the
potential missed opportunities and unintended consequences due to the
final AMI model transfer episode initiation and attribution policy, we
will be examining AMI transfers to and from AMI model participants very
closely through our monitoring and evaluation activities as discussed
in sections III.G.4. through 6. and IV. of this final rule, both of
beneficiaries that ultimately are included in AMI episodes and those
that are not. We may revisit the transfer policy or propose payment
adjustments through future rulemaking if we see reduced AMI transfer
efficiency, opportunities to increase transfer efficiency,
disproportionate transfers of complex AMI beneficiaries or those with
potentially avoidable complications suggesting that AMI model
participants are engaging in adverse patient selection or providing
poor quality care, inordinate loss of beneficiaries from the AMI model
due to transfer outside of the MSAs where the AMI and CABG models are
being tested, or other patterns of concern.
(b) Adjustments for CABG Model Episodes
Among Medicare beneficiaries historically discharged under a CABG
MS-DRG, average episode spending was substantially higher for those
beneficiaries who also had AMI ICD-CM diagnosis codes on their
inpatient claims ($57,000) than those who did not ($44,000).\80\ About
30 percent of CABG beneficiaries had AMI ICD-CM diagnosis codes on
their claims, while about 70 percent did not, and this percentage of
CABG beneficiaries with AMI varied substantially across IPPS hospitals
furnishing CABG procedures.\81\ While average spending, in total, was
substantially higher for CABG beneficiaries with AMI than without AMI,
average spending during the anchor hospitalization was not
substantially higher. Rather, much of this variation in CABG model
episode spending occurred after discharge from the anchor
hospitalization and correlated both with the presence of AMI and
whether the CABG beneficiary was discharged from the anchor
hospitalization in a CABG MS-DRG with major complication or comorbidity
(MS-DRGs 231, 233, or 235) as opposed to a CABG MS-DRG without major
complication or comorbidity (MS-DRGs 232, 234, or 236). Specifically,
we found that average CABG episode spending after discharge from the
anchor hospitalization was--
---------------------------------------------------------------------------
\80\ Episodes for CABG model beneficiaries initiated by all U.S.
IPPS hospitals and constructed using standardized Medicare FFS Parts
A and B claims, as proposed in this rule, that began in CYs 2012-
2014.
\81\ Episodes for CABG model beneficiaries initiated by all U.S.
IPPS hospitals and constructed using standardized Medicare FFS Parts
A and B claims, as proposed in this rule, that began in CYs 2012-
2014.
---------------------------------------------------------------------------
$9,000 for non-AMI CABG beneficiaries discharged from MS-
DRGs 232, 234, or 236;
$11,000 for CABG beneficiaries with AMI discharged from
MS-DRGs 232, 234, or 236;
$16,000 for non-AMI CABG beneficiaries discharged from MS-
DRGs 231, 233, or 235; and
$20,000 for CABG beneficiaries with AMI discharged from
MS-DRGs 231, 233, or 235.\82\
---------------------------------------------------------------------------
\82\ Episodes for CABG model beneficiaries initiated by all U.S.
IPPS hospitals and constructed using standardized Medicare FFS Parts
A and B claims, as proposed in this rule that began in CYs 2012-
2014.
---------------------------------------------------------------------------
Thus, for CABG model episodes, we proposed to set CABG model-
episode benchmark prices by first splitting historical CABG model-
episode expenditures into expenditures that occurred during anchor
hospitalizations and expenditures that occurred after discharge from
the anchor hospitalizations.
We proposed to calculate the CABG anchor hospitalization benchmark
price by following the general payment methodology that was applied to
the CJR model (80 FR 73337 through 73358), with expenditures limited to
those that occurred during the anchor hospitalization and risk
stratification according to the price CABG MS-DRG.
We also proposed to calculate the CABG post-anchor hospitalization
benchmark price by following the general payment methodology that was
applied to the CJR model (80 FR 73337 through 73358), with expenditures
limited to those that occurred after the anchor hospitalization and
risk-stratification according to the presence of an AMI ICD-CM
diagnosis code on the anchor inpatient claim and whether the price MS-
DRG is a CABG MS-DRG with major complication or comorbidity (231, 233,
or 235) or a CABG MS-DRG without major complication or comorbidity
(232, 234, or 236).
We proposed that the CABG model-episode benchmark price for an
episode would be the sum of the corresponding CABG anchor
hospitalization benchmark price and the corresponding CABG post-anchor
hospitalization benchmark price, as discussed in this section and in
III.D.4.d. of the proposed rule.
The proposals to establish pricing for CABG model episodes were
included in Sec. 512.300(c)(7)(ii). We sought comment on our proposals
to establish pricing for CABG model episodes.
The following is a summary of the comments received and our
responses.
Comment: One commenters suggested that CMS create a separate target
price for CABG episodes where a patient has a previous history of CABG.
Response: We appreciate the commenter's suggestion, but believe the
existing MS-DRGs that apply under the IPPS, which similarly do not
distinguish CABG MS-DRG discharges based on whether or not a
beneficiary had a previous history of CABG, our proposed pricing
adjustments for CABG episodes, and additional risk-adjustments that we
anticipate will be effective in PY3 should appropriately recognize the
potential costs for beneficiaries within CABG episodes whether or not
they had a previous history of CABG.
Final Decision: After consideration of the public comments
received, we are finalizing the proposal, without modification, to
establish pricing for CABG model episodes. Our final policy for
establishing CABG model episodes is included in Sec. 512.300(c)(7)(i).
(c) Adjustments for Certain AMI Model Episodes With CABG Readmissions
In section III.C.4.b of the proposed rule, we discussed AMI model
episodes where a beneficiary is discharged from an AMI model
participant under an AMI
[[Page 310]]
MS-DRG and is later readmitted for a CABG. In that section, we did not
propose to cancel the AMI model episode altogether for a CABG
readmission during the 90-day post-hospital discharge period or cancel
the AMI model episode and initiate a CABG model episode because planned
CABG readmission following an anchor hospitalization that initiates an
AMI episode may be an appropriate clinical pathway for certain
beneficiaries. For example, we noted that historically approximately 10
percent of those AMI beneficiaries who received CABGs during AMI
episodes would receive the CABG between 2 and 90 days post-discharge
from the anchor hospitalization, and most of those readmissions did not
occur through hospital emergency departments. Even though CABG
readmissions are not excluded from AMI model episodes (because they are
clinically-related to the AMI model episode), we proposed to provide an
adjusted AMI model-episode benchmark price in such circumstances so as
not to financially penalize AMI model participants for relatively
uncommon, costly, clinically-appropriate care patterns for AMI model
beneficiaries. Accordingly, we proposed to establish an adjusted CABG-
readmission AMI model-benchmark episode price for AMI model episodes
with a price MS-DRG of 280-282 or 246-251 that have readmission for a
CABG MS-DRG 231-236.
Specifically, if a CABG readmission occurs during an AMI model
episode with a price MS-DRG of 280-282 or 246-251, we proposed to
calculate a CABG-readmission AMI model-episode benchmark price equal to
the sum of the standard AMI model-episode benchmark price corresponding
to the price MS-DRG (AMI MS-DRGs 280-282 or PCI MS-DRGs 246-251) and
the CABG anchor hospitalization benchmark price corresponding to the
MS-DRG of the CABG readmission. Because the adjustment would be based
on the anchor hospitalization benchmark price, which does not include
costs associated with the post-discharge period for CABG, this
adjustment approach would avoid ``double counting'' post-discharge
costs. Because adjusting for spending that occurred during a CABG
readmission accounts for most of the spending variation between AMI
model episodes with a CABG readmission and AMI model episodes without a
CABG readmission, we proposed no additional adjustment to the price for
AMI model episodes with a CABG readmission.
In the event of any other readmission other than CABG during an AMI
model episode that is not excluded from the AMI model episode
definition, we would apply the usual rules of EPM-episode pricing that
would include the spending for the related readmission in the actual
AMI model-episode spending, without other adjustments. Fewer than 3
percent of those AMI model beneficiaries who receive inpatient or
outpatient PCIs during AMI episodes receive the PCIs between 2 and 90
days post-discharge from the anchor or chained anchor hospitalizations,
and we did not propose to make a pricing adjustment for PCIs that occur
later in the AMI model episodes after discharge from the anchor or
chained anchor hospitalizations. Since a PCI for an AMI typically is
provided during the anchor or chained anchor hospitalization and most
PCIs later in an episode occur in the context of a beneficiary
presenting through the emergency department, we believe that the
beneficiary likely has experienced a complication of care resulting in
a PCI that may potentially be avoided through care management during
the AMI model episode. Given that our intention is to offer appropriate
incentives for care quality and efficiency by holding AMI model
participants accountable for readmissions that could be related to the
quality of care provided prior to the readmission, we believe that an
adjustment other than for a CABG readmission would not be appropriate.
