The AHA supports the Centers for Medicare & Medicaid Services’ proposal to delay the start date for its cardiac and surgical hip and femur fracture treatment bundled payment models until Jan. 1, 2018, the association told the agency in comments submitted today, but cautioned against additional delays that “would effectively turn the start date for these programs into a moving target." AHA also urged CMS to provide beneficiary-level claims data to participants as soon as possible, and continued to urge 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 and health systems participating in the models. Among other changes, AHA urged CMS to give providers maximum flexibility to identify and place beneficiaries in the clinical setting that best serves their recovery goals; implement smaller discount factors in the cardiac model; and achieve a “more appropriate” risk-reward balance. “[A]s it exists, the rule places too much risk on providers with little opportunity for reward in the form of shared savings, especially in light of the significant upfront investments required,” said AHA Executive Vice President Tom Nickels.