The AHA today urged further study before the Medicare Payment Advisory Commission votes on a recommendation that Congress implement a unified post-acute care (PAC) prospective payment system (PPS) by 2021.

 “We appreciate the thoughtful work MedPAC has completed thus far on PAC PPS issues,” wrote AHA Executive Vice President Tom Nickels. “However, we urge that, prior to voting on its recommendation, the Commission collect more information about the feasibility and advisability of removing five or more years from the statutory timeline for creating and operationalizing a new payment system.”

The 2014 Improving Medicare Post-Acute Care Transformation Act calls for Medicare to develop a common PPS that could replace the separate payment systems for home health, skilled nursing facilities, inpatient rehabilitation facilities and long-term care hospitals, but does not authorize its implementation.

Under the Act’s current development timeline for a PAC PPS, MedPAC estimates the earliest the new system could be proposed by Congress is 2024.

“The draft recommendation under consideration would truncate this timeline by authorizing the implementation of a PAC PPS by 2021, which staff estimated would require the introduction of a proposal to Congress in 2018 or 2019,” the AHA notes. “Yet, the design, testing and validation of this PPS have only just begun under the leadership of the Centers for Medicare & Medicaid Services and Assistant Secretary for Planning and Evaluation.”

The commission is scheduled to consider the draft recommendation when it meets next week.