ACC Comments on Episode Payment Model Proposed Rule

The ACC submitted comments to the Centers for Medicare and Medicaid Services (CMS) in response to the Advancing Care Coordination Through Episode Payment Models (EPMs) Proposed Rule. The proposal introduces bundled payment for acute myocardial infarction (AMI) and coronary artery bypass grafting (CABG), mandatory in selected geographical areas, and a cardiac rehabilitation incentive payment, which together will be rolled out as a five-year demonstration project from 2017 – 2021. Importantly, the AMI and CABG EPMs qualify as Advanced Alternative Payment Models (APMs) for hospitals meeting certified electronic health record requirements, making these EPMs one of a select few Advanced APM options for specialists and the only option specifically for cardiologists.

In its comments, the College underscored its support of value-based payment models and thanked CMS for including pathways to reward specialists for delivering quality care through these models in the proposed rule. However, the ACC stressed the “extremely challenging nature” of creating value-based models for patients with cardiovascular disease and urged CMS to “proceed with great caution” in regards to implementation and testing. “While we believe value-based payment models can be effective, particularly in encouraging improved collaboration, coordination of services and appropriate care transitions, we recognize that such models are only as strong as their clinical and operational design. Models such as the proposed episode payment models must allow for accurate beneficiary attribution, valid quality and cost measurement, meaningful comparisons, and ultimately development of best practices to achieve better health outcomes for patients,” noted the ACC.

ACC’s comments addressed clinical and operational design providing special attention to the proposed AMI model. The College focused on five key comment areas: clinical homogeneity in the AMI model, quality measures in the AMI model, Advanced APMs, special policies for hospital transfers of beneficiaries with AMI, risk sharing and financial arrangements under EPMs and additional care coordination considerations.

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Keywords: Cardiovascular Diseases, Centers for Medicare and Medicaid Services, U.S., Coronary Artery Bypass, Electronic Health Records, Medicaid, Medicare, Myocardial Infarction

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