The Comprehensive Care for Joint Replacement Payment model could help further hospital efforts to transform care delivery through improved care coordination and financial accountability, the AHA told the Centers for Medicare & Medicaid Services in comments submitted today. The association said it supports the program but urged CMS to “provide hospitals with the necessary tools to be successful under the program and appropriately balance the risk versus reward equation.” Specifically, AHA urged the Health and Human Services Secretary to waive the Physician Self-Referral Law and Anti-Kickback Statute with respect to financial arrangements formed by hospitals that comply with the proposed rule’s requirements. “As proposed, any financial arrangement or agreement under the CCJR model that implicates fraud and abuse laws would not be protected unless it falls under an existing exception or safe harbor,” noted AHA Executive Vice President Tom Nickels. “That is an unacceptable risk for hospitals, whose participation in this program would be mandatory.” AHA also urged CMS to delay the program’s start date and downside risk to give hospitals “adequate time to put in place the care processes and procedures necessary to achieve success in the program.” In addition, the association urged CMS to restrict the program to elective hip and knee replacement episodes, and incorporate a risk-adjustment methodology. It also recommended changes to more appropriately balance provider risk and reward.