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CCJR and Mandatory Bundled Payments: Legal and Practical Perspectives


On July 9, 2015, the Centers for Medicare and Medicaid Services (CMS) issued a new proposed rule for a Comprehensive Care Joint Replacement (CCJR) program that would impose a bundled payments for joint replacement surgery, hospitalization and recovery. Unlike previous programs, the CCJR program, as proposed, is a mandatory program that will impact approximately 900 hospitals in specifically identified metropolitan service areas.

The CMS mandate would begin on January 1, 2016 and include down-side risk to inpatient hospitals beginning in the second year of the five-year program. Hospitals have limited time to prepare for the implementation of this mandatory “bundled” payment program, which up to this point was offered as a voluntary program allowing hospitals, skilled nursing facilities, and physician practices to accept financial risk for select episodes. The CCJR program is intended to advance CMS’s objectives to transform its payment system from volume-based to value-based payments.

The webinar will be organized to provide both legal analysis of the proposed rule, potential options for CMS in issuing the final rule, and practical considerations in preparing for this game-changing CCJR program:

  • Summary of the CCJR program scope and mechanics
  • Understanding of the legal requirements associated with the CCJR program
  • Review of the opportunities and requirements to work with CCJR collaborators (e.g., physicians, therapists, home health, skilled nursing) through gainsharing arrangements
  • Considerations on whether CMS will update the CCJR program to include fraud and abuse waivers
  • Review of hospital impact and operational planning to prepare for the CCJR program
  • Outline of key initiatives proven to lower episode costs and improve outcomes

The live presentation of this program was approved for 1.0 hour general CLE credit in California and Illinois, and 1.2 general CLE credit in Missouri. CLE credit is no longer available for this recording.

John Howard, Partner, Thompson Coburn
Kristi Short, Senior Vice President, Navvis Healthways

Originally Presented:
September 15, 2015