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Top 10 Ways to Make Use of the CMS Bundled Payment Delays

Cindy Friend, RN, BSN, MSN, MBA/HCA
Vice President, Population Health Strategy

On March 20, 2017, the Centers for Medicare & Medicaid Service (CMS) published an interim final rule (IFR) Advancing Care Coordination Through Episode Payment Models (EPMs); Cardiac Rehabilitation Incentive Payment Model; and Changes to the Comprehensive Care for Joint Replacement Model, which officially delays:

  • The implementation of bundled payment for cardiac initiatives from July to October
  • The effective date of a final rule that outlines the implementation of the Comprehensive Care for Joint Replacement (CJR)
  • Other bundled payment programs


Most organizations will wipe their brow and expel a sigh of relief at the news of the delay in the bundled payments program, but this is not the time to rest. Time is of the essence and hospitals and health systems must take advantage of this time to plan and build their bundled payments program; especially, since a federal delay does not mean that other payers will stall. Whether your organization is just beginning to think about building a bundled payments program or has a program in place, here are the top 10 ways to make use of the CMS delays that will help build or improve your bundled payments program.

  1. Set the stage for culture change. While this is not solely linked to your bundles program, establishing a “patient-centered can do attitude” culture can pay off in dividends. Culture change is not an easy task, but it is mission critical for the success of any organizational change or initiative. Most organizations may have a culture change management approach and leveraging an existing framework can save time and the familiarity of the approach will likely resonate more effectively with staff. Healthcare organizations must ensure that any program, new or existing, fosters quality patient care, team work, and empathy. Failure to proactively induce culture change and consistently reinforce can have a negative impact on success.
  2. Engage providers and staff. Engaging providers early in the process and involving them in the decisions is critical to a successful bundled payments program. All too often, administration will make business decisions that affect clinical care delivery and, albeit unintentional, providers and staff are not included in the discussions and decision-making process. Bringing clinical champions into the mix early will solidify their support for the effort. They will have some skin in the game and will act as “invigorators” with their peers. Excluding providers and clinical staff in the process will prove a detriment to the program.
  3. Know your end-to-end costs. Whether you are starting out or have an active bundles program, evaluating the cost as a baseline or comparison to previous costs analysis is essential to identifying potential cost savings. Healthcare providers must conduct an end-to-end cost analysis taking into consideration all the costs associated with the care of the patient, including but not limited to:
    1. Supply chain costs (e.g., implant device)
    2. Inpatient cost
    3. Post-acute cost
  4. Transparency in quality and performance. Conducting peer-to-peer comparisons are a very effective tactic to drive transparency and, ultimately, change. If this level of performance reporting is not a common activity, organizations must approach very cautiously (and lots of forewarning) because it can produce various reactions, including the casting of doubt upon the results. While it can initially be a little uncomfortable for all involved, eventually acceptance of the report and the results will occur. Though, failing to manage performance and leverage peer-pressure will not drive collaboration, discussion, and improvement.
  5. Standardize care pathways and protocols. Creating a clinical pathway that encompasses the entire episode of care (pre-op, peri-op, post-op, and post-discharge) is a daunting task but critical to ensuring compliance with standards of care, consistent care delivery, and optimizing patient outcomes. Encouraging providers and clinical staff to work together on developing care pathways and protocols can foster collaboration that can lead to more effective, more predictable, and more collaborative care across the continuum. While care pathways and protocols can minimize variances in care delivery, patient-specific care needs will always take precedence and can vary depending on the patient’s age, past medical history, functional status, etc.
  6. Evaluate and improve patient throughput. Patient experience is a key driver of patient satisfaction. Healthcare organizations should evaluate the patient throughput. This will likely expose some snafus in the process where patients do not have a seamless care experience (e.g., long wait times, delay transfers, etc.). This is a prime time for an organization to institute throughput improvements and avoid what could lead to derogatory results in a patient satisfaction survey. One important item to keep in mind is that throughput is not a one and done, continuous monitoring of factors impacting or impeding patient throughput is necessary.
  7. Develop a post-acute network strategy. One of the greatest areas of cost-savings is found in the post-acute care settings. For this reason, it is critical for healthcare organizations to understand details post-acute providers, including but not limited to quality measures, performance indicators, cost, and care management outcomes (click to see EcoPATH). Using this information, healthcare organizations will be able to identify which providers to partner with for post-acute network care services. Establishing these networks can be arduous, but establishing service level agreements that define expectations and care delivery protocols will serve the organization well in its cost containment efforts.
  8. Establish post-discharge care management support. While establishing a post-acute network is very beneficial in managing patient care post-discharge, the responsibility of the patient episode of care does not stop at discharge. Healthcare organizations must establish a post-discharge care management support strategy. This does not mean that the organization must create a whole new program but, rather, the organization should evaluate the possibility of leveraging other established programs, such as transitions of care, readmission reduction, etc., as a vehicle to manage the patient care following discharge.
  9. Institute a patient engagement program. A sound patient engagement program addresses patient education, self-care, setting expectations, action plans, behavior modification, etc. A formal program will set the foundation and continuous education and support will help to ensure that patients are receiving a succinct and aligned message from providers and clinical staff across the continuum. Failure to establish a patient engagement program can hinder the success of the program because patients may not receive proper reinforcement that comes from hearing the same instructions and message on a continual basis that can drive compliance.
  10. Evaluate health IT software, technology infrastructure, and data reporting capabilities. Health IT software and the supporting infrastructure is very important in the data capture process for reporting. It is imperative for healthcare organizations to evaluate systems used, the ability to aggregate the data, and the reporting requirements. All too often, organizations will categorize the evaluating the health IT, infrastructure, and reporting process as a low priority given the other, seemingly more important activities, though, find themselves in a crunch to give these items proper attention.
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