LeadingAge, VP of Legislative Affairs, Marsha Greenfield

Major long-term care provider groups have offered detailed policy recommendations on reforms to the post-acute care delivery and payment systems, as requested by Congressional lawmakers. 

In addition to offering recommendations on a host of topics, including readmissions penalties for skilled nursing facilities, site-neutral payments and the system of therapy reimbursements, the groups stressed that Congress should evaluate information coming out of current demonstration projects and models before enacting any radical changes.

The groups sent their recommendations yesterday to the House Ways and Means Committee and the Senate Finance Committee. In a June letter, committee leaders asked long-term care stakeholders to submit their answers to dozens of questions on post-acute reform. The due date for responses was Aug. 19.

The nation’s largest provider organization, the American Health Care Association/National Center for Assisted Living, issued an 88-page response. The executive summary lists eight core policy positions. These include: payment models based on quality measures, which in the skilled nursing sector would include 30-day all-cause, risk-adjusted hospital readmissions; use of common assessments, such as the Continuity Assessment Record and Evaluation (CARE) tool; and bundled payments for care across different provider settings. 

With regard to bundled payments and value-based purchasing in particular, AHCA stressed that lawmakers should gather more information before moving forward with particular reforms. Marsha Greenfield, vice president of legislative affairs for LeadingAge, echoed this.

“There’s a lot going on, and a lot we don’t know yet,” Greenfield told McKnight’s. She said demonstrations launched under the Affordable Care Act will provide valuable information, including “what works and what doesn’t work.”

LeadingAge’s response laid out five principles for post-acute payment reform. These include: resolving inequities in the Medicare and Medicaid payment systems to ensure adequate reimbursement for high-quality, innovative care; implementing enforcement mechanisms to ensure that promised reimbursement rates are met; and payment incentives that would encourage scarce resources to be spent on direct care and other services most directly tied to quality.

The National Association for the Support of Long-Term Care critiqued a “one-size-fits-all” approach to therapy reimbursement in its response (part 1, part 2). The current therapy policies, which include annual reimbursement caps, an exceptions process and a manual medical review process, are not working, said NASL Executive Vice President Cynthia Morton.

“They don’t take any acuity into account,” Morton told McKnight’s. “Once you hit a certain dollar amount, you’ve got to jump through these hoops and those hoops. That’s not working for patients in nursing homes.”

CMS data show older patients have more comorbidities and medical complexity, and NASL data show these people need more therapy, Morton said. Therefore, it doesn’t make sense to have a system that treats these high-needs patients in the same way as lower-acuity patients who can drive themselves to an outpatient therapy clinic.

This idea is “not a big headline” to those in long-term care, Morton acknowledged, but she said NASL sought to remind lawmakers that Medicare Part A and Medicare Part B patients are not distinct. 

“They really do, on Capitol Hill, look at these Part B patients as a group on their own,” Morton said. “But a nursing home resident might run out of Part A benefits after 100 days in a SNF, and then the next day they’re under Part B. We remind the committees of that.”