PTPN comments on CMS proposed hip and femur fracture bundles

On September 28, PTPN submitted comments to CMS on the proposed addition of hip and femur fractures to the Comprehensive Care for Joint Replacement (CCJR) program for bundled payments that began in April of this year. The proposal extends the CCJR bundling provisions beyond total knees and total hips (TKR/THR) to include patients undergoing surgical hip and femur fractures treatment (SHFFT) episodes, seeking to “complete the transition to episode payment for the surgical treatment and recovery of the significant clinical condition of hip fracture”. The program is to launch July 1, 2017 and last 5 performance years through December 31, 2021. (This proposed rule also focuses on implementing mandatory retrospective episode payment models for care associated with bypass surgery and heart attacks.)

The plan announced by CMS would affect the same hospitals and geographic areas as were selected for the CCJR model implemented on April 1, 2016. The new bundling plan also uses a similar framework as CCJR, with the goal of reducing costs through coordination of care and financial accountability. Once again, the model is hospital-centric. The proposed payment model would reimburse hospitals a set amount for an entire episode of care for all services for all providers (even those outside the hospital), starting with admission through 90 days after the patient is discharged. Additionally, Medicare would create targets for spending, and if the total spending is less than the Medicare target, the hospitals may be eligible to receive additional payment from Medicare. However, if the spend is more than the Medicare target, they could be required to pay back Medicare for some portion of the difference. As with the current CCJR program, providers who see these patients outside the hospital setting will still get paid as they normally do for Medicare patients. PTPN members can review both a 30 minute webinar and a members-only guide about the TKR/THR CMS bundled payment program, as well as access marketing materials for these programs, in the members-only section of ptpn.com.

Why was hip and femur fracture chosen? The previous CCJR model focused on common, yet usually elective procedures, whereas hip fracture is more often an unanticipated, serious, and sometimes catastrophic event for Medicare beneficiaries. In 2010, 258,000 people aged 65 and older were admitted to the hospital for hip fracture, with an estimated $20 billion in lifetime cost for all hip fractures in the United States in a single year. In 2013, fracture of the neck of the femur (the most common location for hip fracture) was the eighth most common principal discharge diagnosis for hospitalized Medicare fee-for-service beneficiaries, constituting 2.7 % of discharges.

PTPN’s comments to CMS focused on maintaining and strengthening safeguards for private practice therapists to continue to see these types of patients outside the bundles, as well as to participate in these bundles should they so desire. We also asked CMS to clarify that hospitals could contract with therapy group practices, and not just individual therapists for these programs. And we requested that CMS make these bundled arrangements qualify as Advanced Alternative Payment Models (APMs) under Medicare’s new Quality Payment Program and allow therapists who participate in these bundled arrangements to also qualify under the APMs.

If you’d like a copy of the complete comments, please email nrothenberg@ptpn.com. Together we can make a difference.