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Hospitals Seek Delay with CMS Hip-Knee Replacement Test Program

By Kerry Young, CQ Roll Call

November 13, 2015 -- Hospital groups are asking Medicare officials to delay the start of a program that will hold some of them accountable for how well their elderly and disabled patients fare after hip and knee replacements.

Many hospital associations have expressed support in general for the aim of the Centers for Medicare and Medicaid Services' (CMS) so-called Comprehensive Care for Joint Replacement test model. The agency in July unveiled the draft rule for this program, which is designed to pay hospitals in about 75 U.S. regions more if their patients fare well after hip and knee replacements.

Hospital with poor results would have to return to Medicare a portion of the payment for these procedures.

CMS is expected to release the final version of this rule within days. The agency proposed beginning the test program on Jan. 1, 2016, and ending it Dec. 31, 2020.

The American Hospital Association asked CMS that the start date be pushed to July 1, 2016. The Greater New York Hospital Association asked for a delay to 2017. "If the delay can't be that long, CMS should at least wait until Oct. 1, 2016 to begin the program," wrote Kenneth E. Raske, president of the association, which represents more than 160 member hospitals and health systems in New York, New Jersey, Connecticut, and Rhode Island.

The stakes are high for many hospitals. Hip and knee replacements are some of the most common surgeries performed on people enrolled in Medicare. The program spent more than $7 billion for hospital care associated with these procedures in 2013, with more than 400,000 cases covered, according to CMS.

In his Sept. 8 letter to the agency, Raske of the Greater New York Hospital Association said that CMS had been expected to issue this hospital rule around Nov. 1.

With a mere 60-day notice, it would be impossible for hospitals to develop and implement a meaningful program, he said.

Raske pointed out that hospitals in his group had taken from six months to a year to prepare to participate in another major CMS test program, known as the Bundled Payments for Care Improvement initiative.

Other groups supporting a delay in implementation until at least October 2016 include the Association of American Medical Colleges, Michigan's Trinity Health, and the University of Pittsburgh Medical Center.

In the final rule, CMS also will address other issues raised in the comments about the program. Stryker, a leading maker of orthopedics, asked CMS to consider expanding participation in this program beyond hospitals to so-called conveners that can partner with hospitals. The Kalamazoo, Michigan-based firm said its experience in consulting with hospitals indicates it could help in the efforts to achieve savings through the new Comprehensive Care for Joint Replacement (CCJR) program. Stryker noted in a comment to CMS that it already is a partner in the Bundled Payments for Care Improvement initiative.

"Stryker believes there is ample evidence that conveners play a critical role in bundled payment initiatives, and they therefore should be encouraged to play an active role in the CCJR Model to ensure the success of the program," the company said.

If CMS doesn't broaden the rules of participation for the hip and knee replacement test, the agency should delay the start of this program until Oct. 1, 2016, which is also the start of Medicare's fiscal year 2017 payment period for hospitals," Stryker said. "This would provide hospitals the necessary time to analyze data, redesign care, and put in place proper agreements with partners such as Stryker to prepare for the new program," the company said.

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