The Centers for Medicare & Medicaid Services (CMS) recently released a proposed rule to update the Medicare fee-for-service (FFS) long-term care hospital (LTCH) prospective payment system (PPS) for fiscal year 2025.
Specifically, the rule proposes:
- Increasing the standard LTCH PPS rate by a net 2.4% from $48,117 to $49,263 for LTCHs that meet the CMS quality program reporting (QPR) requirements. LTCHs that fail to meet these requirements are subject to a two percentage point reduction to the annual update.
- Rebasing the market basket from 2017 to 2022 base year.
- Increasing the high-cost outlier (HCO) threshold by 52% for standard LTCH cases from the current $59,873 to $90,921 to achieve the target of paying roughly 8% of aggregate LTCH payments as HCO payments. This increase will result in a decrease in the number of cases qualifying for an outlier payment.
- Continuing to pay cases at the site neutral rate if they fail to meet LTCH criteria.
- Updating the cost outlier threshold for site-neutral cases to the inpatient PPS threshold proposed at $49,237, up from $42,750.
- Revising core based statistical areas as a result of the new Office of Management and Budget labor market delineations based on the 2020 Decennial Census.
- Updating the LTCH QRP to require reporting of four new items to the LTCH Continuity Assessment Record and Evaluation (CARE) Data Set, (LCDC) social determinant of health category.
- Modifying the Transportation assessment item.
- Seeking responses on two requests for information:
- Quality measure concepts for future years.
- Future LTCH Star rating.
The MHA continues to review the proposed rule and will provide LTCHs with an estimated impact analysis in the next few weeks. The MHA encourages hospitals to review the rule and submit comments to the CMS by June 10 and to notify Vickie Kunz regarding issues identified by May 28.
Members with questions should contact Vickie Kunz at the MHA.