The AHA today submitted comments on the long-term care hospital payment and quality reporting provisions included in the Centers for Medicare & Medicaid Services’ proposed rule for the hospital inpatient and LTCH prospective payment system for fiscal year 2019. “The AHA supports several of the proposed rule’s provisions,” the association said. “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.” According to AHA’s analyses, Medicare pays LTCHs less than half the cost of care for site-neutral cases, even though the average acuity level and cost of care are far higher for these cases.

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