Executive Vice President
American Hospital Association
July 7, 2022
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.
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 Instead, the draft design is largely based on out-of-date patient utilization patterns and patient care protocols.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 the 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.
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