The proposal for adjusting episodes involving CABG readmissions was
included in Sec. 512.300(c)(7)(iii). We sought comment on our proposal
for adjusting episodes involving CABG readmissions.
The following is a summary of the comments received and our
responses.
Comment: Several commenters expressed concerns about the proposal
for adjusting episodes involving CABG readmissions--specifically, that
the proposal does not sufficiently account for the increased post-acute
care that a beneficiary typically receives after a CABG, but which they
would not receive after only an AMI. One of the commenters presented
data supporting their concern suggesting that post-discharge spending
for certain MS-DRGs with a CABG readmission was substantially higher
than for those same MS-DRGs without a CABG readmission. The commenters
requested that CMS modify the methodology to account for the increased
post-acute care that a beneficiary typically receives after a CABG.
Response: We appreciate the concerns raised by the commenters and
have conducted further analysis of our proposal with respect to how
well our proposal would account for post-acute care costs for AMI
episodes involving CABG readmissions. While we agree that spending
after discharge from the anchor stay for AMI episodes with CABG
readmissions is substantially higher than for episodes without these
readmissions, we disagree with suggestions that our proposal
inadequately adjusts for these differences. Rather, based on our
analysis, on average, the proposed adjustments account for the
overwhelming majority of additional spending that occurs in AMI
episodes with CABG readmissions relative to episodes without CABG
readmissions. Additionally, the number of episodes for many of the
affected MS-DRGs is relatively small, which we believe would impede our
ability to establish reliable prices that would be an improvement over
our current proposal in terms of payment accuracy. Accordingly, we are
not persuaded to modify our proposal.
Final Decision: After consideration of the public comments
received, we are finalizing the proposal, without modification, to
adjust episodes with CABG readmissions. Our final policy for adjusting
episodes with CABG readmissions is included in Sec. 512.300(c)(7)(ii).
(d) Potential Future Approaches To Setting Target Prices for AMI and
Hip Fracture Episodes
As previously described, our proposed approach for pricing AMI and
CABG model episodes for beneficiaries with AMI set different episode
target prices depending upon whether the beneficiary is managed
medically, undergoes PCI, or undergoes CABG during the acute phase of
the episode, as well as whether the episode involved a chained anchor
hospitalization or CABG readmission. Similarly, the target price set
for beneficiaries experiencing hip fracture would depend on whether the
patient undergoes hip fixation (and therefore initiates a SHFFT model
episode) or hip arthroplasty (and therefore initiates a CJR model
episode). We believed that this would be a prudent approach that both
recognizes the resource costs of services provided while encouraging
care redesign during the portions of these episodes that we believe
present the greatest opportunities to improve the quality and
efficiency of the care delivered. However, we noted that the general
principle guiding our payment reform efforts is that the payment system
should hold providers accountable for the overall quality and cost of
the care their beneficiaries receive rather than
[[Page 311]]
setting their payment based on the specific services delivered or
settings in which they are delivered. We indicated that this approach
would give providers maximum flexibility to redesign care in ways that
both produce the best outcomes for patients and controls the growth in
spending for these services.
For this reason, we expressed interest in exploring future
approaches to episode payment that would set an inclusive target price
for episodes for beneficiaries with AMI that does not depend on whether
the beneficiary is managed medically or receives PCI or CABG during the
acute portion of the episode and, similarly, future approaches that
would set prices for episodes for beneficiaries with hip fracture that
do not depend on whether the beneficiary undergoes hip fixation or hip
arthroplasty. While we believe that the choice of treatment during the
acute phase of these episodes may be determined predominantly by
clinical factors such that financial factors may play a smaller role in
shaping episode care redesign than they do following hospital
discharge, we nevertheless believe it would be valuable to consider
testing an inclusive episode payment model. Providers may be able to
redesign and implement care pathways that we might not have otherwise
anticipated, especially as the evidence-base for AMI and hip fracture
treatment continues to grow and evolve.
We sought comment on this type of approach to setting an inclusive
episode target price and on any episode payment model design features
that would be needed to make such an approach successful. In
particular, we sought comment on potential approaches to risk-
adjustment aimed at ensuring that providers are appropriately paid for
caring for high-complexity episode beneficiaries in the context of this
alternative approach. We would seek to ensure that all providers caring
for these episode beneficiaries, including those providers for which we
proposed additional protections and those that serve a high percentage
of potentially vulnerable populations of medically and socially complex
patients as discussed in section III.D.7.c. of the proposed rule, would
not bear undue financial risk and to mitigate any incentives to avoid
caring for high-complexity patients. In addition, we sought comment on
whether and how our methodology linking quality performance to payment
under the EPMs and the CJR model might need to be modified in the
context of this alternative approach that would set an inclusive
episode target price, in order to appropriately incentivize the
delivery of high-quality care and discourage stinting on appropriate
care.
The following is a summary of the comments received and our
responses. The comments we received typically recommended that we
consider either population-based models or capitated models, which we
have addressed in section III.D.2.b. of this final rule; however, we
are providing some specific examples that were recommended in the
following comments.
Comment: A commenter recommended that we consider a population-
based model that was tied to an ``event'' such as a beneficiary's
initial Medicare enrollment in a selected geographic area such as a
county or MSA; however, we should exclude Medicare Advantage enrollees
or enrollees participating in other Medicare payment reform efforts.
The model would include multiple quality measures reflecting both a
clinical perspective and a beneficiary perspective. The model could
include two tracks: Full financial accountability and partial financial
accountability. Under the first track, we would pay participating
providers a monthly, all-inclusive, beneficiary-risk-adjusted premium
based on regional historical expenditures and the provider would assume
full risk for all Part A and Part B expenditures. Under the partial
financial accountability track, we would continue to provide the plan
administration (allowing provider organizations without claims-payment
and risk-assumption capabilities the opportunity to participate). Model
participants would receive a monthly, beneficiary-risk-adjusted target
budget for Medicare Part A and Part B services and their actual
expenditures would be compared against their target budget at the end
of each year for reconciliation. If costs exceeded the target, then the
participant would repay CMS an agreed upon amount. If costs were below
the target, then CMS would pay the participant an agreed upon amount.
Both tracks could be eligible for Advanced APM designation under the
Quality Payment Program, if they had a certified Electronic Health
Record technology requirement for participants.
Another commenter, who had suggested that CMS adopt a model
including prospective negotiated rates rather than retrospective
reconciliation of fee-for-service claims, suggested that a capitated
model would allow providers to experiment with services, in addition to
telehealth consultations, that do not generate a fee-for-service claim.
In their view, hospitals and surgeons have more opportunity to innovate
in how they deploy professional staff, choose technology, and engage
with outpatient and home-based services when they have full flexibility
within a budgeted payment amount, and would encourage collaboration
between all clinicians involved in patient care as well as provide
predictable pricing. Also, the commenter believes that using
prospectively determined negotiated rates or competitive bids would
result in a more rapid transformation in cost and resource use. In
their view, using target prices based on a provider's historical costs
or the region's average costs is inconsistent with the goal of
implementing innovative payment models. Moreover, current practice
patterns should not be used to set a total cost for care, given the
unnecessary care, excessive costs and cost variations that result from
this payment approach. As such, this commenter recommend that providers
competitively bid their episode price to encourage competition among
providers to achieve the best outcomes for the lowest cost.
A commenter recommended that CMS design EPMs that would allow
providers two options; specifically to (1) organize themselves in the
manner most efficient to accept a prospective bundled payment from
Medicare, and allocate it among the participating providers or (2) if
other providers find it easier to continue billing under current
payment systems, then retrospectively reconcile those payments against
a prospectively defined budget. In this commenter's view, jointly-
governed teams should have the flexibility to determine which
organizational approach and retrospective or prospectively-determined
payment model best works for their particular circumstances.
Another commenter suggested that CMS consider a model that pays
specialists for management of specific conditions and combinations of
conditions using the same payment model concepts being used with
primary care physicians in the Comprehensive Primary Care Plus
initiative. Under this model, CMS should focus accountability on
services directly related to the condition, rather than total spending
on all of the patients' health care needs and for which the physician
may be unable to control. Further, the model would encourage the use of
physician-defined patient condition categories to ensure effective risk
stratification in condition-based payment models. These models would be
risk stratified based on the clinical characteristics and functional
status of patients that are most relevant to the types of conditions
being
[[Page 312]]
managed. Patients could designate the physician who would be managing
care for their condition(s) but would be required to use the team of
providers chosen by that physician for delivery of services related to
the condition(s). Further, target spending amounts would be set for
condition-based payments and episode payments prior to the beginning of
the performance period. Finally, physicians and other providers could
be for high-value services that are not currently billable as part of
condition-based and episode-based payment models that use retrospective
reconciliation.
Another commenter noted that while not recommending a specific
framework, CMS should consider additional geographic-based models that
include other costly procedures that vary in total episode costs, for
example, spine surgery.
