Long-Term Care Hospital PPS: Proposed FY 2021 Rule

At Issue
On May 11, the Centers for Medicare & Medicaid Services issued its fiscal year 2021 proposed rule for the inpatient and long-term care hospital prospective payment systems. This advisory covers the rule’s LTCH-related provisions. Comments on the proposed rule are due to CMS by July 10. A separate advisory will be posted on AHA.org for the inpatient PPS provisions.

Our Take
The AHA appreciates the streamlined LTCH provisions in this rule, relative to prior years, which helps LTCH facilities focus on their COVID-19 responses. We note that in FY 2021, for the first time, no blended payments would apply to LTCH site-neutral cases. We remain concerned that these cases, especially when paid the full site-neutral rate, continue to be materially underpaid – as AHA has shared with CMS and other policymakers.

What You Can Do

  • Share the attached summary with your senior management team to examine the impact these payment changes would have on your organization in FY 2020.
  • Participate in the AHA-member call on this rule on June 10, at 1 p.m. ET. Register in advance here.
  • Submit a comment letter on the proposed rule to CMS by July 10 explaining this rule’s potential impact on your patients, staff and facility.

Further Questions
For questions on this rule, contact Rochelle Archuleta, director of policy, at rarchuleta@aha.org

Key Takeaways

CMS proposes to:

  • Decrease net LTCH payments by 0.9% (-$36 million) in FY 2021, compared to the prior year.
  • Pay all LTCH site-neutral cases a full site-neutral, rather than a blended rate, as required by law.
  • Rebase and revise the LTCH market basket to reflect more current LTCH costs.
  • Update LTCH PPS wage index values.
  • Make no changes to the LTCH quality reporting program.

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