Proposal Would Delay Quality Reporting for Long-term Care, Inpatient Rehab Facilities

The Centers for Medicare & Medicaid Services (CMS) recently included proposals related to the quality reporting programs for long-term care hospitals (LTCHs) and inpatient rehabilitation facilities (IRFs) in its proposed rule to update the Medicare fee-for-service prospective payment system for home health agencies (see related article). LTCHs and IRFs were initially scheduled to begin reporting two new quality measures Oct. 1, 2020, including Transfer of Health Information to the Provider and Transfer of Health Information to the Patient, as well as several standardized patient assessment data elements (SPADES).

Due to the COVID-19 public health emergency (PHE), the CMS declined to release updated versions of the patient assessment tools necessary for reporting this information and delayed the compliance date for reporting these items until Oct. 1 of the year that is at least one full fiscal year after the end of the COVID-19 PHE. The CMS proposes to require reporting of these measures and SPADES beginning Oct. 1, 2022, since COVID-19 cases and deaths have declined. The MHA encourages LTCHs and IRFs to submit comments to the CMS regarding this provision by Aug. 27. Members with questions should contact Vickie Kunz at the MHA.

Medicare Long Term-Care Hospital Prospective Payment System Proposed Rule Released

The Centers for Medicare & Medicaid Services (CMS) recently released a proposed rule to update the Medicare fee-for-service long term-care hospital (LTCH) prospective payment system (PPS) for fiscal year (FY) 2022. Provisions of the proposed rule would take effect Oct. 1, 2021, unless otherwise noted and would:

  • Provide a net 2.4% increase to the LTCH standard operating rate, after budget neutrality, for facilities that comply with the CMS quality reporting program (QRP) requirements.
  • Continue to pay all site-neutral cases at the full site-neutral rate, instead of the prior 50/50 blend of LTCH PPS and site-neutral rates. The CMS projects that site-neutral payments would account for 10% of all Medicare payments to LTCHs in FY 2022.
  • Adapt certain methodologies used to calculate the annual payment update to account for the impact of the COVID-19 public health emergency (PHE). Specifically, the CMS proposes to use pre-PHE data from FY 2019 to set the FY 2022 payment rates.
  • Increase the high-cost outlier threshold by 20% from $27,195 to $32,680 for cases paid at the standard LTCH rate. The outlier threshold for cases paid at the site-neutral rate would continue to mirror the inpatient PPS outlier threshold, proposed at $30,967.
  • Seek input via a formal request for information on closing the health equity gap in CMS quality programs. Specifically, the CMS seeks input on ways to revise several related CMS programs to make reporting of health disparities based on social risk factors, race and ethnicity more comprehensive and actionable for hospitals, providers and patients.
  • Expand the LTCH QRP to assess the rate of COVID-19 Vaccination Coverage Among Health Care Personnel measure.
  • Update the denominator of the Transfer of Health Information to the Patient (TOH-Patient) measure to exclude patients discharged to their homes under the care of a home health agency or hospice.
  • Begin public reporting for two quality measures affected by the COVID-19 reporting exemptions.

The MHA will provide LTCHs with an impact analysis in the coming weeks. The association encourages LTCHs to review the proposed rule and submit comments to the CMS by June 28. A final rule is expected by Aug. 1 for the Oct. 1 effective date.  Members with questions should contact Vickie Kunz at the MHA.

CMS Releases Final Rule for Long Term Care Hospitals

The Centers for Medicare & Medicaid Services (CMS) recently released a final rule to update the Medicare fee-for-service long term care hospital (LTCH) prospective payment system (PPS) for fiscal year (FY) 2021, which begins Oct. 1. Key information from the final rule includes:

  • Providing a net 2.5% increase in the standardized operating rate for cases that meet clinical criteria for services provided at LTCHs that successfully comply with the LTCH quality reporting program (QRP) requirements.
  • Paying all site-neutral cases, defined as cases that do not meet the established clinical criteria, at the site-neutral rate, rather than based on a 50/50 blend of the LTCH PPS and site-neutral rates. Site neutral payments rates are the lower of the inpatient PPS-comparable per-diem amount, including any outlier payments, or 100% of the cost of the case.
  • Rebasing and revising the LTCH marketbasket to reflect more current LTCH costs.
  • Updating the wage index values used for the LTCH PPS, including a 5% stop loss provision to ensure that the wage index for each facility is at least 95% of its FY 2020 value.
  • Making no changes to the LTCH QRP.

The MHA will provide a hospital-specific analysis and a summary of the final rule within the next few weeks. Due to the pandemic, the CMS waived the typical timeline that requires release of a final rule by Aug. 1. Members with questions should contact Vickie Kunz at the MHA.