CJR FAQs Updated
December 2017 CJR Final Rule Policy Changes
On March 8, 2018, CMS posted an updated FAQ document on the Comprehensive Care for Joint Replacement (CJR) Model webpage. The document can be found at the bottom of the CJR webpage in the Participant Resources section. This update reflects several policy changes that were finalized in a December 1, 2017 Final Rule that revised certain CJR model policies.
CJR Model Background
The CJR Model was the first CMS bundled payment model that was mandatory for hospitals within selected metropolitan statistical areas (MSAs). The model began on April 1, 2016 and is set to run through December 31, 2020. This article highlights FAQs that reflect some of the policy changes.
Who is required to participate in the Model?
Initially hospitals paid under the Medicare IPPS in 67 selected MSAs, with a few exceptions were required to participate. As of February 18, 2018, 34 of the 67 areas will remain mandatory participation areas with all hospitals, except low volume or rural hospitals. The remaining 33 areas are now voluntary. Low volume and rural hospitals in the mandatory areas and hospitals in the voluntary areas were given a one-time opportunity in January 2018 to voluntarily opt-in the model for the remaining three years of the model.
How many Hospitals are included in the model?
As of April 1, 2016 there were approximately 800 acute care hospitals eligible to be included. About 100 of these providers do not typically perform joint replacement procedures and may not have any CJR episodes.
As of February 1, 2018 465 hospitals are participating. The list of participant hospitals is available on the CJR webpage: https://innovation.cms.gov/initiatives/cjr.
How will the removal of TKA from the inpatient-only list affect CJR participant hospitals?
“The total knee arthroplasty (TKA) CPT code (27447) was removed from the inpatient-only list in the Calendar Year 2018 Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Payment System final rule, dated December 14, 2017. While this means that Medicare will now pay for TKAs performed in the outpatient setting, it does not mean that CMS expects that all TKA procedures for Medicare beneficiaries will be done in outpatient settings.”
How will the outpatient TKAs affect CJR target prices?
“Since CJR is a regulatory model, changes to the model, including how target prices are calculated, generally must be made through notice and comment rulemaking. Target prices are calculated based on historical claims data without regard to the length of stay for the inpatient claim that forms the anchor stay for the episode. Currently there are no mechanisms to make adjustments to the CJR target prices should the removal of TKA procedures from the inpatient only list lead to a decrease in the number of actual CJR episodes with shorter, less expensive anchor stays. The CJR model team is actively analyzing claims data and may engage in rulemaking on this issue during 2018.”
What are the amendments to the financial arrangement policies, and when are they effective?
Effective January 1, 2018, CMS:
- “Added Non-Physician Provider Group Practices (NPPGP), ACOs, hospitals, and critical access hospitals (CAHs) as CJR collaborators;
- Deleted the term ‘collaborator agreement’ and revised requirements of a financial arrangement between a participant hospital and a CJR collaborator under sharing arrangements to streamline the requirements for participant hospitals;
- Added and revised several financial arrangements and payment terms in order to incorporate the addition of entities and individuals to the list of CJR collaborators, collaboration agents and downstream collaboration agents;
- Added the term “CJR activities” to identify activities that collaborators and their partners undertake toward the CJR model’s goals of improving the quality and efficiency of episodes; and
- Consolidated the requirements under the CJR model for access to records and record retention and apply them more broadly in the model.”
While a good primer for those simply interested in learning more about the CJR model, MMP strongly encourages CJR participating hospitals to take the time to read and understand the entire updated fifty-eight page FAQ document.
Article by Beth Cobb
Beth Cobb, RN, BSN, ACM, CCDS, is the Manager of Clinical Services at Medical Management Plus, Inc. Beth has over twenty-five years of experience in healthcare including eleven years in Case Management at a large multi-facility health system.
This material was compiled to share information. MMP, Inc. is not offering legal advice. Every reasonable effort has been taken to ensure the information is accurate and useful.