KHA comments on CMS’s site-neutral LTCH PPS proposal
Thursday, June 25, 2015 9:00 AM
Last week, KHA expressed serious concern with certain aspects of the Centers for Medicare and Medicaid Services’ (CMS) proposal for implementing a site-neutral payment component to the Long-Term Care Hospital (LTCH) Prospective Payment System (PPS) for cost reporting periods beginning on or after October 1, 2015.
“KHA supports many of CMS’s proposals, such as the proposal to use a specific 15 Medicare-severity-LTC-diagnosis-related groups to identify the psychiatric and rehabilitation conditions that would be paid a site-neutral rate versus a standard LTCH PPS rate, and KHA supports the proposal to use the previously finalized pressure ulcer measure to meet IMPACT Act requirements,” wrote KHA Membership Services Director Pam Kirchem, commenting on LTCH provisions of the proposed inpatient and LTCH PPS rule for fiscal year 2016. “However, we believe that the proposed two outlier-related budget neutrality adjustments are unwarranted and result in inappropriately lower LTCH payments. We recommend CMS calculate standard LTCH PPS and site-neutral rates separately.”
In addition, KHA opposes the proposed use of inpatient PPS discharge status codes to, in part, identify cases that were immediately discharged from an inpatient PPS hospital to an LATCH, because PPS discharge status codes are highly unreliable and would result in the systematic undercounting of cases eligible for a standard LTCH PPS rate thus penalizing LTCHs for unintentional data inaccuracy. KHA strongly encourages CMS to develop and make publicly available a comprehensive plan describing how it will implement the provisions of the IMPACT Act in all of its post-acute care quality programs.
A copy of the comments is available on the Policy Issues page of the Members Only section of www.kyha.com.
For further information, contact Pam Kirchem at KHA (firstname.lastname@example.org).