Long Term Acute Care Hospital: Continuity Assessment Record and Evaluation
LTCH facilities collect data through the Continuity Assessment Record and Evaluation (CARE) Data set measures.[i]
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The Improving Medicare Post-Acute Care Transformation Act (IMPACT Act) of 2014 includes numerous provisions aimed at standardizing data collected and reported by post-acute care (PAC) providers, including IRFs, SNFs, LTCHs, and HOME HEALTHs. These include standardized patient assessment data, data on quality measures, data on resource use, and other measures. Data must be standardized and interoperable to allow for the exchange of the information and for the use of such data to enable access to longitudinal information and to facilitate coordinated care. CMS must report back to PAC providers their performance on measures via confidential feedback reports, as well as provide for public reporting.
Such standardized data may serve multiple purposes, including supporting improvement in Medicare beneficiary outcomes; facilitating coordinated care; enabling comparisons across PAC settings; improving discharging planning; and informing payment reforms. With respect to payment reforms, the IMPACT Act also requires the Medicare Payment Advisory Commission (MEDPAC) to evaluate and recommend features of PAC payment systems, or a unified PAC payment system, that establish(es) payment rates according to patient characteristics instead of PAC settings, as well as to offer recommendations and a technical prototype for a PAC prospective payment system by 2023. MedPAC submitted the first report in June 2016, and in its June 2017 Report to Congress, MedPAC recommended that Congress should direct the Secretary of Health and Human Services (HHS) to implement a unified prospective payment system for post-acute care beginning in 2021. However, the MedPAC recommendations are not binding, and Congress has not enacted such changes.
CMS has been moving forward with implementation of the IMPACT Act requirements, including implementing certain standardized quality measures, resource use measures, and standardized patient assessment data elements, as well as providing feedback reports and engaging in public reporting. However, additional work remains – for example, development and implementation of IMPACT Act quality measures related to communicating the existence of and providing for the transfer of health information and care preferences, as well as implementation of additional standardized patient assessment data elements related to cognitive function and mental status; special services, treatments, and interventions; and impairments. While not required under the IMPACT Act, CMS has also taken steps to potentially adjust payments for specific PAC provider types (e.g. skilled nursing facilities and home health agencies) by relying more heavily on patient characteristics rather than their use of services.
Site Neutral Proposal
Lawmakers are considering three site-neutral payment changes that would result in lower payments to hospitals.[ii]
- Paying hospitals for evaluation and management (E/M) services in the hospital outpatient department (HOPD) setting at the physician fee schedule (PFS) amount
- Paying hospitals for 66 specified ambulatory payment classifications (APCs) at the PFS amount
- Capping hospital payments for 12 proposed APCs at the Ambulatory Surgery Center (ASC) rate
This proposal is in an effort to curb costs; however, hospital services are not comparable to a physician office or ASC. To begin with, hospitals require more extensive and therefore more expensive licensing, accreditation, and liability payments. Additionally, hospitals are subject to more extensive regulation. Hospitals provide care services at all hours, every day of the year. Hospitals aim to provide services to vulnerable populations experiencing trauma or during disasters. The costs associated with such events are built into hospital overhead, rather than being charged or reimbursed individually.[iii]