Response: We appreciate the comments and suggestions that were
offered and that while not adopting these suggestions for these models,
we will take them into consideration as we explore similar models in
the future.
(e) Summary of Final Pricing Methodologies for AMI, CABG, and SHFFT
Model Episode Scenarios
Tables 14 through 16 summarize our final standard pricing
methodologies and the adjustments that will occur that are in sections
III.D.4.b.(1) and (2) of this final rule for AMI, CABG, and SHFFT model
episodes.
Table 14--AMI Model Pricing Scenarios
------------------------------------------------------------------------
AMI pricing scenario Price
------------------------------------------------------------------------
Single hospital AMI MS-DRG or PCI MS- Episode benchmark price is
DRG (with AMI diagnosis). standard episode benchmark
price based on anchor MS-DRG.
An AMI MS-DRG or PCI MS-DRG (with AMI Episode benchmark price is the
diagnosis) anchored episode with CABG sum of the standard episode
readmission. benchmark price corresponding
to the anchor MS-DRG and the
CABG anchor hospitalization
benchmark price corresponding
to the CABG readmission MS-
DRG.
------------------------------------------------------------------------
Table 15--CABG Model Pricing Scenarios
------------------------------------------------------------------------
CABG pricing scenario Price
------------------------------------------------------------------------
Single hospital CABG MS-DRG with AMI Episode benchmark price is the
diagnosis. sum of the CABG anchor
hospitalization benchmark
price for the MS-DRG and the
CABG post-anchor
hospitalization benchmark
price based on the presence of
an AMI ICD-CM diagnosis code
and whether the anchor MS-DRG
is w/MCC or w/o MCC.
Single hospital CABG MS-DRG without AMI Episode benchmark price is the
diagnosis. sum of the CABG anchor
hospitalization benchmark
price for the MS-DRG and the
CABG post-anchor
hospitalization benchmark
price based on no AMI ICD-CM
diagnosis code and whether the
anchor MS-DRG is w/MCC or w/o
MCC.
------------------------------------------------------------------------
Table 16--SHFFT Model Pricing Scenarios
------------------------------------------------------------------------
SHFFT pricing scenario Price
------------------------------------------------------------------------
SHFFT MS-DRG........................... Episode benchmark price is
standard episode benchmark
price based on anchor MS-DRG
(which is the price MS-DRG).
------------------------------------------------------------------------
(3) Three Years of Historical Data
As was the case for the CJR model (80 FR 73340 through 73341), we
proposed to use 3 years of historical EPM episodes for calculating EPM
participants' EPM-episode benchmark prices, with each set of historical
episodes updated every other year (81 FR 50854). Under our proposal,
each of the first 2 years of historical data would be trended to the
most recent of the 3 years, based on national trend factors for each
combination of price MS-DRGs and payments would be updated for each
payment system (for example, IPPS, PFS, etc.) based on annual changes
in input costs (see sections III.D.4.b (4) and III.D.4.b (5) of the
proposed rule). Under our proposal, we would establish historical EPM-
episode payments based on episodes that started between--
January 1, 2013 and December 31, 2015 for performance
years 1 and 2;
January 1, 2015 and December 31, 2017 for performance
years 3 and 4; and
January 1, 2017 and December 31, 2019 for performance year
5.
We believe that 3 years of historical EPM-episode data should
provide sufficient historical episode volume to reliably calculate EPM-
episode benchmark prices, and that updating these data every other year
would allow us to make the most current claims data available in a way
that incorporates the effects of regular Medicare payment system
updates and changes in utilization without creating uncertainty in
pricing for EPM participants. We would further note that the effects of
updating EPM-participant hospital-specific data on an EPM-episode's
benchmark prices would diminish over time as the contribution of
regional pricing on EPM benchmark prices will increase from one-third
for performance years 1 and 2 to two-thirds in performance year 3, and
100 percent in performance years 4 and 5.
The proposal for 3 years of historical data updated every other
year under the EPMs was included in Sec. 512.300(c)(1).
We sought comment on our proposal for 3 years of historical data
updated every other year.
The following is a summary of the comments received and our
responses.
Comment: Some commenters requested that CMS apply more trend data
than the 3 years we proposed. A commenter expressed concern that in the
absence of several years of historical data, target setting would not
fully reflect case mix and behavior changes in addition to historical
claims patterns.
[[Page 313]]
Further, an impact of a focus on short-term costs may be a shift away
from new technologies proven to improve outcomes and reduce costs.
Another commenter requested an additional 2 years of trend data for
Program Year 1, to bring the data up from 2015 to the 2017 program
level and another 3 years of trend data to bring the 2015 claims up to
the 2018 level. A commenter requested that the process be open and
transparent so as to insure that all impacted collaborators are given
the information and opportunity to comment and adjust.
Response: We continue to believe our proposed period for 3 years of
historical data updated every other year is appropriate for the models.
We disagree that including additional years of data beyond those we
proposed would be necessary or helpful. Instead, rather than improving
our historical data, the request for additional years of data could
result in more heterogeneous historical data that is less reflective of
a participant's most recent performance.
Final Decision: After consideration of the public comments
received, we are finalizing the proposal, without modification to use 3
years of historical EPM episodes for calculating EPM participants' EPM-
episode benchmark prices, with each set of historical episodes updated
every other year. The final policy for using 3 years of historical EPM
episodes for calculating benchmark prices is included in Sec.
512.300(c)(1).
(4) Trending Historical Data to the Most Recent Year
We recognize that some payment variation could exist in the 3 years
of historical EPM-episode data due to annual Medicare payment system
updates (for example, IPPS, OPPS, IRF PPS, SNF PPS) and national
changes in utilization patterns. Thus, EPM episodes in the third year
of the 3 historical years might have higher average payments than those
from the earlier 2 years, in part due to Medicare payment rate
increases over the course of the 3-year period. Also, EPM-episode
payments could change over time due to national trends reflecting
changes in industry-wide practice patterns. For example, readmissions
for all patients, including those in CABG model episodes, may decrease
nationally due to improved industry-wide surgical protocols that reduce
the chance of infections. We do not intend for the incentives under the
EPMs to be affected by Medicare payment system rate changes that are
beyond EPM participants' control or to provide reconciliation payments
to (or require repayments from) EPM participants for achieving lower
(or higher) Medicare expenditures solely because they followed national
changes in practice patterns. Instead, we aim to incentivize EPM
participants to improve care quality and efficiency based on their
hospital-specific inpatient and post-discharge care practices under the
EPMs.
To mitigate the effects of Medicare payment system updates and
changes in national utilization practice patterns on the 3 years of
historical episode data, we proposed to apply a national trend factor
to each of the years of historical EPM-episode payments (81 FR 50855)
as we do with the CJR model (80 FR 73341 through 73342). Specifically,
we proposed to inflate the 2 oldest years of historical EPM-episode
payments for EPM episodes to the most recent year of the 3 historical
years using changes in the national EPM-episode payments for each
different type of EPM episode. That is, we proposed to apply separate
national trend factors for the following pricing scenarios:
SHFFT model episodes, separately by each price MS-DRG in
480-482.
AMI model episodes without CABG readmissions, separately
by each price MS-DRG in 280-282 and 246-251; and
The anchor hospitalization portion of CABG model episodes,
separately by each price MS-DRG in 231-236.
The post-anchor hospitalization portion of CABG model
episodes, separately for:
++ With AMI ICD-CM diagnosis code on the anchor inpatient claim and
CABG price MS-DRG with major complication or comorbidity (231, 233, or
235);
++ With AMI ICD-CM diagnosis code on the anchor inpatient claim and
CABG price MS-DRG without major complication or comorbidity (232, 234,
or 236);
++ Without AMI ICD-CM diagnosis code on the anchor inpatient claim
and CABG price MS-DRG with major complication or comorbidity (231, 233,
or 235); and
++ Without AMI ICD-CM diagnosis code on the anchor inpatient claim
and CABG price MS-DRG without major complication or comorbidity (232,
234, or 236).
For example, when using Calendar Year (CY) 2013 through 2015
historical EPM-episode data to establish EPM-episode benchmark prices
for performance years 1 and 2, we would calculate an aggregate national
average SHFFT model episode payment in historical episodes with price
MS-DRG 480 for each of the 3 historical years. To trend historical
payments to the most recent year in an historical window, we would
create a ratio based on national average historical EPM-episode payment
for that episode type in a previous year and for the most recent year.
Thus, in this example, we would create a ratio of national average
SHFFT model historical episode payment with price MS-DRG 480 in CY 2015
as compared to that national average SHFFT model historical episode
payment in CY 2013 in order to trend the CY 2013 historical SHFFT model
episode payments to CY 2015. Similarly, we would determine the ratio of
the national average SHFFT model historical episode payment for CY 2015
to national average SHFFT model historical episode payment in CY 2014
to trend 2014 SHFFT model episode payments to CY 2015. This process
would be repeated for each pricing scenario previously listed.
