LeadingAge Advocates for CMMI Models to Align Financial Incentives

Regulation | June 23, 2020 | by Nicole Fallon

In its comment letter on the CMS proposed rule to extend the Comprehensive Care for Joint Replacement(CJR) Model three years and further refine the model, LeadingAge highlighted the failings of current CMMI models to align financial incentives across all providers who contribute to the models’ success and advocated for testing of new models that would allow post-acute and long-term care providers to play a meaningful role and financially benefit from the success of these models.

The Feb 20 proposed rule, if finalized, will extend the CJR Model through December 31, 2023 for certain participating hospitals and proposes to expand the eligible procedures to include certain outpatient hip and knee replacement procedures. The CJR model is currently scheduled to end December 31, 2020. The rule also seeks to refine aspects of the model such as target pricing, risk adjustment, reconciliation process, and eliminating the current 50% cap on gainsharing with physicians and non-physician practitioners.

A separate interim final rule issued on March 13, extended the current performance year(PY5) for the CJR model by 3 months so it will end now on March 31, 2021 rather than the end of the 2020 calendar year. This step seeks to mitigate the financial impacts of COVID-19 on the CJR participants. CMS also changed the “extreme and uncontrollable circumstances policy” to extend it to episodes impacted by COVID-19. This allows participating CJR hospitals to benefit from the financial safeguards associated with that policy, including capping payments at the episode’s target price for admissions that fall within 30 days prior to the public health emergency period through its termination.