Which parts of the program have changed?
The interim final rule with comment period delays the original July 1, 2017 start of performance year 1 of the newly finalized episode and incentive payment models until October 1. In other words, providers slated to be under mandatory participation for AMI, CABG, or SHFFT bundles will now be eligible for upside-only reconciliation payments for episodes starting on or after October 1, should they successfully reduce episodic spending below their target price. The recently finalized Cardiac Rehabilitation incentive payments have also been delayed to the same October 1 date.
Is a further delay possible?
Yes. CMS is openly considering a further delay to the start of performance year 1 until January 1, 2018. The agency has opened a 30-day comment period to gauge provider interest in this recommendation.
Has the start of mandatory downside risk also been pushed back?
No. The start of downside risk has not been postponed. The new interim final rule affects only the start date of the first performance period. Downside risk is still slated to begin on January 1, 2019, as originally scheduled. However, it is important to note that the new interim final rule did not comment on any aspect of the program beyond year 1. So while it is possible that CMS would eventually modify the timeline for year 2 and 3—including the onset of mandatory downside risk—the new interim final rule contains no information on such a change.