Re: Comprehensive Care for Joint Replacement Payment Model for Acute Care
Hospitals Furnishing Lower Extremity Joint Replacement Services; Proposed Rule
[CMS-5516-P]
Dear Mr. Slavitt and Dr. Conway:
On behalf of the American Association of Neurological Surgeons (AANS) and the Congress of
Neurological Surgeons (CNS), representing over 4,000 neurosurgeons in the United States, we
appreciate the opportunity to comment on CMS’ newly proposed Comprehensive Care for Joint
Replacement (CCJR) payment model. The CCJR would establish bundled payments for total hip and
knee replacements, covering hospitalizations, professional fees, and all clinically related Medicare Part A
and B services for 90 days after discharge, including skilled nursing facility care, home care, and hospital
readmissions. At the end of each year, hospitals that spend less than the target price and achieve
threshold performance on three quality measures would receive a bonus payment, up to a specified cap.
Hospitals that spend more than the target payment would be responsible for repaying Medicare for the
difference, up to a specified cap. This five-year, mandatory program would be implemented in 75
metropolitan statistical areas (MSAs) with approximately 750 hospitals beginning January 1, 2016.
Although the CCJR would not directly impact our membership at this time, this pilot could set the
foundation for future bundled payment models that target other procedures that are relevant to our
membership. Therefore, we appreciate the opportunity to express our overarching concerns with the
proposal and to highlight questions and other issues that we believe must be addressed before CMS
implements this particular model and potentially applies it to other procedures in the future.
The AANS and CNS recognize the positive impact that bundled payments may have on controlling
healthcare costs, but these benefits can only be realized if the model focuses on appropriate and
properly constructed episodes of care and is implemented in a manner that generates trust and buy-in
from all providers affected by the model.
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