CMS has announced recommended increases to key payment systems. The reimbursement increases are to provide better alignment between providers and continued movement toward a unified payment system for the key post-acute care providers, LTACH, IRF and SNF. Data gathering has also undergone further refinement, moving toward the proposed PAC PPS. The proposed new rules for Home Health Agencies are expected to take effect in July, 2019. The following text provides key updates for each of these key areas. In addition, CMS is showing support for hospice and in-patient psych providers through increased payment schedules. These actions by CMS signal continued strong support for post-acute care venues and their importance to America’s healthcare system.

➢   Long Term Acute Care Hospital Payment Increase Update

CMS proposes to increase discharge payments by 2.3% for patients reimbursed under LTC PPS. The proposed FY20 LTACH PPS Standard Federal Payment Rate rises to $42, 950.91. The site neutral payment transition period for cost reporting periods that continued through FY19 will end under the new rules. As such, discharges for cost reporting periods beginning in FY20 will be reimbursed under the site neutral payment rate. The blended rate used during the transitional period will no longer apply.

♦  LTACH Quality Reporting Program

In FY2020 CMS is proposing to adopt two new quality measures relating to the transfer of health information:

  • Transfer of Health Information to the Provider- Post Acute Care (PAC), and
  • Transfer of Health Information to the Patient- Post Acute Care (PAC).

CMS is also proposing the adoption of standardized assessment elements, including:

  • Functional status,
  • Cognitive function and mental status,
  • Special Services,
  • Treatments and Interventions,
  • Medical Conditions and Comorbidities,
  • Impairments,
  • Social Determinants of Health,
  • Race and Ethnicity,
  • Preferred Language and Interpreter Services,
  • Health Literacy,
  • Transportation, and
  • Social Isolation.

➢   Inpatient Rehabilitation Facility Payment Increase Update

In FY20, CMS is proposing an increase of 2.3% over the FY19 rates. The proposed Rehabilitation (IRF) FY20 Standard Payment Base Rate is $16,573. CMS is also recommending a change to the case mix groups (CMGs) based on quality indicator data to start in FY20. CMS will use data from FY17 and FY18 to adjust relative weights and length of stay. CMS is further suggesting two additional changes for assigning payment, by removing one data point for motor score and by applying a weighting factor for motor score.

♦  Quality Reporting Program 

CMS has proposed two new quality measures in FY2020:

  • Transfer of Health Information from SNF to another Provider; and
  • Transfer of Health Information from SNF to the Patient.

CMS is also recommending adoption of standardized patient assessment data elements (SPADEs) that assess the following:

  • Cognitive function and mental status,
  • Special Services,
  • Treatments and Interventions,
  • Medical Conditions and Comorbidities,
  • Impairments,
  • Social Determinants of Health,
  • Race and Ethnicity,
  • Preferred Language and Interpreter Services,
  • Health Literacy,
  • Transportation, and
  • Social Isolation.

➢   Skilled Nursing Facility Payment Increase Update

CMS is proposing a 2.5% increase in FY20 over the previous year’s reimbursement. No base rate number is available because the number varies by geographic location. Effective October 1, 2019, revisions will be made to the SNF PPS with the new Patient Driven Payment Model (PDPM).  Utilizing ICD-10 codes for patient classification, this new structure will focus on the value, and not the volume, of care provided within a patient’s SNF stay.  Under this rule CMS is proposing a sub-regulatory process for making updates to the ICD-10, a process similar to that used under the Inpatient Rehabilitation Facility Prospective Payment System (IRF PPS).

In addition to the above proposed change, CMS is also proposing a change in the definition of group therapy for SNFs. While currently defined as “four patients”, CMS is proposing to adopt the same definition used within the IRF PPS of “two to six patients” undergoing similar activities. Again, the change demonstrates a concerted effort toward establishing consistency among post-acute care providers.

♦  Quality Reporting Program 

In a continued push for increased quality, CMS is proposing two new quality measures in FY2020:

  • Transfer of Health Information from SNF to another Provider; and
  • Transfer of Health Information from SNF to the Patient.

♦  Value Based Purchasing

On October 1, 2018, SNFs began receiving incentive payments based on quality performance under an all-cause measure of hospital readmissions. CMS is proposing to change the name of this measure to “Skilled Nursing Facility Potentially Preventable Readmission after Hospital Discharge”, which maintains the acronym SNFPPR.

CMS is also recommending a change in the requirements for SNFs with less than 25 eligible cases during a baseline period or those with zero eligible cases during a program year.

In addition, CMS is looking to adopt standardized patient assessment data to assess the following:

  • Cognitive function and mental status,
  • Special Services,
  • Treatments and Interventions,
  • Medical Conditions and Comorbidities,
  • Impairments,
  • Social Determinants of Health,
  • Race and Ethnicity,
  • Preferred Language and Interpreter Services,
  • Health Literacy,
  • Transportation, and
  • Social Isolation

➢   Hospice Payment Increase Update

While not part of the proposed Unified Post-Acute Payment System, Advis provides the following update to Hospice providers.

CMS is proposing a 2.7% updated increase to the Hospice payment rates under FY20. The proposed annual cap for Hospice payments for any one patient will be $29,993.99. Under the FY20 proposed rules, CMS would revise the rates for Continuous Home Care (CHC), General Inpatient Care (GIP), and Inpatient Respite Care (IRC). The change is in response to a need to right size reimbursement with cost of care. Part of the proposed payment update includes utilizing concurrent data for the hospice wage index instead of the previous year’s wage index data, as was previously the practice.

CMS is also proposing to amend the election statement required of Hospice patients to include a rationale for items deemed unrelated to the terminal illness.  This change is to ensure those patients electing Hospice care are doing so in an informed manner.

♦  Hospice Quality Reporting Program

Largely unchanged under the FY20 proposed rules, CMS will continue data collection on “Hospice Visits over the Last 7 Days”, but will not publish data related to this measure. CMS will instead review data to determine the need for any additional changes prior to publication.

➢   Inpatient Psychiatric Facilities Payment Increase Update

Under the FY20 IPF proposed rules, CMS is estimating an increase of 1.7% making the Psychiatric (IPF PPS) Federal per diem base rate $803.48. CMS is also proposing to update the data used for the market basket by utilizing the 2016 base year instead of 2012.

♦  IPF Quality Reporting Program

In FY20, CMS is proposing one new measure to begin in FY21 entitled Medical Continuation Following Inpatient Psychiatric Discharge.  This measure will track whether patients with Major Depressive Disorders, Schizophrenia or Bipolar Disorder fill at least one medication within two days before or 30 days after discharge following admission to an Inpatient Psychiatric Facility.

Conclusion

Advis is a national expert in post-acute care services. Advis can assist providers in submitting comments under the proposed new rules; help determine how the proposed rules may impact your facility; or help in exploring interest in establishing a post-acute care venue that may be beneficial to your organization.

Please be advised, the deadline for submitting comments under the proposed rules is as follows:

  • Long Term Acute Care Hospitals- June 24, 2019;
  • Inpatient Rehabilitation Facilities – June 17, 2019;
  • Skilled Nursing Facilities – June 18, 2019;
  • Hospice – June 18, 2019; and
  • Inpatient Psychiatric Facilities – June 17, 2019.

For more information on how Advis can help your organization, please call our office at (708) 478-7030 or contact us at www.advis.com/contact.