CMS Issues COVID-19 Flexibilities For CMMI Alternative Payment Models

Bass, Berry & Sims PLC

Bass, Berry & Sims PLC

Centers for Medicare & Medicaid Services (CMS) has announced flexibilities and adjustments for current and future alternative payment models administered by the Center for Medicare and Medicaid Innovation (CMMI) to accommodate relevant participants, providers and stakeholders during the COVID-19 public health emergency. While CMS announced that additional details regarding model-specific flexibilities will be released on a rolling basis, CMS leadership authored a blog post and released a table that outlines the models and changes applicable to relevant models.

CMS has utilized existing flexibilities built into current bundled payment models, as well as aligned its additional adjustments with COVID-19 public health emergency flexibilities available on a Medicare fee for service basis (see our previous alert on Section 1135 waivers here). CMS also aimed to adjust financial methodology for performance-based rewards and repayment obligations during the public health emergency to accomplish the following:

  • Encourage continued participation in CMMI alternative payment models and ensure higher quality outcomes.
  • Create equity and consistency across models.
  • Reduce risk for model participants and the Medicare and Medicaid programs.

For example, certain models exclude COVID-19 cases or may reduce exposure for downside risk during the public health emergency. Other flexibilities offered by CMS involve quality reporting changes, including extending deadlines or implementing exceptions. Lastly, CMS announced adjustments to certain model timelines due to COVID-19. CMMI will extend timelines for certain existing models and delay starts for upcoming models.

A full version of the table outlining CMMI flexibilities is available here, which addresses the following models:

  • Bundled Payments for Care Improvement Advanced Model.
  • Comprehensive ESRD Care Model.
  • Comprehensive Care for Joint Replacement Model.
  • Direct Contracting Model.
  • Emergency Triage, Treat and Transport Model.
  • Oncology Care Model.
  • Home Health Value-Based Purchasing Model.
  • Independence at Home.
  • Integrated Care for Kids Model.
  • Kidney Care Choices.
  • Maternal Opioid Misuse Model.
  • Medicare Choices Model.
  • Medicare Diabetes Prevention Program Expanded Model.
  • Primary Care First Model.
  • Medicare ACO Track 1+ Model.
  • Next Generation ACO.

Additionally, in separate guidance, CMS published flexibilities in response to COVID-19 for the Medicare Shared Savings Program, available here.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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