08 Sep Task Force Consensus Comments to CMS Regarding Proposed Comprehensive Care for Joint Replacement Program
The Task Force submits our consensus comments on the proposed Comprehensive Care for Joint Replacement (CCJR) program. Members of the HCTTF have over 3,000 episode initiators live in the Bundled Payments for Care Improvement (BPCI) program today. We believe bundled payments can promote high-quality, high-value care during Medicare beneficiaries’ episode of care and encourage coordination among providers. These outcomes can be achieved while ensuring access to care and freedom of choice for Medicare beneficiaries, regardless of the severity of their illnesses. Moreover, we applaud many of the design features in the CCJR model; our suggestions herein reflect a desire to refine this important initiative. The proposed rule outlines the framework for a program that could become very successful at reducing Medicare spending and improving patient care.
Task Force Response Summary
1. The CMS discount to the Target Price Should Vary Based on Non-DRG Costs. We encourage CMS to discount a hospital’s target episode price based on the fraction of post-acute care spending relative to total episode spending.
2. Re-Open the Discussion of Episode Definition and Methodology. We encourage the Secretary to appoint a Federal Advisory Committee of relevant stakeholders, including BPCI participants, consumers, patients and purchasers, to develop episode construction methodologies, quality metric and the sharing of episode risk informed by their experience in the BPCI initiative.
3. Reconcile Quarterly, with Optional Annual Reconciliation. We recommend quarterly reconciliations so that organizations producing savings can offset the expenses associated with managing 90-day episodes and to provide relatively fast feedback and rewards to program participants.
4. Provider Claims Data Prior to the Start of the Model. CMS should consider the benefits of making historical claims data available before the effective date of a bundled payment program.
5. Lower the Stop-Loss Level for Hospitals with Minimal Volume. We recommend offering a lower stop-less threshold for hospitals with less than 35 annual LEJR cases, to protect those low volume, typically smaller hospitals, from the consequences of random variation in outcomes.
6. Beneficiary Protections. The Task Force supports the beneficiary protections included in the Proposed Rule and the incentives provided for the collection of data to enable the further development of patient-reported outcomes measures.
7. Seek Fraud and Abuse Waivers to Enable Gainsharing. CMS should consider the benefits of making waivers available to hospitals mandated to participate in the CCJR model.
Letter submitted on September 8, 2015