At Issue

On Aug. 2, 2021 the Centers for Medicare & Medicaid Services (CMS) issued its fiscal year (FY) 2022 final rule for the inpatient and long-term care hospital (LTCH) prospective payment systems (PPS). This advisory covers the rule’s LTCH-related provisions. We issued a separate advisory on the inpatient PPS provisions.

Our Take

The AHA appreciates that the agency took a relatively streamlined approach to the LTAC provisions in this rule. This will help LTCH facilities focus on their COVID-19 responses and not on modifying operations to comply with substantial changes in policy. This is particularly important given recent surges of the virus, as well as AHA’s analysis that found that in December 2020, 1 out of 2 LTCH patients had or were recovering from the virus. In addition, we note that since LTCH site-neutral cases are no longer being paid a blended rate, some LTCHs continue to struggle with the Medicare payment amount. Specifically, Medicare on average continues to underpay materially for this population of cases, as AHA has shared with CMS and other policymakers on many occasions. With regard to quality, while AHA suggested an incremental — rather than immediate — implementation of the COVID-19 vaccination-among-health care personnel (HCP) measure, we plan to work with our members and CMS to gather this important data without unnecessarily increasing burdens on providers.

Key Resources

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