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What to know about CMS' proposed IPPS and LTCH rules


CMS on Friday published its proposed fiscal year (FY) 2027 Inpatient Prospective Payment System (IPPS) and Long-Term Care Hospital (LTCH) Prospective Payment System rule, which includes a 2.4% pay increase for inpatient hospital services and a mandatory episode-based payment model for joint replacements that would be the first of its kind.

Details on the IPPS and LTCH rule

The proposed rule includes identical payment updates for acute hospitals providing inpatient care and LTCHs. The agency proposed a 3.2% increase in the market basket used to calculate rates, minus a 0.8% productivity adjustment, meaning hospitals would receive a 2.4% pay increase under the proposed rule. Last year, hospitals received a 2.6% payment increase.

CMS said it expects that hospital payments will increase by around $1.4 billion for FY2027. It's also possible Congress could extend higher payments that are slated to expire on Dec. 31 for Medicare-dependent hospitals and low-volume hospitals, which CMS estimated would raise total payments by an additional $400 million.

In addition, CMS proposed expanding the Comprehensive Care for Joint Replacement (CJR) model into a mandatory, nationwide program that will be called CJR-X and begin on Oct. 1, 2027.

 

 

"Differences in patient selection, perioperative pathways, implant use, and post-acute utilization across hip, knee, and ankle procedures can drive meaningful variation in quality, safety, and total episode cost under a 90-day model." 

Under CJR-X, hospitals would be accountable for spending on the episode of care encompassing initial joint replacement surgery, the stay at the hospital, and the first 90 days of recovery, including follow-up care like physical therapy. The expanded model also adds ankle replacements, which weren't included in the initial program.

According to CMS, the initial CJR model, which ran from 2016 to 2024 in around 320 hospitals, generated around $112.7 million in net Medicare savings between 2021 and 2023. If implemented, CJR-X would be the first mandatory, nationwide episode-based payment model.

The proposed IPPS and LTCH rule also features several additional changes, including:

  • Changes to the Hospital IQR Program, including the adoption of three new measures — one focusing on excess days in acute care for diabetes-related hospitalizations and two focusing on advanced care planning and certain hospital harm-related incidents — the modification of five mortality measures (heart attack, heart failure, pneumonia, COPD, and coronary artery bypass graft surgery) starting with the 2028 payment determination, adding Medicare Advantage patients to the program, and shortening the performance period from three years to two. Additionally, three measures would be removed beginning with the 2030 payment determination.
  • The addition of a hospital 30-day, all-cause, risk-standardized readmission rate following sepsis hospitalization measure to the hospital readmissions reduction program starting in 2029.
  • Several changes to the Promoting Interoperability Program, including updating the definition of certified EHR technology, removing two electronic referral loop measures, modifying the electronic prior authorization measure, adding a unique device identifiers for implantable medical devices measure to the public health and clinical data exchange objective, and adding two new electronic clinical quality measures with the 2030 payment determination.
  • Updates to the Transforming Episode Accountability Model (TEAM), a mandatory alternative payment model finalized last year, that "would modify policies affecting episode category triggers, quality measure assessment, and the construction of target prices," according to an executive summary of the proposed rule.

Discussion

CMS Administrator Mehmet Oz said CJR-X will help "better align financial incentives with improved health outcomes — protecting taxpayer dollars while ensuring patients get the care they need before, during, and after surgery."

In a statement, Charlene MacDonald, president and CEO of the Federation of American Hospitals, said that the "continued use of mandatory models further destabilizes the system by interfering with clinical decision-making, failing to reflect how care is delivered across providers, and limiting providers' ability to determine the best course of care for each patient."

Anne Schmidt, director of workforce and health system improvement at Optum Advisory*, said the expansion of the CJR "matters because joint replacement is one of the most variation-sensitive lines in healthcare."

"Differences in patient selection, perioperative pathways, implant use, and post-acute utilization across hip, knee, and ankle procedures can drive meaningful variation in quality, safety, and total episode cost under a 90-day model," Schmidt said. "As participation becomes mandatory, organizations will need to focus on identifying and addressing unwarranted variation across the full episode of care, while preserving appropriate clinical judgment for patients with higher complexity."

MacDonald said the proposed payment increase is "a step in the right direction, but it does not negate the compounding effects of rising inflation, record levels of uncompensated care, and a growing uninsured population."

*Advisory Board is a subsidiary of Optum. All Advisory Board research, expert perspectives, and recommendations remain independent.

(Early, Modern Healthcare, 4/10; Muoio, Fierce Healthcare, 4/10; Condon, Becker's Hospital Review, 4/10)

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