While promising in its potential to move us closer to the day when our health care system provides higher quality, better coordinated care at lower cost, the National Partnership for Women & Families expresses concern about the proposed Comprehensive Care for Joint Replacement (CCJR) Payment Model in comments submitted today to the Centers for Medicare and Medicaid Services (CMS).

“Bundled payment models like the CCJR have the potential to drive quality improvement and better value in our health care system. But these models will only be successful if they protect patient choice and hold hospitals and providers accountable for improving care coordination, patient experience of care and health outcomes,” said Debra L. Ness, president of the National Partnership.

In its comment letter, the National Partnership recommends modifications to the proposed model to help ensure that beneficiaries receive the appropriate care, in appropriate settings, at the most appropriate time. Recommendations include requiring hospital use of shared care planning, appropriateness screening criteria and meetings with beneficiaries prior to admission, as well as requiring enhanced use of patient-reported outcomes. All of these strategies can help prevent inappropriate utilization of joint replacement surgery and ensure delivery of high quality care, the National Partnership writes.

According to CMS, the proposed CCJR payment model “seeks to encourage greater care coordination by testing bundled payment and quality measurement for an episode of care associated with hip and knee replacements” – two of the most common surgeries for which Medicare pays. If implemented as proposed, the CCJR payment model would be mandatory for hospitals in 75 geographic areas across the United States.

In its comments, the National Partnership expresses concerns about making the model mandatory, in part because as currently proposed, the CCJR model does not require hospitals to outline a robust clinical care model or demonstrate familiarity with care coordination, which could result in beneficiaries receiving low-quality care in a hospital that is unprepared to coordinate their care. The comments also raise concerns about how the current absence of accurate risk adjustment could perversely incentivize hospitals to avoid treating higher-risk candidates. The letter offers possible solutions to these concerns, and offers a range of other recommendations to strengthen the model.

The National Partnership’s comments are available here.