This week, AAHKS submitted comments to the Centers for Medicare & Medicaid Services (CMS) on its hospital inpatient prospective payment systems (IPPS) proposed rule for fiscal year 2027. Comments include concerns with grouping methodology for new joint infection DRGs and classification and relative weight changes for Medicare Severity DRGs. We also recommend that CMS postpone implementation of the CJR-X until several key design elements can be verified through the current TEAM model which just began. Read the full letter and review the summary points below.
Concerns on CJR-X proposals include:
- Too many providers are untested and unprepared for VBC to accept 20% risk in an episode payment model.
- Lack of ASC participation undermines the success of the model.
- The continued lack of a convening role for physicians and mandatory shared savings with surgeons will further drive consolidation and drive more physicians out of independent practice.
Comments on TEAM updates include:
- Creating a separate episode benchmark for procedures performed at the ASC based on ASC-specific cost experience, and carefully analyze this data for several years before considering a benchmark combining ASC and HOPD procedures
- Utilizing AJRR for quality reporting for TEAM and CJR-X
- Excluding ASCs in TEAM undermines its success
- AAHKS favors an opt-in period for POHs to join TEAM