Earlier this summer the Centers for Medicare & Medicaid Services (CMS) and the Center for Medicare and Medicaid Innovation proposed a new “Comprehensive Care for Joint Replacements Model” (CCJR) program designed to foster better coordination of services and efficiency in the delivery of knee and hip replacements.

In a formal comment letter to CMS, the National Association of Urban Hospitals expressed support for the concept underlying the program but expressed concern about five specific aspects of the proposed program:

• the program’s savings assumptions
• the assignment of virtually all risk to hospitals
• the breadth of services for which hospitals would be at risk
• the program’s lack of socio-economic risk adjustment
• the inclusion of non-elective joint replacement procedures