We noted our belief that this method for trending data would
capture updates in Medicare payment systems as well as national
utilization pattern changes that might have occurred within that 3-year
period. Moreover, as with the CJR model, we believed that adjusting for
national rather than regional trends in utilization would be most
appropriate as any Medicare payment system updates and significant
changes in utilization practice patterns would not be region-specific
but rather be reflected nationally.
The proposal for trending historical data was included in Sec.
512.300(c) (11). We sought comment on our proposal for trending
historical data.
The following is a summary of the comments received and our
responses.
Comment: A few commenters addressed the use and trending of
historical data. A commenter expressed their general agreement with the
proposed trending methodology, but recommended that CMS update prices
every other year rather than annually to limit the extent that
participants would face increasingly more difficult targets. Another
commenter recommended that CMS trend the initial 3 years of historical
data for the full five years of the models. A commenter suggested that
CMS apply more trend data to each performance year and expressed
concerns that while CMS would trend data to the end of the benchmark 3-
year period, CMS would not be trending data from the end of the
benchmark period to match the time period for which the prices will be
applied to pay providers.
Response: We appreciate the comments we received on our proposal to
trend data and would like to clarify that their application would be on
a semi-annual basis when we update target prices rather than annually.
We disagree with the suggestion to apply
[[Page 314]]
the 3 initial years of trend data to all five performance years as our
intention is to establish target prices for the models using more
recent performance data so as to maintain incentives for participants
to continuously improve. Similarly, we disagree with the suggestion to
expand the number of years used to trend data or to permanently relate
trend data for a given performance year to those data for the initial
3-year benchmark period as doing so would result in data that are less
representative of a participant's most recent performance.
Final Decision: After consideration of the public comments
received, we are finalizing the proposal, without modification, to
trend data. Our final policy for trending data is included in Sec.
512.300(c) (11).
(5) Update Historical EPM-Episode Payments To Account for Ongoing
Payment System Updates
As previously mentioned, we proposed to prospectively update the
historical EPM- episode payments to account for ongoing updates to
Medicare payment systems (for example, IPPS, OPPS, IRF PPS, SNF, PFS,
etc.) in order to ensure we incentivize EPM participants based on
historical utilization and practice patterns, not Medicare payment
system rate changes that are beyond hospitals' control. Under our
proposal (81 FR 50855), we would apply the same methodology developed
for the CJR model to incorporate Medicare payment updates (80 FR 73342
through 73446).
Because Medicare payment systems rates are not updated at the same
time during the year--for example, rates under the IPPS, IRF PPS, and
SNF payment systems are updated effective October 1, while the hospital
OPPS and MPFS rates are updated annually effective January 1--we
proposed to generally update historical EPM-episode payments and
calculate EPM-episode benchmark prices separately for EPM episodes
initiated between January 1 and September 30 versus October 1 and
December 31 of each performance year, and at other intervals if
determined necessary. The EPM-episode benchmark price in effect as of
the day the EPM episode is initiated would be the EPM-episode benchmark
price for the whole EPM episode. Note that for performance year 5, the
second set of EPM-episode benchmark prices would be for EPM episodes
that start and end between and including October 1 and December 31
because the fifth performance period of the SHFFT, CABG, and AMI models
would end on December 31, 2021. Also, an EPM episode benchmark price
for a given EPM performance year could be applied to EPM episodes
included in another performance year. For example, an EPM episode
initiated in November 2017, and ending in February 2018 would have an
EPM-episode benchmark price based on the second set of 2017 EPM-episode
benchmark prices (for EPM episodes initiated between October 1, 2017,
and December 31, 2017), and it would be captured in the CY 2018 EPM
performance year (performance year 2) because it ended between January
1, 2018, and December 31, 2018. We refer to section III.D.2.a. of this
final rule for further discussion on the definition of EPM performance
years.
We proposed to update historical EPM-episode payments by applying
separate Medicare payment system update factors each January 1 and
October 1 to each of the following six components of each EPM
participant's historical EPM-episode payments:
Inpatient acute.
Physician.
IRF.
SNF.
HHA.
Other services.
A different set of update factors would be calculated for January 1
through September 30 versus October 1 through December 31 EPM episodes
each EPM performance year. The six update factors for each of the
previously stated components would be EPM-participant hospital-specific
and would be weighted by the percent of the Medicare payment for which
each of the six components accounts in the EPM participant's historical
EPM episodes. The weighted update factors would be applied to
historical EPM-participant-specific average payments to incorporate
ongoing Medicare payment system updates. A weighted update factor would
be calculated by multiplying the component-specific update factor by
the percent of the EPM participant's historical EPM-episode payments
the component represents, and summing together the results. Each of an
EPM participant's six update factors would be based on how inputs have
changed in the various Medicare payment systems for the specific EPM
participant.
As an example, we would assume for purposes of this example that 50
percent of an EPM participant's historical EPM-episode payments were
for inpatient acute care services, 15 percent were for physician
services, 35 percent were for SNF services, and 0.0 percent were for
the remaining services. We would also assume for purposes of this
example that the update factors for inpatient acute care services,
physician services, and SNF services are 1.02, 1.03, and 1.01,
respectively. The weighted update factor in this example would be the
following: (0.5 * 1.02) + (0.15 * 1.03) + (0.35 * 1.01) = 1.018. The
EPM participant in this example would have its historical average EPM-
episode payments multiplied by 1.018 to incorporate ongoing payment
system updates. The specific order of steps, and how this step fits in
with others, is discussed further in sections III.D.4.c through d. of
the proposed rule. Also, as discussed further in sections III.D.4.c.
through d. of the proposed rule, the update factors would vary by price
MS-DRG. For example, in CABG model episodes, the update factors would
be calculated separately for the anchor hospitalization portion of
episodes and the post-anchor hospitalization portion of episodes, as
described in section III.D.4.d. of the proposed rule.
Region-specific update factors for each of the previously stated
components and weighted update factors would also be calculated in the
same manner as the EPM-participant-specific update factors. Instead of
using historical EPM episodes attributed to a specific hospital,
region-specific update factors would be based on all historical EPM
episodes initiated at any IPPS hospital within the region with
historical EPM episodes, regardless of whether or not the MSAs in which
the hospitals are located were selected for inclusion in the models. We
referred to the CJR Final Rule (80 FR 73342 through 73446) for further
discussion of our specific methodology and considerations for adopting
this methodology for updating historical EPM-episode payments for
ongoing payment system updates.
The proposal for updating episode payments for ongoing annual
Medicare payment updates was included in Sec. 512.300(c)(10). We
sought comment on our proposal for updating episodes payments for
ongoing annual Medicare payment updates. We received no specific
comments on our proposal for updating historical EPM-episode payments
to account for ongoing payment system updates. However, we wish to
highlight that, as we do for the CJR model (80 FR 73343 through 73344),
where an equation is used to calculate update factors for payment
systems that apply annual updates to their rates effective October 1 of
each year such as for inpatient acute, SNF, and IRF services, in lieu
of calculating the update factors using the values applicable at the
end of the latest historical year used to calculate target prices, we
use a blend of the values applicable during the latest historical
[[Page 315]]
year. This blend is intended to account for the payment systems that
update payment rates on a fiscal year cycle, and ensure we are
calculating update factors based on the payment rates that apply to a
given period to the extent feasible, and result in more accurate target
price calculations.
Final Decision: We are finalizing the proposal, without
modification, to update episode payments for ongoing annual Medicare
payment updates. The final policy for updating episode payments for
ongoing annual Medicare payment updates is included in Sec.
512.300(c)(10).
(6) Blend Hospital-Specific and Regional Historical Data
We proposed to calculate EPM-episode benchmark prices using a blend
of EPM-participant-specific and regional historical average EPM-episode
payments, including historical EPM-episode payments for all IPPS
hospitals that are in the same U.S. Census division, which was
discussed further in section III.D.4.b.(7) of the proposed rule (81 FR
50856). Specifically, we proposed to blend two-thirds of the EPM-
participant-specific historical EPM-episode payments and one-third of
the regional historical EPM-episode payments to set an EPM
participant's EPM-episode benchmark prices for the first 2 performance
years of the EPMs (CYs 2017 and 2018). For performance year 3 of the
EPMs (CY 2019), we proposed to adjust the proportion of the EPM-
participant-specific and regional historical EPM-episode payments used
to calculate the EPM-episode benchmark prices from two-thirds EPM
participant-specific and one-third regional to one-third EPM
participant-specific and two-thirds regional. Finally, we proposed to
use only regional historical EPM-episode payments for performance years
4 and 5 of the EPMs (CYs 2020 and 2021) to set an EPM participant's EPM
episode-benchmark prices, rather than a blend between the participant-
specific and regional historical EPM episode payments.
