AHA today proposed several recommendations for future episode-based payment models in response to a Centers for Medicare & Medicaid Services request for information to inform potential rulemaking or policies for future bundled payments. Among other comments, AHA said future models should provide transparent, real-time data; be flexible in design, voluntary and adequately long in duration; ensure pricing does not disincentivize efficiency and include guardrails to protect organizations from competing against their own best performance; include adequate risk adjustment and account for social needs; provide upfront incentives to transition to the model and additional risk; waive legal barriers to care coordination; and exempt providers from penalties once they achieve critical thresholds. According to CMS, potential future models will build on lessons learned from models such as Bundled Payments for Care Improvement, BPCI Advanced, and Comprehensive Care for Joint Replacement.

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