Tuesday, March 21, 2017

HHS Delays New Mandatory Bundles

James Michel

The Department of Health and Human Services (HHS) this morning issued an interim final rule delaying the effective date of the final rule, "Advancing Care Coordination through Episode Payment Models (EPMs); Cardiac Rehabilitation Incentive Payment Model; and Changes to the Comprehensive Care for Joint Replacement Model."

The initial final rule, published on January 3, 2017, implements three new mandatory bundled payment models - coronary artery bypass graft (CABG); acute myocardial infarction (AMI); and surgical hip and femur fracture treatment (SHFFT) - in a variety of healthcare markets across the country. The effective date of the new mandatory EPMs originally was July 1, 2017. The interim final rule issued today delays the effective start-date of the three new EPMs for three months, to October 1, 2017. HHS is seeking comment on the appropriateness of the delay and is specifically requesting feedback on delaying the start-date even further to January 1, 2018. Other components of the original final rule are also delayed to October 1, including the cardiac rehabilitation incentive payment program and modifications to the Comprehensive Care for Joint Replacement (CJR) demonstration.

According to the rule, HHS is delaying the rule "to allow time for additional review, to ensure that the agency has adequate time to undertake notice and comment rulemaking to modify the policy if modifications are warranted, and to ensure that in such a case participants have a clear understanding of the governing rules and are not required to take needless compliance steps due to the rule taking effect for a short duration before any potential modifications are effectuated." The rule specifically references the "Regulatory Freeze Pending Review" executive memorandum signed by President Trump on January 20, 2017.

HHS Secretary Tom Price has previously stated his preference for delivery system and payment reform demonstrations that are voluntary as opposed to mandatory. This interim final rule signals that the agency is willing to reconsider its approach to broad, mandatory payment demonstrations.

Comments on the interim final rule will be due April 19th.  AHCA plans to submit comments. Please contact James Michel with any questions or comments on this rule or AHCA's response.

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