Consistent with our methodology for the CJR model (80 FR 73544), we
proposed two exceptions. First, we proposed to use only regional
historical EPM-episode payments to calculate EPM episode-benchmark
prices for EPM participants with low historic EPM-episode volume). For
SHFFT model episodes, this exception applies to SHFFT model
participants with fewer than 50 historical SHFFT model episodes in
total across the 3 historical years. For AMI model episodes anchored by
MS-DRGs 280-282, this exception applies to AMI model participants with
fewer than 75 of these particular AMI model historical episodes in
total across the 3 historical years. For AMI model episodes anchored by
PCI MS-DRGs 246-251, this exception applies to AMI model participants
with fewer than 125 of this particular AMI model historical episodes in
total across the 3 historical years. For CABG model episodes, this
exception applies to CABG model participants with fewer than 50
historical CABG model episodes in total across the 3 historical years.
The thresholds for low historic volume in this final rule are higher
than the CJR model threshold for low historical LEJR episode volume of
20 episodes in total across the 3 historical years. The higher
thresholds are based on the volume thresholds from the BPCI Model 2
Risk Track B for 90-day episodes, which increase when the ratio of
within-hospital episode spending variation to between-hospital episode
spending variation increases. That is, as EPM episode payment variation
increases within a hospital relative to EPM-episode payment variation
between hospitals, it is necessary to have more EPM episodes at that
hospital to estimate a stable EPM-episode benchmark price using data
from only that hospital. We proposed to set higher thresholds for the
SHFFT, AMI, and CABG models based on internal analysis from BPCI
episode data that shows higher within-hospital episode spending
variation relative to between-hospital episode spending variation for
episodes anchored by the EPM MS-DRGs, compared to episodes anchored by
MS-DRGs 469 and 470 included in the CJR model.\83\
---------------------------------------------------------------------------
\83\ BPCI Model 2 Baseline Price Common Template calculations
for 90-day episodes in Risk Track B calculates BPCI volume
thresholds based on the ratio of within-hospital episode spending
variation and between-hospital episode spending variation for BPCI
Clinical Episodes, based on episodes that met BPCI eligibility
criteria and that began in July 1, 2009-June 30, 2012.
---------------------------------------------------------------------------
Second, in the case of an EPM participant that has undergone a
merger, consolidation, spin-off, or other reorganization that results
in a new hospital entity without 3 full years of historical claims
data, we proposed that EPM participant hospital-specific historical
EPM-episode payments would be determined using the historical EPM
episode payments attributed to their predecessor(s), as in the CJR
model (80 FR 73544).
The aforementioned proposals align with our method for blending EPM
participant hospital-specific and regional data under the CJR model. We
referred to the CJR model Final Rule (80 FR 73346 through 73349) for
further discussion on alternatives to and reasons for adopting this
methodology for the CJR model, which informed our proposal with respect
to the EPMs.
The proposal for blending payments when establishing participants'
benchmark and quality-adjusted targets and certain exceptions was
included in Sec. 512.300(c)(2), (3), and (4). We note that the
specific order of steps, and how this step fits in with others, is
discussed further in section III.D.4.c. of this final rule. We sought
comment on our proposal for blending payments when establishing
participants' benchmark and quality-adjusted targets as well as the
exceptions.
The following is a summary of the comments received and our
responses.
Comment: Commenters expressed different views on the proposal to
base prices initially on a blend of participant-specific and regional
historical data, while phasing in full regional pricing. Their
perspective commonly related to the proposal to determine regional
prices based on U.S. Census Divisions, which is discussed in section
III.D.4.b.(7) that immediately follows. Some commenters appreciated the
proposal of moving to regional pricing because it would help attenuate
the effect of participants having to compete against their own best
performance and where the most efficient participants in a region could
be rewarded. Moreover, some of these commenters recommended that CMS
even accelerate regional pricing or allow efficient participants the
option to transition from historic to regional target prices at an
accelerated rate. A commenter viewed the proposal as a way to
incentivize both historically efficient and less efficient hospitals to
provide high quality, efficient care.
Response: We appreciate the comments supporting our proposal to
blend payments when establishing participants' benchmark and quality-
adjusted targets and agree with their perceived benefits of the
proposal. We do not agree with suggestions to accelerate regional
pricing or allowing flexibility for hospitals to accelerate their
transition to regional prices. We continue to believe our proposed
phase-in period for regional pricing would generally be most protective
of participants as they adjust to the models because their performance
would be compared to their own historical performance rather than
hospitals in their region. We are also concerned that allowing certain
hospitals the option to accelerate toward regional pricing as was
suggested could affect our estimates
[[Page 316]]
and possibly generate inflated reconciliation payments due to potential
selection issues if historically efficient hospitals were to opt
earlier for a more generous regional price. Allowing certain hospitals
the option to select regional pricing earlier would also increase
administrative complexity under the models.
Comment: Several commenters opposed proposed regional pricing
policy, asking that CMS slow its phase-in period, asking that CMS
phase-in regional prices to something less than 100 percent, for
example, to only a 50-50 blend of participant-specific and regional
pricing, or relying solely on participant-specific performance data.
Some commenters suggested that hospitals might not be prepared to
compete relative to regional pricing while others expressed concern
that hospitals would be penalized for factors beyond their control, for
example, hospitals with a disproportionately large population of high-
cost or vulnerable beneficiaries. Thus, several commenters suggested
that CMS also account for these factors.
Response: As we stated in the CJR Final Rule (80 FR 73348), we
believe that only using participant-specific pricing would not reward
already efficient participants for maintaining high performance and
participants already delivering high quality and efficient care would
find it challenging to improve upon their own historical performance to
quality for reconciliation payments. We appreciate the concerns raised
about participants being penalized for factors beyond their control
once regional prices are phased-in. As discussed earlier in section
III.D.4.b.(2) of this final rule, we will be exploring additional
methods for further risk-adjusting episodes under the models that we
intend to make effective by PY3. We believe that these additional
adjustments in tandem with our general methodology for risk
stratification, caps on high-payment episodes, and limits on Medicare
repayments will offer sufficient protections to participants so that
they are not penalized once regional pricing is phased-in.
Comment: Some commenters noted that even when regional pricing is
fully phased-in, CMS and participants will see diminishing returns over
time, beginning with providers in low-spending areas where more limited
opportunities for additional gains in efficiency exist and target
prices could not be further constrained without putting the quality of
care at risk. Thus, these commenters requested that CMS use the higher
of national or regional historical episode payments when calculating
the target price to help ensure that appropriate incentives are
provided to participants in both high- and low-spending areas. A
commenter recommended that CMS vary pricing based on whether the
participants is in a MSA with higher or lower than average historical
prices. For example, for participants in MSAs with costs well above the
national average, target prices would be based on a blend of
participant-specific data and MSA historical data to help level the
playing field while continuing to allow program savings. For
participants in MSAs already below the national average, CMS should use
a 5-state regional benchmark that would allow high performing MSAs to
drive improvement and achieve savings for CMS and providers.
Alternatively, some commenters recommended that CMS adopt a bifurcated
transition whereby it uses a lower weight for the participants
determined to have spending higher than their region similar to the
Shared Savings Program.
Response: As we stated in the CJR Final Rule (80 FR 73348), we
believe that using the higher of regional and participant-specific
prices would not sufficiently incentivize inefficient participants to
become more efficient. That is, participants with historically high
episode expenditures would have less of an incentive to become more
efficient over the course of a model if they can quality for
reconciliation payments by improving only slightly relative to their
own performance while still being less efficient than their regional
peers.
We appreciate the suggestions to adopt a bifurcated transition or
to vary pricing based on whether the participant is in a MSA with
higher or lower than average historical prices--that is, to base target
prices on a blend of participant-specific data and MSA historical data
in MSAs with higher than average costs and a 5-state regional benchmark
for hospitals in MSAs with lower than average costs, but do not believe
these would materially improve upon our proposed methodology. We
believe the protections we are offering participants are sufficient and
obviate further adjustments such as the ``bifurcated'' transition or
weighting adjustments recently adopted for the Shared Savings Program.
Further, we believe the latter proposal would decrease incentives for
all participants by potentially making it too difficult to achieve
success for participants in higher-spending regions while relaxing
standards for those in lower spending regions.
