The draft version of a unified Medicare payment model for post-acute care contains “numerous fundamental flaws.”
That’s according to a statement issued late last week by the American Hospital Association (AHA).
Among those flaws, AHA cited the lack of a workable risk adjustment approach and missing reforms outlined by the Centers for Medicare & Medicaid Services (CMS).
The draft payment model is based on out-of-date patient use patterns and care protocols, according to Stacey Hughes, executive vice president of AHA – fundamental and long-lasting delivery changes created during the pandemic were not included.
Such flaws render the proposed model “unworkable” for patients and providers, Hughes said in the statement, adding that Congress should not consider it as a viable option in its current form.
CMS and the Department of Health and Human Services Assistant Secretary for Planning and Evaluation (ASPE), with their contractor RTI International, were tasked with developing a new payment model for post-acute care services as part of the Improving Medicare Post-Acute Care Transformation (IMPACT) Act of 2014.
RTI released its most recent draft of the model this month in a report to Congress.
The model attempts to merge four Medicare prospective payment systems (PPS) into one – the SNF PPS, along with systems for home health, long-term care hospitals (LTCH) and inpatient rehabilitation facilities (IRF).
Essentially, the model would be a drastic overhaul to how Medicare pays for post-acute care services.
As it stands, the model doesn’t align payments with the costs of treating an increasingly diverse post-acute care patient population.
Even CMS and ASPE acknowledge their draft model still needs significant work.
“Although we believe that the clinical concepts and analytic approach upon which the prototype is based are sound, it will be important to understand the implications for costs of care of COVID-19 and the revised payment systems, and to recalibrate the payment weights accordingly,” respective parties said in their report to Congress.
Other factors like unified cost-sharing rules and the value-based purchasing (VBP) program will need to be considered too, according to CMS, ASPE and RTI.
“The agencies should go back to the drawing board to create a solution that both reflects the current health care delivery system and ensures access to care for all Medicare PAC patients,” said Hughes.
The association raised concerns about the prototype PAC payment model in August 2021 as well, specifically RTI’s use of data from 2017 to 2020 to design the model.
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