Industry Insights

CJR Bundle Participants – Hospital Compliance Surveys Out Now

July 2018
Author:  Randy Biernat

Randy Biernat

Partner

Consulting

201 N. Illinois Street, Suite 700
P.O. Box 44998
Indianapolis, IN 46244-0998 (46204)

Indianapolis
317.383.4000

On July 10, 2018, the Centers for Medicare & Medicaid Services began issuing participant hospital compliance surveys related to its mandatory bundled payment initiative, the Comprehensive Care for Joint Replacement Model (CJR).

Based on a copy of the survey we obtained, questions related to five key areas include:

  • Type and nature of policies and procedures related to the CJR program’s operational elements
  • Governing body oversight
  • Beneficiary incentives
  • Beneficiary choice and notifications
  • Sharing arrangements

The heaviest emphasis in the survey appears to be on gathering information on business practices related to beneficiary choice and notifications and sharing arrangements with CJR collaborators.

Responses to the compliance survey are due August 3, 2018.

In analyzing the survey, there are very few requests for formal documentation to support the indicated answers. However, survey responses that indicate a lack of policies and procedures related to key areas of the CJR program may trigger follow-up request letters for additional information or other further inquiry.

If your organization needs assistance in responding to this survey or would like BKD to perform substantive procedures and/or a “mock audit,” contact Randy or your trusted BKD advisor.

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