CMS Again Delays Bundled Payment Models for Cardio and Ortho

CMS Again Delays Bundled Payment Models for Cardio and Ortho

For the second time, the Centers for Medicare and Medicaid Services (CMS) announced a delay in implementing bundled payment models. CMS’ Interim Final Rule[1] delays several Medicare payment models until Oct. 1, 2017. This rule has stakeholders wondering if there will be yet another delay beyond October or if bundled payments will take hold at all under the Trump administration.

Implications for Cardio and Ortho

An article in the National Law Review details specific implications of the Interim Final Rule:[2]

  • The delay of the effective dates of three new episodic payment models – each designed to test the propriety of episodic payments for certain cardiac and orthopedic conditions and procedures – until Oct. 1, 2017.
  • The delay of the effective date of the Cardiac Rehabilitation Incentive Payment Model – designed to encourage providers in 90 geographic areas to provide cardiac rehabilitation services via the implementation of a retrospective incentive payment program – until Oct. 1, 2017.
  • The delay of the effective date of amendments to the Comprehensive Care for Joint Replacement Model – designed to test the propriety of a bundled payment reimbursement methodology for an episode of care associated with hip and knee replacements – until Oct. 1, 2017.

Will Bundled Payments Eventually Be Voluntary?

Many stakeholders in cardiology and orthopedics favor voluntary, rather than mandatory, compliance with bundled payments. When CMS set the deadline as July 1, 2017, Tom Nickels, executive vice president for government relations and public policy for the American Hospital Association issued a press release expressing concerns that the payment models were “too much, too soon,” and added: “While it is important to test new payment models, hospitals should not be forced to participate in complicated new programs if the government has not already proven that they will benefit the patients we serve. We will continue to urge that any new bundled payment programs be of a voluntary nature.”[3]

Federation of American Hospitals (FAH) is also in favor of the delay. Chip Kahn, president and chief executive officer of FAH issued a statement saying, “We so appreciate Secretary Price’s decision to delay these bundled payment programs and welcome a fresh set of eyes on these policies. Taking the time to get the policy right is what is most important.”[4]

An article by Advisory Board, a best practices firm committed to assisting health care organization, states that Ashish Jha, a professor of health policy at the Harvard School of Public Health believes the “delays might suggest CMS will make the programs voluntary, which he said would affect the pool of participants and ultimately drive up costs.”[5]

Your Chance to Be Heard

CMS is accepting comments on the Interim Final Rule through April 19, 2017, 5 p.m. EST. If you wish to comment, CMS asks that you refer to file code CMS-5519-IFC. You may submit comments in one of four ways, and CMS requires you to choose only one:

  1. Electronically at Follow the ‘‘Submit a comment’’ instructions.
  2. Regular Mail
  3. Express or Overnight Mail
  4. Hand or Courier

Details about how to submit via mail, hand or courier can be found in the CMS rule. CMS will not accept fax transmissions.

[1] Government Publishing Office, “DEPARTMENT OF HEALTH AND HUMAN SERVICES Centers for Medicare & Medicaid Services 42 CFR Parts 510 and 512 [CMS–5519–IFC] 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; Delay of Effective Date,” Federal Register / Vol. 82, No. 53 / Tuesday, March 21, 2017 / Rules and Regulations, Mar. 21, 2017,

[2] Kenneth Yood, “CMS Delays Implementation of New Payment Models (Again),” National Law Review, Mar. 29, 2017,

[3]>Tom Nickels, “Statement on CMS’ New Bundled Payments for Cardiac Care and Hip Fractures Final Rule,” American Hospital Association, 2016

[4] Chip Kahn, “FAH Leader Reacts to Delay of Mandatory Bundles,” FAH Hospital Policy Blog, Mar. 20, 2017,

[5] “CMS delays start date for several new mandatory bundled payment models,” Mar. 21, 2017, Advisory Board,


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