When it comes to bundling payments for post-acute care, the AHA Thursday told Congress that now is the time for learning through testing new small-scale payment and delivery models, rather than drawing broad conclusions as reflected in the recently introduced Bundling and Coordinating Post-Acute Care Act, or BACPAC.

“Now is the time to dedicate resources toward building the knowledge base needed to improve our health care delivery system by testing new models on a small scale and using the lessons learned to develop proposals before considering widespread adoption and implementation,” the AHA said in an April 16 statement submitted to the House Energy & Commerce Health Subcommittee hearing on BACPAC.

The bill, H.R. 1458, proposes a condition-related group (CRG) payment system for post-acute care along the lines of the diagnosis-related groups used by hospitals. These CRGs would involve clinical condition-specific, bundled payments. 

Hospitals, insurers, post-acute care providers or third-party groups would be eligible to act as coordinators that establish networks of post-acute care providers to deliver the serviced covered in BACPAC’s bundle: skilled nursing facilities, inpatient rehabilitation facilities, long-term care hospitals, home health agencies, durable medical equipment, outpatient physician and occupational therapy, and outpatient drugs and biologicals.

The coordinator would manage a patient’s care for a 90-day period beginning with the patient’s discharge from a general acute-care hospital. For an eight-year period beginning in fiscal year 2020, payments to a bundled payment coordinator would be reduced to 96% of what the payments would have been under Medicare fee-for-service. Any further savings generated through care coordination or other means would be shared by the coordinator, providers of bundled services, the physician, and, if no readmission occurs, the referring hospital.

In its statement to the House health care panel, the AHA said it supports several elements in the bill. But the association expressed concern over its “potential to preempt valuable work already undertaken in this area; its reliance on the ‘Continuity Assessment Record and Evaluation (CARE) Tool’ as a patient assessment instrument; and its inappropriate adjustment for readmissions.”

The AHA noted the bundled payment demonstrations that are taking place through the Center for Medicare and Medicaid Innovation, and suggested it would be better to learn from those models and apply that knowledge before embarking on comprehensive legislation. “These new insights will help shape the ongoing re-tooling of bundling, shared savings and other innovations that are in the testing stage,” the AHA observed.  


Concerns with CARE Tool. The AHA questioned the bill’s use of the CARE Tool as a patient assessment instrument. Developed as part of the Medicare Post-Acute Care Payments Reform Demonstration, the tool measures the health and functional status of Medicare beneficiaries when they are discharged from acute-care hospitals and measures changes in severity and other outcomes for post-acute care patients.   

The AHA said the tool is not designed to recommend “the most clinically appropriate placement post-hospitalization. In addition, it has been widely criticized for its length and for its inability to capture the full spectrum of medical acuity for post-acute are patients.”  The association added that many hospitals have developed their own patient discharge tools designed to reduce variation in post-hospital placement and avoidable readmissions.


Readmissions. The bill would reduce the amount of the bundled payment by the amount paid for a 90-day readmission to the hospital. The AHA called that adjustment “inappropriate and unnecessary.” It would rather see the bill focus on those readmissions that are preventable.

For more on the AHA’s statement, visit www.aha.org/testimony.