CMS Modifies Innovations Models in Response to COVID-19 Public Health Emergency

WASHINGTON, D.C. (June 9, 2020)—On June 2, 2020, the Centers for Medicare & Medicaid Services (CMS) announced plans to modify aspects of various innovation models being administered by the Centers for Medicare & Medicaid Innovation (CMMI) in response to COVID-19 public health emergency (PHE). As part of its announcement CMS issued a table containing specific model adjustments related to financial methodologies, quality reporting and model timelines that it is implementing at this time. The announcement indicates that these changes are not exhaustive; other changes may be implemented as the PHE evolves.  

Following are some of the models included in the table:

• Bundled Payments for Care Improvement Advanced
• Comprehensive Care for Joint Replacement (CJR) Model
• Direct Contracting (Global and Professional)
• Home-health Value-based Purchasing Model (HHVBP): previously announced quality reporting exceptions/extensions 
• Independence at Home (Section 3024 of the ACA)
• Primary Care First—Serious Illness Component (SIP):  Delay start of SIP component until April 1, 2021 

CMS used the following principles to determine appropriate changes:  

• 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

CMS plans to provide additional information regarding the implementation of these changes directly to model participants, and such changes may involve amendments to participation agreements and other model documents. CMS also noted that, based on the future evolution of the COVID-19 PHE, there is a possibility that the implementation of new models may be further delayed. However, it is the National Association for Home Care & Hospice’s (NAHC’s) understanding that as of the current time CMS intends to move forward with the Medicare Advantage (MA) Value-Based Insurance Demonstration (VBID) test of carving hospice into the MA benefit package.

Additional information about each of these model adjustments is available here.