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Bundled Payments on the Back Burner
Bundled Payments on the Back Burner
By Colin Luke | 03-22-2017

An interim final rule (IFC) published by the Centers for Medicare & Medicaid Services (CMS) has delayed the expansion of the Comprehensive Care for Joint Replacement (CJR) bundled payment pilot program, the implementation of cardiac care bundled payment initiatives, and the launch of the Cardiac Rehabilitation Incentive Payment Model.

Overall,  the rule makes it less likely in the short term that there are going to be any significant new bundled payment initiatives for home health and other healthcare providers.  HHS Secretary Dr. Thomas E. Price has made it quite clear that he wants greater provider involvement in bundled payment design, and he intends to “re-tool” proposed bundled payment programs to allow providers more time to prepare for and implement complex new payment models.  In the longer term, the jury is still out on whether bundled payments will become a significant source of reimbursement for home health payments as these programs move to voluntary participation and become more physician and hospital friendly.

The IFC seems a clear indication that the transition from fee for service to mandatory bundled payments is going to be slowed down and scaled back.  Dr. Price dislikes mandatory quick shifts in payment methodology without proven and corresponding benefits to patient care.  He is certainly moving away from unnecessary provider mandates. The new rules, however, won’t likely spell the end for bundled payments. This is simply a signal that the Trump Administration is not enamored with unjustified provider mandates and arbitrary percentage deadlines in the shift away from fee-for-service payment methodologies. It’s worth noting, however, that commercial payors that have seen cost reductions under bundled payments will likely want to continue the programs regardless of federal policy. 

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Colin H. Luke
205.226.5717
colin.luke@wallerlaw.com
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