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November 17, 2015

AAOS on CMS Bundled Payment Final Rule

Washington, DC—Yesterday, the Centers for Medicare and Medicaid Services (CMS) released a rule finalizing the plan announced in July to bundle payment and quality measures for hip and knee replacements at hospitals in 67 – down from 75 – randomly selected geographic areas. AAOS commends CMS’ efforts to address stakeholder concerns while implementing this unique model. Specifically, the revised composite quality score methodology and more gradual transition to downside risk are positive steps. However, AAOS raised a number of issues to CMS in previous comments on the proposed rule that still need to be addressed, including the absence of risk-adjustment in the program and a lack of designated physician leadership for episodes-of-care.

Importantly, while a delayed implementation date adds some flexibility to the payment program, an additional three months does not fully address the concern that physicians in the United States continue to require better analytics and support, tools for best practices and ease of reporting, validated patient risk assessment measures, and data sharing with physicians through required transparency by hospitals and payers. While CMS has made progress in some of these areas, it needs to further strengthen the support and infrastructure for physicians and facilities before adding programs that require significant investment and development. AAOS recommended CMS postpone the mandatory implementation feature of the program until at least 85 percent of providers have attained meaningful use or another metric of infrastructure readiness. 

“The AAOS supports efforts by CMS to make appropriately structured alternative payment models available to physicians and other providers,” stated David D. Teuscher, MD, President of AAOS. “But we are very concerned about serious unintended consequences for Medicare beneficiaries and physicians. We have submitted a number of suggestions to CMS that would improve the program to ensure the highest quality of care for those patients and are closely reviewing the final rule to determine which of these suggestions were taken up. AAOS members have been leaders in developing, implementing, and evaluating episode of care payments, and we look forward to working closely with CMS on further refining the program and to improving the care of all musculoskeletal patients in the United States.”

For further information:

Follow the AAOS Office of Government Relations on Twitter: @AAOSAdvocacy
Elizabeth Fassbender
Communications Manager
AAOS Office of Government Relations
(202) 548-4143
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