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Robert B. Vogel, MD, JD
Retinal Ophthalmologist at Piedmont Eye Center, Lynchburg VA;
Attorney, Overbey Hawkins & Wright, PLLS, Lynchburg, VA;
Adjunct Professor, Humanities and Bioethics, Liberty University School of Medicine, Lynchburg, VA.
Mandatory bundled payment programs for cardiac and orthopedic surgery have been postponed, according to CMS. The programs were finalized in late 2016 and scheduled for implementation on March 21.
CMS in March posted an interim rule in the Federal Register pushing the start date of the cardiac and orthopedic models back to October 1, 2017. CMS is seeking public comment regarding potential difficulties with implementation of these bundled payment models and comments regarding the delay. According to the interim rule, “[T]his additional 3-month delay is necessary to allow time for additional review, to ensure that the agency has adequate time to undertake notice and comment rulemaking to modify the policy if modifications are warranted, and to ensure that in such a case participants have a clear understanding of the governing rules and are not required to take needless compliance steps due to the rule taking effect for a short duration before any potential modifications are effectuated.”
This language seems to suggest that CMS is delaying the implementation of these specific programs, in part, to review whether the use of bundled payments arrangements is congruous with the new administration’s healthcare policies in general.
Bundled payments are part of Medicare’s effort to shift to encouraging quality of care from reimbursing for quantity of care. Bundled payments purportedly encourage coordination of care between hospitals, physicians, and other providers by paying a flat fee for certain medical services, incentivizing stakeholders to lower cost. There were three new payment models previously announced for heart attack patients and one new payment model for patients who undergo surgery for a hip fracture, other than hip replacement.