Hospital Association to MedPAC: SNF Payment Reduction Harmful to ‘Entire Care Continuum’

With referrals to nursing homes under pressure, thanks to a bottleneck in part caused by the ongoing staffing crisis, hospitals are urging more support for post-acute providers.

The American Hospital Association (AHA), for one, has called for “law updates” when it comes to hospital-based skilled nursing facilities and inpatient rehabilitation facilities (IRFs). AHA on Tuesday sent a letter to the Medicare Payment Advisory Commission (MedPAC) with this recommendation, among others.

AHA refers to MedPAC’s draft recommendation to Congress on Dec. 8 to lower Medicare payments to SNFs by 3% for 2024, and a 3% reduction for IRF Prospective Payment System payments for the same year.

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Such recommendations area familiar refrain for MedPAC; the commission suggested a 5% cut for 2023, citing “rebounded” industry transactions.

“Such a reduction would be harmful to the entire care continuum, but in particular to hospital-based SNFs and their host hospitals,” AHA Senior Vice President of Public Policy Analysis and Development Ashley Thompson said in the letter. “[Post-acute care] providers have stretched beyond their usual capacity to support their acute-care counterparts and maximize care for their communities.”

Hospital-based nursing homes already struggling with razor-thin margins saw “massively negative” margins in 2020 at about -50%, Thompson said in the letter.

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Thompson acknowledged that freestanding SNFs in particular have struggled to control community spread of Covid-19, resulting in infections and deaths. Hospital-based SNFs, meanwhile, have continued to focus on treating medically complex patients in order to relieve capacity issues for the “host hospital,” she added.

Nursing homes, among other post-acute care settings, play a “pivotal role” as part of the entire health care continuum.

“[Post-acute care] providers have helped alleviate acute-care hospital capacity issues, as well as rehabilitated Covid-19 patients facing continued challenges in their recovery,” Thompson said in the letter. “Far from winding down, [post-acute care] providers continue to provide critical support to their acute-care partners as the country faces a potential ‘tripledemic’ of COVID-19 and other respiratory illnesses.”

To drive this point home, the AHA letter showed an increase in patient case-mix, average length of stay and ICU days among patients in post-acute care settings, including SNFs.

Data compares Medicare Fee-for-Service (FFS) patients from Jan. 27 2020 to March 31 2022 versus Nov. 23 2017 to Jan. 26 2020.

Thompson also pointed to comments made by Health and Human Services Secretary Xavier Becerra urging state leaders to continue utilizing Covid-era waivers and flexibilities as these threats converge.

Becerra’s comments fly in the face of what the Centers for Medicare & Medicaid Services (CMS) was saying in October – urging providers to “move forward” as waivers sunset.

Other recommendations in the letter calls for a higher market-basket update beyond MedPAC’s draft to Congress to account for inflation, increasing reimbursement for physicians and introducing add-on payments for safety-net clinicians.

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