Site-neutral payments for skilled nursing facilities and inpatient rehabilitation facilities should not be considered until the recently passed IMPACT Act has been implemented, a rehab provider association strenuously urged Wednesday in a letter to the Medicare Payment Advisory Commission.
In reports to Congress and in recent testimony to House of Representatives members, MedPAC officials have suggested that equalizing payments for SNFs and IRFs for certain conditions could be sound policy. The panel this week could vote on whether to officially recommend site-neutral payments, which are supported by prominent long-term care associations. The policy would reduce Medicare spending without compromising patient care, the argument goes. The American Medical Rehabilitation Providers Association objected to this line of thinking in its 11-page letter.
It is all but impossible to compare IRF and SNF patient outcomes, because there has been no requirement or framework for the two provider types to report comparable data, AMRPA stated. The Improving Medicare Post-Acute Care Transformation Act calls for this type of standardized reporting, but the law was signed in October and has not yet been implemented. MedPAC should not formally recommend site-neutral payments until the IMPACT Act has gone into effect and outcomes have been assessed, AMRPA wrote. The law calls for standardized data to be submitted beginning in 2019.
The rehab association also described “grave concerns” with the methodology behind MedPAC’s examination of this issue. The site-neutral proposal that has been floated is based on “unsubstantiated data, anecdotal evidence, and a series of flawed assumptions,” according to the letter. Additionally, the association criticized MedPAC for a lack of transparency. At a November meeting, the commission discussed 17 conditions that would be potential candidates for site-neutral payments but did not specifically identify them.
If MedPAC proceeds to recommend site-neutral payments and Congress implements them, patients could suffer, AMRPA warned. It argues that IRFs are subject to hospital-level regulations, while there are “virtually no regulations” to ensure the quality and supervision of rehab provided in nursing homes.
Click here to access the complete letter.