A unified post-acute payment system proposed by the Medicare Payment Advisory Commission is “unworkable as a foundation” the American Hospital Association maintains.

In a letter to Centers for Medicare & Medicaid Services Administrator Seema Verma and Acting Assistant Secretary for Planning and Evaluation John Graham sent last week, the AHA expressed three primary concerns about the prototype. The group backed up its concerns with a commissioned report from consultant Dobson DaVanzo.

Mike Cheek, senior vice president for reimbursement policy at the American Health Care Association/National Center for Assisted Living, said that while the group hasn’t taken an official position on MedPAC’s plan, it “appreciates the Commission’s work to modernize the payment system” and looks forward to providing input as development of the system continues. LeadingAge officials had no comment on AHA’s take on the plan.

AHA’s most pressing concern is the proposed model’s use of Post-Acute Care Payment Reform Demonstration data, which was “collected using a flawed tool and methodology” and has become outdated.

“Based on this data concern alone, we urge CMS and ASPE not to rely on the prototype as the basis for their work,” AHA Executive Vice President Tom Nickels wrote.

The AHA also took issue with the plan’s regression-based design, and a potential to jeopardize patients’ access to care and payment accuracy.

The group recommended CMS and ASPE engage in a “transparent” development process of the new post-acute care payment system; ensure payment access to services; use the most up-to-date cost data; streamline the payment system to achieve payment predictability; integrate any needed regulatory changes with implementation of the new system; and anticipate the impact alternative payment models may have on the model.

“Given the magnitude of the problems identified with the MedPAC prototype, we encourage CMS and ASPE not to rely on it as they conduct their PAC PPS development Process,” Nickels said. “Its limitations prevent confidence in its accuracy and reliability, and should rule out its use as a basis of a new PAC PPS payment model.”