It also noted that the CCJR isn't the only mandatory bundle pay initiative. The Home Health Value-Based Purchasing model outlined in the 2016 Home Health Prospective Payment System Final Rule will be mandatory for home health agencies starting Jan. 1, 2016.
Most organizations submitting comments on the proposed regulations asked the agency to wait until Jan. 1, 2017, to implement it.
The Mayo Clinic, for instance, argued that it needs more time to fully understand and implement the requirements and educate its staff and patients.
The CMS did postpone the program but pushed it back just three months, to April 1, 2016, saying that should give hospitals enough time to prepare.
The American Hospital Association said in a statement that it appreciates the delay but remains “concerned that hospitals will still be pressed to put in place the processes and procedures necessary for the program.”
The agency also said it would issue a notice along with HHS' Office of Inspector General
https://www.cms.gov/Medicare/Fraud-and-Abuse/PhysicianSelfReferral/Downloads/2015-CJR-Model-Waivers.pdf">granting participants leeway under the federal kickback and physician self-referral law (PDF), known as the Stark law. Similar waivers were extended to accountable care organizations participating in the Medicare Shared Savings Program.
Providers argue the fraud and abuse laws would make it legally complicated for them to enter into the necessary coordinated-care agreements with one another. The laws generally prohibit physicians from making referrals for services covered by government programs to entities in which they have financial interests unless they meet certain exceptions.
In 2014, approximately 430,000 Medicare beneficiaries had discharges for lower-extremity joint replacements, costing Medicare more than $7 billion for the hospitalizations alone.
The CMS estimates that the new bundled-payment test will cover about 23% of the hip and knee replacements that Medicare pays for, which is down from 25% in the proposed rule.
The program would put about $1.2 billion in Medicare spending in the new bundles in 2016, and that figure would grow to $2.9 billion in episode spending in 2020.