This week AAHKS submitted comments regarding the Centers for Medicare & Medicaid Services (CMS) proposed rule to extend the Comprehensive Care Joint Replacement (CJR) Model Three Year Extension and Changes to Episode Definition and Pricing. The proposed rule seeks to extend the CJR model’s operation beyond its current scheduled end date of December 31, 2020 to December 31, 2023. The next three years would be known as CJR Performance Year 6 (2021) through Performance Year 8 (2023). While AAHKS supports this extension, we have again requested that the model be voluntary for participants – rather than mandatory. In addition:

  • AAHKS welcomes the addition of outpatient TJA to the CJR, but highlighting the need for better guidance from CMS on the application of the 2-midnight rule to TJA.
  • The proposed blended rate for MS–DRG 470 (without hip fracture and outpatient TKA and THA without hip fracture) may encourage more use of the outpatient setting than is clinically appropriate.
  • The high episode spending cap should be set at 90%.
  • AAHKS welcomes the expanded risk adjustment methodology with some questions and suggestions.
  • AAHKS welcomes the removal of the gainsharing cap.
  • AAHKS is developing proposals for a site-neutral TJA bundled payment model encompassing ASCs and hospitals.
  • Adding new DRGs 521 and 522 to the CJR would preserve the volume of TJA procedures that are subject to value-based care incentives.

Read the letter.