[co-author: Katy Appleby]

This most recent delay raises questions concerning how the Trump administration intends to implement value-based payment in the Medicare program.

The Centers for Medicare and Medicaid Services (CMS) has delayed again the implementation date of its final rule mandating hospital participation in two new cardiac episode-based payment models (EPMs) and an expansion of the Comprehensive Care for Joint Replacement (CCJR) program that began in April 2016 (EPM rule). This most recent delay, published in an interim final rule on March 21, 2017, comes on the heels of a February rule in which CMS addressed the impact of the Trump administration’s regulatory freeze and postponed the effective date of many EPM rule provisions until March 2017.

To that end, CMS has now pushed back the effective date of the EPM rule to May 20, 2017, and further delayed the applicability date of the EPM regulations and conforming changes to the CCJR provisions from July 1 to October 1, 2017. Hinting that another postponement might be forthcoming, CMS is also seeking public comment on delaying the applicability date until January 1, 2018. Emphasizing the agency’s commitment to “providing some period of time between establishing the final model parameters and beginning the model,” CMS is seeking to ensure that “participants have a clear understanding of the governing rules” prior to the EPM rule’s ultimate effective date.

This most recent delay raises questions concerning how the Trump administration intends to implement value-based payment in the Medicare program. It could also signal the end of mandatory payment models under the current administration now that Dr. Tom Price, a vocal opponent of mandatory bundles, helms the U.S. Department of Health and Human Services. And while the future of bundled payments remains uncertain, we can be sure that this isn’t the last word from CMS on the topic.