The AHA today expressed serious concern with certain aspects of the Centers for Medicare & Medicaid Services’ proposal for implementing a site-neutral payment component to the Long-Term Care Hospital Prospective Payment System for cost reporting periods beginning on or after Oct. 1, 2015. “We support many of CMS’s proposals, such as how the agency would identify psychiatric and rehabilitation cases and intensive care unit or coronary care unit days, which align with congressional intent,” wrote AHA Executive Vice President Rick Pollack, commenting on LTCH provisions of the proposed inpatient and LTCH PPS rule for fiscal year 2016. “However, we have serious concerns about others, especially the proposal to use the patient discharge status code from prior hospital stays, to, in part, distinguish cases that would be eligible for a standard LTCH PPS payment versus a site-neutral payment. In addition, we have great concern about the proposed policy for site-neutral cases that would receive a high cost outlier payment. We also call for CMS to share its comprehensive plan and timeframe for implementing the numerous new data reporting and other requirements of the IMPACT Act.”