Stop the 'siloed' policy making for skilled nursing

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Alliance President Alan Rosenbloom
Alliance President Alan Rosenbloom
Last week, three reports issued by three separate government agencies made incongruent recommendations — or no recommendations at all — related to skilled nursing facility (SNF) patient care and policy. This spotlights precisely how federal policymaking is hampered by “siloed thinking.”

The reports, from the Medicare Payment Advisory Commission (MedPAC), the Centers for Medicare & Medicaid Services (CMS), and the Medicaid and CHIP Payment and Access Commission (MACPAC), demonstrate the need for governmental agencies to think more holistically about federal policies governing SNF care, and how those policies affect patients.

Because Medicare and Medicaid together pay for the care of three out of every four SNF residents, it is crucial to look at the impact both programs have on the ability of providers to deliver high quality care. MedPAC's recommendation of no SNF market basket increase for FY 2013 fails to consider carefully enough SNFs' modest – and decreasing – overall margins. But MedPAC's analysis of Medicaid and overall margins is a very positive step toward a more holistic evaluation of SNF payments.

MedPAC and CMS also independently put forward ideas for reducing SNF rehospitalizations. While both ideas are worthy of attention, the divergent nature of the approaches points to the need for more collaborative policy making activity.

MACPAC — the agency charged with making Medicaid recommendations — did not address the elderly long-term care population at all in its report, despite the significant proportion of SNF patients who rely on Medicaid. However, the commission is expected to put forward recommendations on dual eligibles — a report that is expected to focus attention on the needs of SNF patients. We look forward to these recommendations.

Moving forward, all three agencies should examine opportunities to improve policy in the post-acute care arena. Rather than simply reducing Medicare cost-of-living adjustments at a time when the cost of providing care is increasing substantially — and often due to government policy itself — policymakers should consider taking steps toward equalizing payments for certain resident conditions in post-acute settings.

Rationalizing post-acute payments could save scarce government dollars without undercutting our caregiving infrastructure, for example.

SNFs were already slated to absorb $48 billion in Medicare reductions between fiscal years 2012 to 2021, before considering the additional cuts included in the recent payroll tax deal, or the impact of sequestration — which will reduce Medicare payments an additional 2% effective Jan. 1, 2013.

Instead of returning again and again to budget cuts, we must end siloed policymaking for the benefit of seniors, our workforce, and the public at-large.

After all is said and done, MedPAC, CMS and MACPAC have put forward thoughtful policy ideas, and we look forward to working with them to make recommendations and enact policies that will support quality, ensure access, reduce costs and stabilize the tenuous state of SNF economics.

2012 can and must be the year to ensure our most vulnerable are the beneficiaries of coordinated governmental policymaking.

Alan G. Rosenbloom is president of the Alliance for Quality Nursing Home Care. The group is a coalition of 12 leading post-acute and long term care organizations that provide quality skilled nursing care to American seniors and disabled individuals in approximately 1,400 facilities and 44 states nationwide.

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