Comment: Some commenters recommended that, in lieu of regional
pricing targets, CMS adopt national targets. In its comments, MedPAC
noted that national prices are used in other Medicare FFS payment
systems and that it believes the EPMs should transition to national
prices. Further, in 2013, MedPAC reported that risk-adjusted spending
on post-acute care and readmissions varied about 30 percent between
high- and low-spending MSAs for SHFFT episodes. Transitioning to
regionally-based benchmarks, as opposed to nationally-based benchmarks,
will continue to allow large differences in spending across the
country. In markets with long-term care hospitals (LTCH) and inpatient
rehabilitation facilities (IRF), these high-cost settings will raise
the participants' benchmarks. In markets without these providers, on
the other hand, post-acute care is delivered in lower-cost settings and
participants' benchmarks will be lower. MedPAC recommended that CMS
ultimately transition to national benchmarks to exert pressure on high-
cost regions to bring their spending in line with spending in other
markets. Another commenter seemed to suggest that applying nationally-
based benchmarks would help in addressing their concern with disparate
device costs depending on whether a participant was in a rural or
metropolitan area. In their view, participants in rural areas would be
disadvantaged by higher costs for these items.
Response: We agree with MedPAC on the benefits of national prices
as well as their view that national prices should ultimately be adopted
if the EPMs were fully integrated into Medicare on a national basis. We
also continue to believe that our proposal to phase-in regional pricing
from participant-specific prices offers the most appropriate balance of
incentives and protections for purposes of testing the proposed EPMs.
In particular, we are concerned that immediately moving toward national
pricing could impede the chances for success among participants in high
cost regions. As a result, we are reluctant to adopt national pricing
at this time. We also do not agree with the suggestion that moving
toward national pricing would benefit participants in rural areas with
respect to device costs. This is because financial performance,
including spending on devices, during the performance years would be
generally compared to a participant's historical costs or to the
historical costs of providers in their region. In either case, the
costs for
[[Page 317]]
devices should be relatively more comparable than if comparisons were
made to a national measure.
Final Decision: After consideration of the public comments
received, we are finalizing the proposal, without modification, to
blend payments when establishing participants' benchmark and quality-
adjusted targets. We would note that our final policy would also
include Sec. 512.300(c)(5) in conjunction with Sec. 512.300(c)(2),
(3), and (4). Thus, the final policy for blending payments when
establishing benchmark and quality-adjusted targets is included in
Sec. 512.300(c)(2), (3), (4), and (5).
(7) Define Regions as U.S. Census Divisions
As we did for the CJR model (80 FR 73349 through 73350), for all 5
performance years, we defined ''region'' as one of the nine U.S. Census
divisions \84\ in Figure 1 (81 FR 50857).
---------------------------------------------------------------------------
\84\ There are four census regions--Northeast, Midwest, South,
and West. Each of the four census regions is divided into two or
more ``census divisions''. Source: https://www.census.gov/geo/reference/gtc/gtc_census_divreg.html. Accessed on April 15, 2015.
\85\ https://www.eia.gov/consumption/commercial/census_maps.cfm.
[GRAPHIC] [TIFF OMITTED] TR03JA17.000
We believe U.S. Census divisions provide the most appropriate
balance between very large areas with highly disparate utilization
patterns and very small areas that would be subject to price
distortions due to low volume or participant-specific utilization
patterns. Our proposed rule also clarified that we would ascribe the
same regional component of EPM-episode benchmark prices for EPM
participants in MSAs that span U.S. Census divisions. That is, selected
MSAs that span U.S. Census divisions would be attributed to one U.S.
Census division for purposes of calculating the regional component of
an EPM-episode benchmark price. Specifically, we would attribute an MSA
to the U.S. Census division in which the majority of people in the MSA
reside.
The proposal to define a region as one of the nine U.S. Census
divisions was included in Sec. 512.300(c)(2). We sought comment on our
proposal to define region in this manner.
The following is a summary of the comments received and our
responses.
Comment: Many of the commenters on the proposed regional definition
expressed concerns about the proposal to blend participant-specific and
regional pricing. In general, the commenters expressed concerns that,
given the size and diversity of the proposed U.S. Census divisions with
respect to health conditions and costs, a single regional price would
potentially not be an accurate measure of a participant's costs. As a
result, those participants that treated sicker patients would be
penalized in particularly large and diverse regions. Thus, many of
these commenters requested that CMS set prices based on a narrower and
more cohesive geographic area, for example, at the MSA level, IPPS wage
index level, or based on MAC regions. A commenter recommended that CMS
not base benchmark prices fully on a regional average but consider
taking into account a participant's relative mix of patients with
respect to CCs and MCCs.
Another commenter suggested that while some financial risk is
captured based on CMS-HCC scores, the best way to remove unintended
consequence is by comparing participants with similar patient
populations, instead of using Census Divisions to calculate target
prices. In their view, using Census Divisions to set target prices
penalizes high acuity hospitals for existing in the same multi[hyphen]
state ``region'' as lower[hyphen]acuity hospitals, even if those
hospitals are more capable at caring for sicker patients. As such, many
hospitals are funneled the most complex AMI, CABG, or fracture cases,
which may increase average costs in a way that is consistent with
providing the highest[hyphen]quality care. As such, this commenter
recommended that CMS instead compare hospitals against other hospitals
with similar patient populations for the purpose of calculating target
prices. As high[hyphen]acuity
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referral centers are most at[hyphen]risk given that they treat the most
ill patients in the nation for all of the proposed EPMs, the commenter
recommended that CMS group together such high[hyphen]acuity referral
centers and treat them as their own ``Peer group'' cohort rather than
by region or within each region for the purpose of calculating target
price. This would ensure that locations systematically treating the
most complex cases are being compared appropriately. Another commenter
suggested this concept be expanded more broadly so that peer groups
might be formed around characteristics such as urban teaching
hospitals, suburban hospitals, or small rural hospitals.
Response: We appreciate the comments and concerns raised on our
proposal to base regional pricing on U.S. Census Divisions as well as
the suggested alternatives. Our proposal intended to balance our goal
of identifying relatively cohesive, homogeneous, and meaningful groups
for purposes of establishing benchmark prices with what was
administratively feasible. While we appreciate the suggested
alternatives that were offered and could consider them for future
models, we continue to believe, as we stated in the CJR Final Rule (80
FR 73350), that U.S. Census Divisions provide the most appropriate
balance between very large areas with highly disparate utilization
patterns and very small areas that would be subject to price
distortions due to low volume or hospital specific utilization
patterns. We would also note that as discussed earlier in section
III.D.4.b.(2), we will be exploring additional methods for further
risk-adjusting episodes under the models that we intend to make
effective by PY3. We believe that these additional adjustments will
make comparisons of financial performance among participants more
comparable regardless of a region's diversity.
Final Decision: After consideration of the public comments
received, we are finalizing the proposal, without modification, to
define a region as one of the nine U.S. Census divisions. Our final
policy for defining regions is included in Sec. 512.300(c)(2).
(8) Normalize for Provider-Specific Wage Adjustment Variations
Some variation in historical EPM-episode payments across hospitals
in a region may be due to wage adjustment differences in Medicare
payments. In setting Medicare payment rates, Medicare typically adjusts
facilities' costs attributable to wages and wage-related costs (as
estimated by the Secretary from time to time) by a factor (established
by the Secretary) that reflects the relative wage level in the
geographic area of the facility or practitioner (or the beneficiary's
residence, in the case of home health and hospice services) compared to
a national average wage level. Such adjustments are essential for
setting accurate payments, as wage levels vary significantly across
geographic areas of the country. However, having the wage level for one
hospital influence the regional-component of another hospital's EPM
episode-benchmark price with a different level would introduce
unintended pricing distortion not based on utilization pattern
differences.
To preserve how wage levels affect provider payment amounts, while
minimizing the distortions introduced when calculating the regional-
component of blended EPM-episode benchmark prices, we proposed to
normalize for wage indices at the claim level for both historical EPM-
episode payments and actual EPM-episode payments (81 FR 50858). As
discussed in section III.D.3.b. of the proposed rule (81 FR 50845
through 50846), we utilize the CMS Price (Payment) Standardization
Detailed Methodology to calculate EPM-episode benchmark and quality-
adjusted target prices and actual EPM-episode spending. This
methodology removes wage level differences in calculating standardized
payment amounts.
We believe it is important to reintroduce wage index variations
near the end of the EPM-episode price-setting methodology and when
calculating actual EPM-episode payments during an EPM performance year,
to account for the differences in cost for care redesign across
different geographic areas of the country. For example, hiring
additional hospital staff to aid in patient follow-up during the post-
discharge period of an AMI model episode would be significantly more
costly in San Francisco than in rural Idaho. If we do not reintroduce
wage index variations into EPM-episode benchmark price and actual EPM-
episode payment calculations, we would calculate reconciliation and
repayment amounts that would not capture labor cost variation
throughout the country, and EPM participants in certain regions may see
less opportunity and financial incentive to invest in care redesign.
Thus, when setting EPM-episode benchmark prices and calculating actual
EPM-episode payments, we proposed to reintroduce the participant-
specific wage variations by multiplying EPM-episode payments by the
wage normalization factor when calculating the EPM-episode benchmark
prices and actual EPM-episode payments for each EPM participant, as
described in section III.D.4.c. of the proposed rule.
