30 Mar Task Force Comments on LAN Elective Joint Replacement White Paper
The Task Force continues to advocate for full transparency in all matters related to bundled payment programs, including the specific methodology and data for setting target prices and the way issues such as attribution are handled. We also believe that bundled payments can promote greater transparency for patients in the evaluation and selection of health care providers. Transparency, in general, will lead to shorter cycle times to refine program designs while also creating greater confidence in the technical aspects of any bundled payment program.
Our recommended refinements to the LAN’s Elective Joint Replacement (EJR) Model design include
1. Patient Population and Transparency in Episode Creation. Data is key to fostering consensus and reaching agreement on appropriate structures to manage bundled payment programs. We believe greater transparency will lead to shorter cycle times to refine program designs while also creating greater trust in the technical aspects of any bundled payment program.
2. The Importance of an Accountable Entity. We strongly support the sharing of risk among physicians, hospitals, and other health care providers. We believe that the “accountable entity” will be paramount in serving this function through the EJR model.
3. Engaging Hospital-based Physicians. We believe that any capable organization should be able to sponsor an accountable entity. We further believe that the clinical model for the EJR episode should acknowledge the importance of hospital-based physicians.
4. Patient-Focused Quality Metrics. The HCTTF supports the use of patient-reported outcome and functional status measures. However, we recommend that providers only be subject to performance in quality metrics that have been validated by sufficient data and accepted by institutions such as the National Quality Forum.
5. Seeking Fraud and Abuse Waivers to Enable Gainsharing. The BPCI Initiative has demonstrated the importance of gainsharing in the design of successful bundled payment programs. While gainsharing helps to align care delivery incentives through financial benefits, gainsharing is often viewed under federal policy as inappropriate remuneration that raises fraud and abuse concerns.
Read the letter for an in-depth review of the Task Force’s recommended refinements to the LAN’s EJR Model.
Letter submitted on March 28, 2016