AHA Comments on the CMS’ FY 2019 Proposed Rule For the Long-Term Care Hospital PPS

The AHA supports several of the proposed rule’s provisions. In particular, we appreciate and endorse the agency’s proposal to permanently withdraw the 25% Rule; however, we oppose the associated budget neutrality adjustment proposed by CMS. We also support the proposed changes related to co-located satellite facilities, and the streamlining of the LTCH quality reporting program. In addition, this letter reiterates our concerns related to underpayment for site-neutral cases.