CMS's latest bundled payments program is beset by "unrealistic expectations" and needs to be modified to account for patient acuity and other factors that can skew reimbursement, says one expert.
First, some good news: Expect a rollback of the aggressive implementation timeline for the cardiac care bundled payments program announced by CMS Monday.
Now, the bad news: Preparations, including developing strong relationships with other pieces of the cardiac care continuum, need to start now.
Regardless of whether your organization is in one of the 98 randomly selected geographic regions ultimately selected for mandatory participation in the program, no one should waste the probable delay.
So says Colin Luke, a partner at the Birmingham, AL, office of Nashville-based law firm Waller. The complexity of the cardiac care bundle program surprised him, even given his experience helping systems navigate regulatory compliance matters related to CMS's bundled payment programs for total joint care and cancer care.
"The complexity was beyond what I expected and the degree to which the hospitals will bear the burden is greater than expected," says Luke.
Hospitals' administrative expenses to participate in the mandatory program will likely exceed any possible financial rewards available during the course of the proposed rule, he says. It runs through 2021. After that, CMS expects to tweak and expand the bundling program nationwide.
But first, there is a public comment period that closes at the end of September.
Administrative Hassles Eyed
Luke expects hospitals to take a view in the short term that participation in the program as detailed in a CMS fact sheet will dramatically increase their administrative burden while rewards for such investments won't be seen until far down the line.
"I doubt many [hospitals and health systems] believe in the short term that participation is going to be worth the extra expense and administrative hassles," he says.
"CMS has figured out how to make a hospital accountable for non-employed, non-contracted, non-affiliated providers that are responsible for most of the downstream and parallel care. Even without downside risk (in the first 15 months or so of the program), hospitals are exposed to unrealistic expectations."
Philip Betbeze is the senior leadership editor at HealthLeaders.