The AHA agrees with the principles underlying the proposed cardiac bundled payment model, but the proposed rule raises serious concerns about the pace of payment reform, AHA told the Centers for Medicare & Medicaid Services in comments submitted today. “Hospitals strongly support CMS’s push for adoption of alternative payment models and are working to help ensure these complex models work for patients,” wrote AHA Executive Vice President Tom Nickels. “However, if the agency does not, in turn, support hospitals by recognizing the significant investments of time, effort and finances that these models require, neither we nor the agency will find success.” Specifically, AHA urged the agency to simplify the cardiac model and consider expanding the Comprehensive Care for Joint Replacement model to include surgical treatment for hip and femur fractures “only when a solid foundation of evidence, analysis and evaluations is present.” The association also urged CMS to incorporate a risk-adjustment methodology and more robust transfer-adjustment methodology into the models, among other changes.