We proposed to use the following algorithm to create a wage
normalization factor: 0.7 * IPPS wage index + 0.3. The 0.7 approximates
the labor share in IPPS, IRF PPS, SNF, and HHA Medicare payments. The
specific order of steps, and how this step fits in with others, is
discussed further in section III.D.4.c. through III.D.4.e. of the
proposed rule (81 FR 50862 through 50864). We also referred to the CJR
model Final Rule for more detailed information on our normalization
process adopted for the CJR model (80 FR 73350 through 73352).
The proposal to normalize for provider-specific wage adjustment
variations was included in Sec. 512.300(c)(12). We sought comment on
our proposal to normalize for these variations.
We received no specific comments on our proposal to normalize for
provider-specific wage adjustment variations other than one in support
of the proposal.
Final Decision: We are finalizing the proposal, without
modification, to normalize for provider-specific wage adjustment
variations. Our final policy for normalizing provider-specific wage
adjustment variations is included in Sec. 512.300(c)(12).
(9) Combining Episodes to Set Stable Benchmark and Quality-Adjusted
Target Prices
For the purposes of having sufficient episode volume to set stable
EPM-episode benchmark and quality-adjusted target prices, we proposed
generally to follow the process from the CJR model (80 FR 73352 and
73353) to calculate severity factors, EPM participant-specific weights,
and region-specific weights that allow us to surmount issues of low
volume for EPM episodes with particular characteristics by aggregating
EPM episodes and portions of EPM episodes across dimensions that
include anchor MS-DRGs, the presence of AMI ICD-CM diagnosis code on
the anchor inpatient claim, and the presence of a major complication or
comorbidity for anchor CABG MS-DRGs (81 FR 50858 through 50861). Where
the CJR Final Rule referred to anchor factors, however, for the
purposes of the proposed rule, we referred to severity factors to avoid
confusion when performing calculations pertaining to expenditures that
occurred during the anchor hospitalization and after the anchor
hospitalization in CABG model episodes.
[[Page 319]]
For SHFFT model episodes, we proposed to combine episodes with
price MS-DRGs 480-482 to use a greater historical episode volume to set
more stable SHFFT episode benchmark and quality-adjusted target prices.
To do so, we proposed to calculate severity factors for episodes with
price MS-DRGs 480 and 481 equal to--
[GRAPHIC] [TIFF OMITTED] TR03JA17.001
The national average would be based on SHFFT model episodes attributed
to any IPPS hospital. The resulting severity factors would be the same
for all SHFFT model participants. For each SHFFT model participant, a
hospital weight would be calculated using the following formula, where
SHFFT model episode counts are SHFFT-model-participant hospital-
specific and based on the SHFFT model episodes in the 3 historical
years used in SHFFT model episode benchmark and quality-adjusted target
price calculations:
[GRAPHIC] [TIFF OMITTED] TR03JA17.002
A SHFFT model participant's specific average episode payment would
be calculated by multiplying such participant's weight by its combined
historical average episode payment (sum of historical episode payments
for historical episodes with price MS-DRGs 480-482 divided by the
number of historical episodes with price MS-DRGs 480-482). The
calculation of the participant weights and the participant-specific
pooled historical average episode payments would be comparable to how
case-mix indices are used to generate case-mix adjusted Medicare
payments. The participant weight essentially would count each episode
with price MS-DRGs 480 and 481 as more than one episode (assuming
episodes with price MS- DRGs 480 and 481 have higher average payments
than episodes with price MS-DRG 482) so that the pooled historical
average episode payment, and subsequently the SHFFT model episode
benchmark and quality-adjusted target prices, are not skewed by the
SHFFT model participant's relative breakdown of historical episodes
with price MS-DRGs 480 and 481 versus historical episodes with price
MS-DRG 482.
We would calculate region-specific weights and region-specific
pooled historical average payments following the same steps as for
hospital-specific weights and hospital-specific pooled average
payments. Instead of grouping episodes by the attributed hospital as
for hospital-specific calculations, region-specific calculations would
group together SHFFT model episodes that were attributed to any IPPS
hospital located within the region. The participant-specific and
region-specific pooled historical average payments would be blended
together as discussed in section III.D.4.b.(6) of the proposed rule.
The specific order of steps, and how this step fits in with others, is
discussed further in section III.D.4.c. of the proposed rule.
Afterwards, the blended pooled calculations would be ``unpooled''
by setting the episode benchmark price for episodes with price MS-DRG
482 to the resulting calculation, and by multiplying the resulting
calculation by the severity factors to produce the episode benchmark
prices for episodes with price MS-DRGs 480 and 481. Applying the
discount factor as discussed in III.D.4.b.(10) and III.D.4.c. of the
proposed rule would result in the SHFFT model quality-adjusted target
prices for episodes with price MS-DRGs 480-482.
For episodes in the AMI model with price MS-DRGs in 280-282 or 246-
251 and without readmissions for CABG MS-DRGs, we proposed to follow an
analogous procedure to the SHFFT model with the following
modifications. First we proposed to group episodes with price MS-DRGs
280-282 separately from episodes with price MS-DRGs 246-251 for the
calculations. Second, we proposed to calculate severity factors for
episodes with price MS-DRGs 280-282 as--
[GRAPHIC] [TIFF OMITTED] TR03JA17.003
Third, we proposed to calculate hospital-specific weights and
region-specific weights for episodes with price MS-DRGs 280-282 as--
[[Page 320]]
[GRAPHIC] [TIFF OMITTED] TR03JA17.004
Fourth, we proposed to calculate severity factors for episodes with
price MS-DRG 246-251 as--
[GRAPHIC] [TIFF OMITTED] TR03JA17.005
Fifth, we proposed to calculate hospital-specific weights and
region-specific weights for episodes with price MS-DRG 246-251 as--
[GRAPHIC] [TIFF OMITTED] TR03JA17.006
After blending historical and regional pooled episode payments for
episodes with price MS-DRGs 280-282, the blended pooled calculations
would be ``unpooled'' by setting the episode benchmark price for price
MS-DRG 282 to the resulting calculation, and by multiplying the
resulting calculation by the severity factors to produce the episode
benchmark prices for price MS-DRGs 280 and 281.
After blending historical and regional pooled episode payments for
episodes with price MS-DRGs 246-251, the blended pooled calculations
would be ``unpooled'' by setting the episode benchmark price for price
MS-DRG to the resulting calculation, and by multiplying the resulting
calculation by the severity factors to produce the episode benchmark
prices for price MS-DRGs 246-251.
Applying the discount factor as discussed in III.D.4.b.(10) and
III.D.4.c of the proposed rule would result in the quality-adjusted
target prices for price MS-DRGs 280-282 and 246-251.
For episodes in the CABG model with price MS-DRGs in 231-236, we
proposed to calculate severity factors, hospital-specific weights, and
region-specific weights separately for the anchor hospitalization
portion of CABG model episodes and the post-anchor hospitalization
portion of CABG model episodes.
For the anchor hospitalization portion of CABG model episodes, we
proposed to follow an analogous procedure to the SHFFT model with the
anchor hospitalization portion of CABG model episodes grouped by the
price MS-DRG. Specifically, we proposed to calculate anchor
hospitalization severity factors for price MS-DRGs 231-235 as--
[[Page 321]]
[GRAPHIC] [TIFF OMITTED] TR03JA17.007
We also proposed to calculate participant-specific weights and
region-specific weights for the anchor hospitalization portion of CABG
model episodes as--
[GRAPHIC] [TIFF OMITTED] TR03JA17.008
After blending historical and regional pooled anchor
hospitalization payments for the CABG model episodes, the blended
pooled calculations would be ``unpooled'' by setting the price MS-DRG
236 anchor hospitalization benchmark price to the resulting
calculation, and by multiplying the resulting calculation by the
severity factors to produce the anchor hospitalization benchmark prices
for price MS-DRGs 231-235.
