CMS Releases New CMMI Payment Model Flexibilities for COVID-19

June 5, 2020

Earlier today, the Centers for Medicare & Medicaid Services (CMS) announced changes in payment methodologies, quality reporting, and timelines for the Center for Medicare & Medicaid Innovation (CMMI) models in response to COVID-19. The changes include, but are not limited to, the following:

Payment Methodology Changes

  • Bundled Payments for Care Improvement Advanced
    • Option to eliminate upside and downside risk by excluding Clinical Episodes from Reconciliation for Model Year 3 (2020)
  • Comprehensive End-Stage Renal Disease Care Model (CEC) and Next Generation Accountable Care Organizations (NGACO) Model
    • Reduce 2020 shared losses by the proportion of months that occur during the public health emergency (PHE) and exclude COVID-19 inpatient episodes
    • Remove 2020 financial guarantee requirement
  • Oncology Care Model (OCM)
    • Option to forgo upside and downside risk for performance periods affected by the PHE

Delays and Extensions

  • Emergency, Triage, Treat, and Transport (ET3) Model: start delayed to fall 2020
  • OCM: Model extended by one year (through June 2022)
  • Maternal Opioid Misuse Model: start of beneficiary enrollment delayed to July 1, 2020
  • Primary Care First Serious Illness Component: performance period start delayed to April 1, 2021
  • CEC: Model extended through March 2021

See a full list of programs and changes in the chart available here. Please note that the chart includes the following flexibilities for the Comprehensive Care for Joint Replacement (CJR) Model, the first two of which were finalized in CMS’s interim final rule released March 30:

  • Extends Performance Year (PY) 5 by three months (i.e., through March 2021)
  • Caps actual episode payments at target price, eliminating downside risk during the PHE
  • Extends the appeals timeline for PYs 3 and 4 from 45 days to 120 days

In addition to listing more changes for the models highlighted above, the chart also includes program changes—including many quality reporting changes—for the following models: Direct Contracting (Global and Professional), Independence at Home (Section 3024 of the Affordable Care Act), Integrated Care for Kids Model, Kidney Care Choices, Medicare Diabetes Prevention Program Expanded Model, and Medicare ACO Track 1+ Model. We anticipate future model-specific guidance on these flexibilities.

For questions regarding financial changes, please contact Rebecca Ryan. For questions regarding quality reporting changes, please contact Amy Chin.