CMMI Requests Input on Upcoming Mandatory Episode-Based Payment Model

A new mandatory bundled payment model is likely on its way in 2026, and the Center for Medicare & Medicaid Innovation (“CMMI”) is seeking input on how to structure the model to work for existing population-based models, including accountable care organizations (“ACOs”).

On July 18, 2023, CMMI released a Request for Information (“RFI”) on a potential new episode-based payment model. The RFI requests input on the design of the model, as well as on care delivery within the model. CMMI’s goal is for the new model to align episodic and longitudinal population-based incentives by building on previous care improvement models.

The CMMI announcement states that “the model would require participation by certain entities, such as Medicare providers or suppliers or both located in certain geographic regions, to ensure that a broad and representative group of beneficiaries and participants is included.” CMMI currently anticipates that the model will be mandatory, in order to “help to overcome voluntary model challenges such as clinical episode selection bias and participant attrition.”

The complete RFI, with all questions and instructions for comment submission, can be found here. Comments must be submitted by August 17, 2023.

Practical Takeaways

  • The new model would be launched no earlier than 2026, giving participants ample time to prepare.
  • The model is likely to include a 30-day episode length, which is shorter than most prior episode payment models, in order to preserve spending reductions while also mitigating inefficiencies that occur as a result of the extended duration of overlap between episode payment models and ACOs.
  • CMMI anticipates making the model mandatory for Medicare providers or suppliers or both located in certain geographic regions. Accordingly, the model will be implemented via notice and comment rulemaking as opposed to voluntary participation agreements.
  • CMMI is focused on including multi-payer alignment, in part to alleviate the burden on providers.

If you have questions related to the RFI or would like assistance preparing comments on the new model, please contact:

Special thanks to Nikkia Jacques, summer associate, for her assistance with the preparation of this article.

Hall Render blog posts and articles are intended for informational purposes only. For ethical reasons, Hall Render attorneys cannot give legal advice outside of an attorney-client relationship.

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