CMS and ASPE issue draft unified post-acute care payment model

The Centers for Medicare & Medicaid Services and the Office of the Assistant Secretary for Planning and Evaluation today issued their report to Congress, in which they presented a draft unified payment model for the four post-acute care settings: long-term care hospitals, inpatient rehabilitation facilities, skilled nursing facilities and home health agencies. The report includes discussion on how Medicare could pay for care provided in these four settings under a single payment system; the Medicare program currently pays for these services through four distinct payment systems.

In the report, CMS/ASPE agree that significant, additional work would be needed to complete their draft model, including possible field testing. In addition, the report highlights that the model was built mostly using data collected prior to the COVID-19 pandemic; since policymakers cannot yet predict costs of care following the pandemic, the model’s effectiveness and impact remain unknown. Further, implementation of a unified post-acute care payment system cannot be done under CMS’s existing statutory authority.
This report was required by law and utilized three technical expert panels of stakeholders, including representatives of the American Hospital Association.

“Today’s draft unified payment model for post-acute care (PAC) under Medicare contains numerous fundamental flaws which render it unworkable for both patients and providers,” AHA Executive Vice President Stacy Hughes said in a statement today.

“Importantly, the draft model lacks a comprehensive and reliable risk adjustment approach, which endangers access to care — particularly for the most critically ill patients. It also fails to reflect both the significant reforms that CMS itself has made to the existing PAC payment systems, as well as the fundamental and long-lasting delivery system changes created by the COVID-19 pandemic. Instead, the draft design is largely based on out-of-date patient utilization patterns and patient care protocols. Additionally, the draft model identifies patients' clinical characteristics using inconsistent definitions and guidelines.

“While CMS and ASPE do not have the authority to implement their draft model, and, in fact, acknowledge that significant policy work remains to complete it, Congress should not consider the model put forth today viable for future action. As we have expressed to the agencies in the past, we remain concerned that the draft model fails to align payments with the costs of treating the widely varied PAC patient population — which is essential to ensure access to quality care. The agencies should go back to the drawing board to create a solution that both reflects the current health care delivery system and ensures access to care for all Medicare PAC patients.”
AHA members will receive a Special Bulletin tomorrow with additional details on this report, as well as an invitation to participate in a members-only virtual meeting to discuss the report and next steps.