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News & Press: Government Affairs News

CMS Releases COVID-19 Changes to CMMI Models

Wednesday, June 3, 2020   (0 Comments)
Posted by: Bradley Coffey, MA, AAOE Government Affairs
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Baltimore, MD - The Centers for Medicare and Medicaid Services (CMS) has released flexibilities for demonstration models run through the Center for Medicare and Medicaid Innovation (CMMI). These model flexibilities were created to ease the burden of these demonstration models during the COVID-19 public health emergency.

Two models, Bundled Payments for Care Improvement Advanced (BPCI-A) and Comprehensive Care for Joint Replacement (CJR), have large orthopedic participation. The flexibilities for these models are outlined below. We have also included information on models with less orthopedic participation for those practices that may be participating:

Innovation Center Model  Financial Methodology Changes Quality Reporting Changes Model Timeline Changes
Bundled Payments for Care Improvement  Advanced
  • Option for participants to eliminate upside and downside risk by excluding clinical episodes from reconciliation for Model Year 3 (2020)
  • For BPCI-A participants that choose to remain in two-sided risk, exclude certain clinical episodes from reconciliation with a COVID-19 diagnosis during the episode
  • No Change
  • No Change
Comprehensive Care for Joint Replacement
  • Remove downside risk by capping actual episode payments at the target price for episodes with a date of admission to the anchor hospitalization between January 31, 2020 through the termination of the emergency  period.
  • Extend the appeals timeline for Performance Year 3 and Performance Year 4 from 45 days to 120 days
  • No Change
  • Extend Performance Year 5 through March 2021
Direct Contracting (Global and Professional)
  • Adjust model to reflect change in duration of 2021 Performance Period due to April 1, 2021 start.
  • Adjust quality benchmarks, if necessary to reflect change in duration of 2021 Performance Period due to April 1, 2021 start.
  • Delay start of the first Performance Period for cohort #1 to April 1, 2021.
  • Create application cycle during 2021 for second cohort to launch January 1, 2022.
Medicare ACO Track 1+ Model
  • Remove episodes of care for treatment of COVID-19.
  • Medicare Shared Savings Program Extreme and Uncontrollable Circumstances policy applies to 2020 financial reconciliation.
  • 2019 Web Interface quality measure reporting deadline extended from March 31, 2020 to April 30, 2020.
  • Medicare Shared Savings Program Extreme and Uncontrollable Circumstances policy applies to 2019 and 2020 reporting.
  • Continue to monitor impact on 2020 quality reporting.
  • Voluntary election to extend agreement for 1 year through December 2021.
Next Generation ACO (NGACO)
  • Reduce 2020 downside risk by reducing shared losses by proportion of months during the PHE.
  • Cap NGACOs' gross savings upside potential at 5% gross savings.
  • Remove episodes of care for treatment of COVID-19.
  • Use retrospective regional trend, rather than prospective, for 2020.
  • Remove 2020 financial guarantee requirement.
  • 2019 Web Interface quality measure reporting deadline extended from March 31, 2020 to April 30, 2020.
  • 2019 quality audit canceled.
  • Continue to monitor impact on 2020 quality reporting.
  • Extend model through December 2021.

CMS is making these changes to address the COVID-19 public health emergency and provide flexibilities to participating providers. CMS states that these changes are not exhaustive and that there is potential for future adjustments "as the COVID-19 public health emergency continues to evolve".

CMS states that it used the following principles to determine which changes are appropriate:

  • Utilize flexibilities that already exist in current model design.
  • Continue sufficient financial incentives that encourage higher quality outcomes to participate in value based arrangements.
  • Ensure equity and consistency across models.
  • Align as much as possible with national value based and quality payment programs.
  • Minimize risk to both model participants, the Medicaid program, and the Medicare Trust Funds.
  • Minimize delays in new model implementation while providing additional opportunities for participation in new models.
  • Minimize reporting burden.
  • Complements and builds off of new CMS COVID-19 PHE flexibilities as outlined in regulation and waivers.

You can read more about CMS' changes in this HealthAffairs blog post from CMS Administrator Seema Verma.


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