CMS Delays Cardiac Bundled Payment Model
The Centers for Medicare and Medicaid Services announced on March 21st in the Federal Register the...
CMS announced on December 20th that they are moving forward with the mandatory Medicare cardiac bundled pricing model by issuing final regulations.
While CMS proceeds, there is serious conjecture that President-Elect Trump’s choice for HHS Director, Rep. Tom Price (R-GA), will, if confirmed, cancel the project.
While CMS is officially defending the model and its implementation in July 2017, Dr. Price has publicly criticized the mandatory model as going too far, too fast and …”dramatically altering the delivery of care.”
While CFA is no more prescient than anyone else in the industry, not knowing with any certainty if the mandatory model will be implemented on schedule, made voluntary, scaled back or even cancelled, we do know that this situation should not lure hospitals into thinking they will not eventually be held accountable for building value into these (and other) targeted cardiac procedures. Financial accountability to Medicare for a bundled price may be in question; but clinical quality outcomes and process of care accountability is not contingent on model implementation and never will be.
First, all affected parties should look over the final regulations as published online on December 20. A prepublication copy is available at https://federalregister.gov/d/2016-30746 and on FDsys.gov. The regs are scheduled for official publication in the Federal Register on January 3, 2017. The final regulations reflect the provisional regulations published in July except for a few small changes made to reflect healthcare industry concerns. These include:
CMS has stated that they estimate that 1,120 hospitals in 98 randomly selected MSA’s will participate in the cardiac model. That is a lot of hospitals and potentially a significant impact.
CFA firmly believes that hospital cardiac programs need to prepare for bundled pricing assuming that Medicare will implement the new model on schedule and as stipulated in the final regulations. We feel that this hospital commitment to a process and an outcome that may not actually come to pass as a Medicare model is nonetheless justifiable based on the value of the work necessary to address the underlying financial, quality outcome, process improvement, cost reduction and care coordination issues that currently exist in every hospital. We have proposed a methodology and approach to the model (refer to the Diagnostic Angiography and Interventional Cardiology article ) that can get you started. Unless and until the model is officially implemented, the hospital financial responsibility for ninety-day post-acute care for these patients will not be an issue except from an overall care coordination perspective.
While addressing the underlying issues associated with all types of cardiac patients is appropriate and necessary, prioritizing patient groups is appropriate when beginning to address quality outcomes, process improvement, cost reduction and care coordination issues. Of the two categories of potentially impacted patients, CABG surgery and AMI, we offer the following prioritized approach if the hospital is starting from a position of relative inexperience:
Hospital cardiac program preparation for value-based purchasing needs to be an ongoing and continuous endeavor. To the extent that the Medicare cardiac bundle becomes reality, this factor alone should spur on all hospitals to plan for and initiate performance improvement activities to address foundational financial, quality outcome, process improvement, cost reduction and care coordination issues associated with all patient populations, but particularly the two groups singled out by Medicare – CABG surgery and AMI. If the Medicare model is implemented, changed, or cancelled, the challenge of addressing the evolving needs of these patients in an increasingly competitive and value-conscious market remains the same.
As always, CFA invites your comments, suggestions and questions. For additional information, including blog posts specific to bundled pricing and Medicare’s new cardiac bundle, please refer to the CFA Perspective Blog
The Centers for Medicare and Medicaid Services announced on March 21st in the Federal Register the...
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