SUBJECT: Medicare Program; Cancellation of Advancing Care Coordination Through
Episode Payment and Cardiac Rehabilitation Incentive Payment Models;
Changes to Comprehensive Care for Joint Replacement Payment Model (CMS5524-P)
Dear Ms. Verma,
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’ proposal to cancel the Episode Payment Models (EPMs)
and Cardiac Rehabilitation (CR) incentive payment model, as well as revise certain aspects of the active
bundled payment model, Comprehensive Care for Joint Replacement (CJR).
Background
The CJR model, which is currently in its second performance year, is a mandatory bundled payment
program designed to pay providers a single payment for an episode of care for a hip or knee
replacement. The CJR regulations require that hospitals in 67 randomly selected metropolitan statistical
areas (MSAs). In general, participation in the CJR model runs until January 1, 2021.
The EPMs were designed around three clinical conditions for which CMS believes hospitals have a
significant opportunity to redesign care, improve quality and control costs:
- Acute Myocardial Infarction (AMI) Model;
- Coronary Artery Bypass Graft (CABG) Model; and
- Surgical Hip and Femur Fracture Treatment (SHFFT) Model.
…
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