FRIDAY November 20, 2015:

“Overview of Comprehensive Care for Joint Replacement (CJR) Model”

Bundles and Waivers Galore

Is this meant to distract us?

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The most recent Final Rule posted by CMS is this CMS-5516-F, the Final Rule for yet another new payment model, the Comprehensive Care for Joint Replacement (CJR) Model. Just what we need, right? Another Final Rule to absorb for 2016?

At least one bit of good news. Ok, two. First, this rule doesn’t go into effect until April 1, 2016, instead of January 1. Second, it includes some “waivers” for payment arrangements that would otherwise likely grant you a new wardrobe, all in orange, with white canvas slippers.

Is CMS trying to distract us? And from what?

My question, contrarian that I am, is this: are they trying to give us a Red Herring, so we don’t think too much about some other Final Rule? And if that’s true, which one is the Red Herring?

So, let’s discuss it today, while we review these topics:

1. What is CMS’ stated “aim” for this program?
   
2. What is CMS’ true “aim”?
   
3. What kind of payments are being allowed, that are otherwise illegal?
   
4. Are the waivers only about payments?

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