Patient Access to PAC Services at Risk
The unified post-acute care (PAC) payment system required by the Improving Medicare Post-Acute Care Transformation (IMPACT) Act of 2014 is not on track to protect access to medically necessary PAC services. Rather, the payment system under development disregards the realities of the post-COVID-19 pandemic landscape, and thus will not reflect the actual clinical and resource needs of the modern PAC patient population.
Creating a consolidated payment system that accounts for the medical complexity of the full array of patients treated across the four PAC settings is difficult. In fact, doing so requires taking into account the long-term health care delivery system changes spurred by both the COVID-19 public health emergency (PHE) and the major PAC payment reforms implemented after the IMPACT Act’s passage. To this point, as we near the two year anniversary of the PHE, we understand that if it is actually to function in the real world, the new model must facilitate patient access to the services provided by home health (HH) agencies, skilled nursing facilities (SNFs), inpatient rehabilitation facilities (IRFs) and long-term care hospitals (LTCHs).
The IMPACT Act could not have anticipated the major and sustained influence of COVID-19 and the resulting changes to the overall health care delivery system, including in PAC. However, as we prepare for the postpandemic landscape, Congress must take steps to align the new model with these profound changes, if the IMPACT Act’s goal to produce a unified PAC payment system is to be meaningfully fulfilled. As such, the AHA continues to strongly urge Congress to pass H.R. 2455, The Reset the IMPACT Act, to yield a PAC Prospective Payment System (PPS) prototype that could function in the post-pandemic environment.
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