The Medicare Payment Advisory Commission’s post-acute care prospective payment system prototype contains fundamental problems that make it unworkable as a foundation for a PAC PPS, AHA told the Department of Health and Human Services today. According to an AHA-commissioned analysis of the prototype by consultant Dobson DaVanzo, shared today with HHS, the prototype relies on outdated, non-representative data from the Centers for Medicare & Medicaid Services’ PAC Payment Reform Demonstration, may be administratively unfeasible and would threaten patient access to care. Based on the analysis, AHA recommends that the Centers for Medicare & Medicaid Services and HHS’ Office of the Assistant Secretary for Planning and Evaluation ensure a transparent process as they develop a PAC PPS, wrote AHA Executive Vice President Tom Nickels. AHA also recommends the agencies use the most currently available cost data to improve the timeliness and accuracy of the model; use a more streamlined approach that allows providers to efficiently and reliably calculate payments; streamline the regulatory framework; and anticipate the impact of alternative payment models.