The Health Care Incentives Improvement Institute (HCI³) isn’t happy about a new proposed regulation by CMS, which HCI³ thinks would limit the its ability to improve care and budget patient treatment.

In response, HCI³ released a statement today recommending CMS not implement new episode payment models for acute myocardial infarction, coronary artery bypass graft and surgical hip/femur fracture treatments.

HCI³is a nonprofit organization based in Newtown, Connecticut, that works to improve healthcare while ensuring it remains affordable. The letter to CMS was written by François de Brantes, HCI³’s executive director.

"In building these new payment episodes upon MS-DRG codes and centering the care on hospitals, CMS is significantly limiting the opportunity to improve care or effectively budget for each patient's treatment, two things the best episode-based programs can do very well," de Brantes said in a statement. "Well-designed episode-based payment programs, such as the ones described in a recent Health Care Payment Learning and Action Network (HCPLAN) report, engage physicians in taking accountability for the management of patients. CMS should stop its continued attempts to focus on facility-based episodes and apply the important recommendations of the HCPLAN."

HCI³also expressed concerns over who is allowed to initiate and control episode payment models (EPM). Current rules say that only facilities can do so, which makes it more difficult to engage clinicians, who are the ones giving care and keep affordability in mind. Additionally, the EPM model doesn’t include the ability to adjust for a particular patient’s needs, including the severity of their illness.

Instead, HCI³ is proposing an alternative episode-based payment methodology that would avoid many of the problems they have expressed discontent for.

To read the full plan, click here.