CJR Model Update: December 2017 Final Rule and Interim Final Rule with Comment

Transcription

1 Joint Replacement Model CJR Model Update: December 2017 Final Rule and Interim Final Rule with Comment Joint Replacement Model December 13, 2017 Presenters: Lisa Opdycke, MPP Sarah Mioduski, JD Audio available through device speakers OR by dialing (800) Conference Room:* # Access Code: #

2 Agenda Webinar Logistics Background December 1, 2017 Final Rule Summary - Mandatory & Voluntary Participation - Technical Refinements & Clarifications - Advanced Alternative Payment Model Extreme and Uncontrollable Circumstances Policy: Interim Final Rule with Comment Period Summary Changes to the CJR Model Effective January 1, 2018 Questions 2

3 Introduction to Adobe Connect To Enlarge the Presentation To Dial In Via Telephone Closed Captioning Download Available Resources To Ask Questions 3

4 Introduction to Adobe Connect (Cont.) Use the Q&A pod to submit any questions or comments Please if your question/comment is directed to a specific presenter Submit your question/comment by clicking the chat bubble icon 4

5 December 2017 Final Rule and Interim Final Rule with Comment Presentation Lisa Opdycke, MPP & Sarah Mioduski, JD CJR Model Team 5

6 Background On August 17, 2017 The Cancellation of Advancing Care Coordination Through Episode Payment and Cardiac Rehabilitation Incentive Payment Models; Changes to Joint Replacement Payment Model Proposed Rule was published in the Federal Register. The comment period for this rule closed on October 16, 2017 and we received 85 comments. On December 1, The Cancellation of Advancing Care Coordination Through Episode Payment and Cardiac Rehabilitation Incentive Payment Models; Changes to Joint Replacement Payment Model Final Rule and Interim Final Rule with comment was published in the Federal Register. The Interim Final Rule with Comment finalized and seeks comment on an extreme and uncontrollable circumstances policy to provide flexibility in the determination of episode costs for CJR participant hospitals located in areas impacted by extreme and uncontrollable circumstances, including specific hurricanes and wildfires during

7 Summary of Major Changes The December 1, 2017 final rule and interim final rule with comment: Cancelled the Episode Payment Models (EPMs AMI, CABG and SHFFT) and the Cardiac Rehabilitation (CR) incentive payment model. Established Voluntary participation for: - All eligible hospitals in 33 of the 67 Metropolitan Statistical Areas (MSAs) in CJR. - Low volume (hospitals with fewer than 20 episodes in the historical baseline period used to create the PY1 target prices) and rural hospitals in all MSAs. Established a one time participation election (opt-in period) for hospitals in voluntary MSAs as well as low-volume and rural hospitals. Finalized several technical refinements and clarifications for certain CJR model payment, reconciliation, and quality provisions. Finalized a change to the Affiliated Practitioner List criteria to broaden the CJR Advanced Alternative Payment Model (APM) track to additional eligible clinicians. 7

8 Participation Changes CJR will continue on a mandatory basis in 34 of the 67 current MSAs. These 34 mandatory areas are listed in Table 1 of the 12/1/17 rule. For low-volume and rural hospitals along with hospitals in the voluntary MSAs, a one-time participation election period for hospitals will be held from January 1, 2018 January 31, Opt-in will be necessary to continue participation in CJR for low-volume and rural hospitals in both mandatory and voluntary MSAs and for any hospital in the voluntary MSAs. - A list of hospitals that qualify as low-volume or rural can be found on the CJR webpage at - All PY3 episodes will be cancelled for hospitals that are eligible to elect continued CJR participation but choose not to do so. 8

9 Finalized Participation Requirements for Hospitals in the CJR Model Mandatory Participation MSAs Voluntary Participation MSAs *Note: Participation requirements are based on the CCN status of the hospital as of January 31, A change in the rural status after the voluntary election period does not affect the participation requirements. 9

10 Voluntary Participation Election The one-time participation election period will begin January 1, 2018, and end January 31, CMS must receive the participation election letter via no later than 11:59 pm ET January 31, The hospital s participation election letter will serve as the model participant agreement for the remaining performance years. - A participation election letter template and instructions are available on the CJR webpage. - One completed Voluntary Participation Election Letter must be submitted for EACH hospital choosing to opt-in to the CJR model. Voluntary participation will be effective February 1, 2018, and will continue through the end of the CJR model. - It is not possible to opt out of the model once a hospital chooses to participate. Providers opting in will remain in the model through performance year five, which ends December 31,

