HAP Comment Letter to CMS on 2016 Comprehensive Care for Joint Replacement Payment Model Proposed Rule

September 3, 2015

Andy Slavitt
Acting Administrator
Centers for Medicare & Medicaid Services
U.S. Department of Health and Human Services
Attention: CMS-5516-P
Hubert H. Humphrey Building
200 Independence Avenue, S.W., Room 445-G
Washington, DC 20201

SUBJECT: CMS-5516-P. Comprehensive Care for Joint Replacement Payment Model for Acute Care Hospitals Furnishing Lower Extremity Joint Replacement Services Proposed Rule, July 9, 2015

Dear Mr. Slavitt:

On behalf of The Hospital & Healthsystem Association of Pennsylvania (HAP), which represents approximately 240 member institutions, we appreciate the opportunity to comment about the Centers for Medicare & Medicaid Services’ (CMS) Comprehensive Care for Joint Replacement Payment Model for Acute Care Hospitals Furnishing Lower Extremity Joint Replacement Services proposed rule for calendar year 2016.

HAP supports CMS’ effort to move towards a value-based reimbursement system.

This bundled initiative is an important step towards this goal. However the Pennsylvania hospital community has several concerns, including:

• The short time frame to implement processes for a January 1, 2016, start
• The failure to provide exclusions such as non-elective surgeries
• The lack of necessary legal protections to permit hospitals to partner successfully with other providers

Attached are HAP’s detailed comments about the proposed regulations.

Thank you for your consideration of HAP’s comments regarding this proposed rule.

If you have any questions, please contact Laura Stevens Kent, vice president, federal advocacy, at (202) 863-9287, or Kate Slatt, senior director, health care finance policy, at (717) 561-5317.

Sincerely,

Jeffrey Bechtel
Senior Vice President, Health Economics and Policy