CMS may have overcorrected in cancellation of cardiac models

The CMS may have overcorrected when it honored some hospitals' request to cancel mandatory cardiac pay models. The move means hospitals that were ready to embrace the models could be out millions of dollars. Those hospitals are also missing out on millions in bonus payments they would have received had they improved care.

The CMS wants to cancel models for acute myocardial infarction, coronary artery bypass and as well as the Cardiac Rehabilitation Incentive Payment Model, all of which were scheduled to begin on Jan. 1, 2018. Comments on the termination were due Oct. 16. The CMS announced plans to launch the initiatives last year to address one of Medicare's biggest cost drivers. The CMS pays approximately $11.7 billion annually for inpatient costs for Medicare beneficiaries with coronary heart disease. The models were to kick off in 98 regions around the country and more than 1,100 hospitals were expected to participate in the efforts. The CMS believed the models were not supported by hospitals. "Stakeholders have asked for more input on the design of these models. These changes make this possible and give the CMS maximum flexibility to test other episode-based models that will bring about innovation and provide better care for Medicare beneficiaries," CMS Administrator Seema Verma said in a statement. The agency said in its proposed rulemaking that since the models hadn't yet started, there wouldn't be much financial impact. But hospitals say that isn't true. For months, they've been training staff, updating IT systems, developing clinical protocols, hiring care managers and redesigning clinics. The Acute Myocardial Infarction model was especially hard to implement for providers because they had to develop strategies for both medical and procedural treatment of heart attack, according to Kristen Barlow, senior consultant, research at Advisory Board. "Given the extensive preparation many hospitals have conducted in anticipation of the program's launch, the CMS' assumption that the proposed cancellation will not have any cost to providers is incorrect," Dr. Janis Orlowski, chief healthcare officer at the Association of American Medical Colleges said in a comment letter. Hospitals can spend up to $1 million annually on just data vendor contracts to track the patients being treated under value based models, according to the AAMC. In addition, some are paying care coordinators as much as $81,000 a year. But hospitals won't just lose their investments they've made to launch the models, they'll lose out on bonus payments they could have earned under the experiments. Had providers performed well, the CMS expected to pay out more than $100 million in incentive payments. "We urge the CMS to expeditiously pursue the creation of new, voluntary advanced APMs that would allow hospitals to...capitalize on the work many of them already have done to prepare for such models," Tom Nickels, executive vice president of the American Hospital Association added in a comment letter. Dr. Richard Prager, president of the Society of Thoracic Surgeons echoed the request in his letter. He noted the cancellation of the models means that most cardiothoracic surgeons will not have a viable option if they want to earn the APM bonus payments under MACRA. The AAMC is suggesting the CMS swiftly establish the next iteration of the Bundled Payments for Care Improvement initiative which was supposed to be announced this year. The trade group believes the new iteration contains opportunities to participate in similar episodes that would have existed under the canceled EPMs. The CMS did consider altering the design of these models to allow for voluntary participation, but since that would potentially involve restructuring the models, payment methodologies, financial arrangement provisions and quality measures, it did not believe that such alterations would offer providers enough time to prepare for such changes, given the planned Jan. 1, 2018 start date, it said.