11 Technical Refinements and Clarifications (1) CMS may take remedial action if hospitals or collaborators fail to participate in CJR model evaluation. Reconciliation calculations will continue to be done separately for each individual hospital that merges or reorganizes during a performance year for the period prior to the merger or reorganization. The CJR Telehealth Healthcare Common Procedure Coding System (HCPCS) codes will having pricing adjusted to include the facility practice expense (PE) values, which will increase the payment amounts. To ensure that model participants are aware of periodic ICD 10-CM code updates to the Hip/Knee Complications measure, participants must use the applicable ICD 10-CM code set that is updated and released to the public each calendar year in April by CCSQ and posted on the Hospital Quality Initiative Measure Methodology web site. 11

12 Technical Refinements and Clarifications (2) Changes to the CJR model quality measures and composite quality score methodology, which were finalized in the EPM final rule, will be applied during the PY1 subsequent reconciliation. This may result in significant differences between the reconciliation payments calculated during the PY1 initial reconciliation and the PY1 subsequent reconciliation. The methodology differs from that used to determine the quality-adjusted target price for the PY1 initial reconciliation calculation as follows: the quality-adjusted target price will be recalculated to apply the amended reductions to the effective discount factors, including applying more generous criteria for earning quality improvement points. 12

13 Advanced APM In this final rule, we establish a clinician engagement list to broaden the scope of eligible clinicians that are considered Affiliated Practitioners under the CJR model. Eligible clinicians that may be included on a clinician engagement list are physicians, nonphysician practitioners, or therapists who are not CJR collaborators during the period of the CJR model performance year specified by CMS but who have a contractual relationship with the Advanced APM participant hospital based at least in part on supporting the hospital s quality or cost goals under the CJR model. The clinician engagement list and the clinician financial arrangement list will be considered together an Affiliated Practitioner List, which is used by CMS to identify eligible clinicians for the Qualified Practitioner (QP) determination under the Quality Payment Program. 13

14 Interim Final Rule with Comment Period Summary (1) Establishes a policy effective as of 1/1/18 to provide some flexibility in the determination of episode costs for providers located in areas impacted by extreme and uncontrollable circumstances. Addresses Hurricane Harvey, Hurricane Irma, Hurricane Nate, and the California wildfires of August, September, and October 2017 but could also include other similar events that occur in the future. As of the PY 2 initial reconciliation, this policy will apply to CJR participant hospitals that have a CCN primary that is located in an emergency area during an emergency period, as those terms are defined in section 1135(g) of the Act, for which the Secretary has issued a waiver under section 1135 and is located in a county, parish, or tribal government designated in a major disaster declaration under the Stafford Act. 14

15 Interim Final Rule with Comment Period Summary (2) For a non-fracture episode with a date of admission to the anchor hospitalization that is on or within 30 days before the date that the emergency period (as defined in section 1135(g) of the Act) begins, actual episode payments are capped at the target price determined for that episode under For a fracture episode with a date of admission to the anchor hospitalization that is on or within 30 days before or after the date that the emergency period (as defined in section 1135(g) of the Act) begins, actual episode payments are capped at the target price determined for that episode under There is a 60 day comment on this Extreme and Uncontrollable Circumstances policy which will close on January 30,

16 Changes to the CJR Model from the May 21, 2017 Final Rule that take effect Jan. 1, 2018 The May 21, 2017 Advancing Care Coordination Through Episode Payment Models (EPMs); Cardiac Rehabilitation Incentive Payment Model; and Changes to the Joint Replacement Model (CJR) Final Rule included various policy changes for CJR that were not impacted by the recent cancellation of the EPMs and CR Incentive Payment Model. Changes to the CJR model that become effective on January 1, 2018: - Access to Records and Records Retention - Financial Arrangements 16

17 Changes to the CJR Model Effective on January 1, 2018 Access to Records and Records Retention: Beginning January 1, 2018, the CJR model records access and retention requirements are consolidated and apply more broadly across the model. Financial Arrangements: - All financial arrangements changes will be effective January 1, Most notable changes to financial arrangements under the CJR model are: ü Streamlining and reorganizing the provisions for clarity and consistency and removal of the term collaborator agreement ü Expanding the scope of financial arrangements and eligible CJR collaborators ü Addition of the term CJR Activities 17

18 CJR Financial Arrangements: Diagram Effective January 1,

19 CJR Financial Arrangements: Waivers of Certain Fraud and Abuse Laws On December 05, 2017, the OIG and CMS jointly issued new waivers, effective January 1, 2018, for specified arrangements permitted under the. These new waivers are the result of certain programmatic changes being made by the CMS to the CJR Model and on their effective date supersede the original waiver notice, which was jointly issued by OIG and CMS on November 16, To download the new waivers, please go to Abuse/PhysicianSelfReferral/Downloads/2017-CJR-Model- Waivers.pdf. 19

20 Outreach and Support for Hospitals For CJR Model inquiries, the CJR Model Team at For CJR participant hospitals, the CJR Support Team at Model background documents, list of hospitals, and other materials on the CMMI CJR public website at CJR Connect 20

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