CJR – The Northbound Train – Delayed Departure?

Prior to the September 8th deadline, CMS received in excess of 300 written comments on the Notice of Proposed Rule Making (NPRM) regarding CMS-5516-P Medicare Program; Comprehensive Care for Joint Replacement Payment Model for Acute Care Hospitals Furnishing Lower Extremity Joint Replacement Services, published in the Federal Register on July 14, 2015.
The proposed rule (CJR) would create a new mandatory Medicare Part A and B payment model under section 1115A of the Social Security Act in which acute care hospitals in specified geographic areas would receive a retrospective bundled payments for a 90 day episode of care for hip or knee joint replacement/reattachment.

While comments ranged the gamut, essential policies and uncertainty surrounding operational issues are major areas of concern for constituents in implementing the program by January 1, 2016.  Legal waivers have yet to be clarified, codes for payment waivers have yet to be developed as well as the data request process, et al.  Many urged CMS to delay the start date of the mandatory CJR until at least October 1, 2016, providing all stakeholders sufficient time to prepare, including CMS.

Current prevailing consensus seems to indicate the CJR Model will be delayed until October 1, 2016.  However, with Health and Human Services first benchmark of 30% of fee-for-service via alternative payment models by 2016, CMS could delay only the mandatory nature of the program until October 1, 2016 and make the CJR program available to ready-and-willing participant hospitals in the defined areas as proposed.

The train remains northbound!

Written by Richard S. Morgan on Linkedin