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FAH Suggests Improvements to Extreme and Uncontrollable Circumstances Policy

In a letter sent today to CMS Administrator Seem Verma, FAH expressed appreciation for the new Extreme and Uncontrollable Circumstances policy for the Comprehensive Care for Joint Replacement (CJR) Model, which provides relief to the hospitals affected by this year’s disasters.

However, FAH explained how the new rule could be improved if CMS treated fracture and non-fracture episodes the same. The letter states:

“Specifically, we believe episode payments should be capped for non-fracture episodes with an anchor hospitalization that is on or within 30 days before or after the date that the emergency period begins. Such a change is warranted based on the actual experience of our hospitals in the impacted areas..”

FAH also suggested that CMS consider applying a similar policy to the voluntary Bundled Payments for Care Improvement (BPCI) model.

You can find the letter here.