For the post-anchor hospitalization portion of CABG model episodes,
we proposed to follow an analogous procedure to the SHFFT model with
the post-anchor hospitalization portion of CABG model episodes grouped
in the following manner--
With AMI diagnosis on the anchor inpatient claim and price
MS-DRG with major complication or comorbidity (231, 233, or 235)
With AMI diagnosis on the anchor inpatient claim and price
MS-DRG without major complication or comorbidity (232, 234, or 236)
Without AMI diagnosis on the anchor inpatient claim and
price MS-DRG with major complication or comorbidity (231, 233, or 235)
Without AMI diagnosis on the anchor inpatient claim and
price MS-DRG without major complication or comorbidity (232, 234, or
236)
Specifically, we proposed to calculate post-anchor hospitalization
severity factors as--
[[Page 322]]
[GRAPHIC] [TIFF OMITTED] TR03JA17.009
We also proposed to calculate hospital-specific weights and region-
specific weights for the post-anchor hospitalization portion of CABG
model episodes as--
[GRAPHIC] [TIFF OMITTED] TR03JA17.010
After blending historical and regional pooled post-anchor
hospitalization payments for the CABG model episodes, the blended
pooled calculations would be ``unpooled'' by setting the without AMI
ICD-CM diagnosis code on the anchor inpatient claim and price MS-DRG
without major complication or comorbidity (232, 234, or 236) post-
anchor hospitalization benchmark price to the resulting calculation,
and by multiplying the resulting calculation by the severity factors to
produce the post-anchor hospitalization benchmark prices for:
With AMI diagnosis on the anchor inpatient claim and price
MS-DRG with major complication or comorbidity (231, 233, or 235)
With AMI diagnosis on the anchor inpatient claim and price
MS-DRG without major complication or comorbidity (232, 234, or 236)
Without AMI diagnosis on the anchor inpatient claim and
price MS-DRG with major complication or comorbidity (231, 233, or 235)
We proposed to calculate episode benchmark prices for CABG model
episodes by summing combinations of CABG anchor hospitalization
benchmark prices and CABG post-anchor hospitalization benchmark prices.
Applying the discount factor as discussed in III.D.4.b.(10) and
III.D.4.d of the proposed rule would result in the quality-adjusted
target prices for CABG model episodes.
For episodes in the AMI model with CABG readmissions, we proposed
to perform no additional blending of participant-specific and regional-
specific episode payments. We proposed to calculate the AMI model
episode benchmark and quality-adjusted target prices for such episodes
as described in section III.D.4.e. of the proposed rule.
The proposals to combine episodes to set stable benchmark and
quality-adjusted target prices were included in Sec. 512.300(c)(13).
We sought comment on our proposals for combining episodes for these
purposes.
We received no comments on our proposals for combining episodes.
Final Decision: We are finalizing the proposal, without
modification, to combine prices for episodes. Our final policy for
combining episodes is included in Sec. 512.300(c)(13). We would note
that since we did not finalize our proposal for price MS-DRGs, the term
price MS-DRG is excluded and replaced with the term anchor MS-DRG.
(10) Effective Discount Factor
As discussed in section III.D.2.c. of the proposed rule, we
proposed to make EPM participants partly or fully accountable for EPM-
episode payments in relationship to the EPM quality-adjusted target
price (81 FR 50844). As part of this, in setting an episode quality-
adjusted target price for an EPM participant, we proposed to apply an
effective discount factor to an EPM participant's participant-specific
and regional blended historical EPM-episode payments for a performance
period. We expect EPM participants to have a significant opportunity to
improve the quality and efficiency of care furnished during episodes in
comparison with historical practice, because the EPMs would facilitate
the alignment of financial incentives among providers caring for EPM
beneficiaries. Our proposed effective discount factors were intended to
serve as Medicare's portion of reduced expenditures from an EPM episode
with any EPM-episode expenditures below the quality-adjusted target
price potentially available as reconciliation payments to the EPM
participant where the anchor hospitalization occurred.
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For the EPMs, we proposed to establish a 3 percent effective
discount factor to calculate the quality-adjusted target prices for EPM
participants in the below acceptable and acceptable quality categories,
as discussed in section III.E.3.f. of the proposed rule (81 FR 50887
through 50893) and similar to the CJR model (80 FR 73355). The
effective discount factor to calculate the quality-adjusted target
price for EPM participants in the good and excellent quality categories
would be 2 percent and 1.5 percent, respectively.
As discussed in section III.D.2.c. of the proposed rule (81 FR
50844), because of the proposed phase-in of repayment responsibility
with no responsibility in either performance year 1 or performance year
2 (NDR) and only partial repayment responsibility in performance year 2
(DR) and all of performance year 3, an EPM participant with actual EPM-
episode payments that exceeded the quality-adjusted target prices
multiplied by the EPM participant's number of EPM episodes to which
each quality-adjusted target price would apply in performance year 2
(DR) and performance year 3 would owe Medicare less than would
otherwise result from this calculation.
Also, as discussed in section III.E.3.f of the proposed rule (81 FR
50801), we proposed to apply an ``applicable discount factor'' to
repayment amounts in performance years 2 and 3 while this repayment
responsibility was being phased-in. We refer to section III.E.1. and
specifically Tables 20 through 28 in our proposed rule for further
illustration of the discount percentages that would apply for
reconciliation payment and Medicare repayment over the 5 EPM
performance years (81 FR 50888 through 50892). We believe this
methodology offers EPM participants an opportunity to create savings
for themselves and Medicare, while also maintaining or improving
quality of care for EPM model beneficiaries.
The proposal to establish discount factors that would apply to the
quality categories was included in Sec. 512.300(d). We sought comment
on our proposal to establish discount factors that apply to the quality
categories.
The following is a summary of the comments received and our
responses.
Comment: Most commenters suggested that the ability to achieve
savings under the proposed models (most notably for the cardiac models
and the CABG model in particular) was more limited than for the CJR
model, and that these limitations would become more significant as
target prices decline further over time. For example, commenters opined
that while about half of CJR episode spending is attributable to the
initial hospitalization, CMS noted that about three-quarters of CABG
episode spending is attributable to the initial hospitalization. As
such, there are fewer opportunities to achieve efficiencies within the
inpatient hospital payment amount because it is a predetermined per-
discharge payment based primarily on the patient's condition, not on
services provided. Further, some portion of CABG and AMI costs outside
the initial hospitalization is attributable to readmissions; however,
these costs are already declining due to hospitals' responses to the
HRRP and any remaining readmissions are more likely to be clinically
appropriate and necessary. As such, it would be difficult to achieve
efficiencies within the remaining percentage of spending that occurs
outside the initial hospitalization. Thus, commenters requested that
CMS implement a smaller discount factor than what was proposed--
typically a 1 percentage point reduction.
Response: We appreciate the comments and concerns raised with
respect to our proposed discount factor. We recognize that, as compared
to episodes under the CJR model, opportunities to achieve improved
efficiencies under the proposed models would be different and
potentially more challenging for participants under the proposed
models. However, we do not believe the increased efficiencies needed to
be successful as was proposed under the models are unattainable. Given
our policy to phase-in full regional pricing over time, participants'
performance will increasingly be compared to that of peers within their
region; thus, for the more efficient participants, target pricing would
likely be higher than if we relied on participant-specific pricing
alone. Further, as discussed in section III.D.4.b.(2), we plan to
explore and implement additional adjustments for risk beginning in PY3,
which should facilitate successful participants' ability to achieve
savings under the models. We would also note that our final policy to
include reconciliation payments when updating target prices for
successful participants under the models should ease the decline in
pricing over time, which should facilitate their ability to be rewarded
for improved efficiencies.
Comment: A commenter encouraged CMS to provide participants with
protection against having to make repayments that result from adverse
events beyond their control, similar to the protections offered under
the Medicare Shared Savings Program. Specifically, during risk-bearing
periods of the program, instead of setting a repayment target price
equal to historical payments minus some percentage, the commenters
recommended that CMS should instead set a symmetric target price equal
to historical payments plus or minus some percentage. Under this
proposal, participants with historical payments falling between, for
example, 97 percent and 103 percent of historical payments would
neither receive reconciliation payments nor be held responsible for
repaying Medicare.
Response: We appreciate the suggested alternative the commenter
offered, but would note that the proposed models are intended to test a
bundled payment rather than a shared savings model, which is being
tested through Innovation Center and Shared Savings Program ACO
efforts.
Final Decision: After consideration of the public comments
received, we are finalizing the proposal, with modification, to
establish discount factors that would apply to the quality categories.
Specifically, for repayment amounts in performance year 2, our final
applicable discount factor would apply only to participants that
elected downside risk in that year. Also, in conformance with our final
policy for phasing-in repayment responsibility, the applicable discount
factor is extended so that it will apply to all EPM participants in
performance year 4. Our final policy for the discount factor is
included in Sec. 512.300(d).
c. Approach To Combine Pricing Features for All SHFFT Model Episodes
and AMI Model Episodes Without CABG Readmissions
The following presents our proposed methodology for combining the
pricing features presented in section III.D.4.b. of the proposed rule
with respect to SHFFT model episodes and AMI model episodes without a
CABG readmission (81 FR 50862 and 50863).
Step 1--Calculate historical EPM-episode payments for
episodes that were initiated during the 3-historical-years of each
applicable EPM (that is, individually for each of the SHFFT and AMI
models) (section III.D.4.b.(3) of the proposed rule) for all IPPS
hospitals for all Medicare Part A and B services included in the EPM
episodes. Limit the potential AMI model episodes to those episodes with
price MS-DRGs in 280-282 or 246-251 and without readmissions for CABG
MS-DRGs. We note that specific PBPM payments may be excluded from
historical EPM-episode payment calculations as
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discussed in section III.D.6.d. of the proposed rule.