LTCH Update. Policy & Federal Relations. June 2014

Transcription

1 LTCH Update Policy & Federal Relations June 2014

2 2 Overview: Legislative Update Regulatory Update AHA Webinar Series

3 3 AHA Member Calls Member Calls on FY 2015 Post-Acute Proposed Rules LTCH: Thu, June 5, 1:00ET IRF: Thu, June 5, 3:00ET SNF: Fri, June 6, 1:00 ET AHA Regulatory Advisories available at Please to register.

4 4 Legislative Update

5 Legislative Outlook No grand bargains No entitlement reform No tax reform No significant deficit reduction But, still have many issues on the table Legislative: associated with various cliffs or deadlines New budget addiction Executive action

6 PAMA s Post-Acute Provisions ICD-10-CM delayed Realigns Medicare sequester at 4 percent for first 6 months of FY 2024 (Saves $4.9 billion) SNF Value-Based Purchasing Program (Saves $2.0 billion) LTCH Criteria Technical Corrections (Spends $100 million Changes to the 50% Compliance Test Medicare Fee-for-Service patients only Moratorium Exceptions Limit key site-neutral payment provision Additional changes still needed

7 IMPACT Act Highlights Framed as creating building blocks of post-acute care reform through collection and reporting of: Standardized patient assessment data Standardized quality measures Significantly expands data collection and reporting requirements for LTCHs, IRFs, SNFs and HHAs Payment penalties for non-reporting Introduces post-acute care related data reporting requirements for general acute care hospitals Requirements phased in over time

8 AHA s Take Support the direction of the bill with cautions Remove hospital reporting requirement Ensure the feasibility of PAC patient assessment data & the suitability of PAC quality measures

9 Bundled Payment Proposals BACPAC (HR 4673 ) Mandatory program Post-acute only bundled payment Multiple types of conveners 90 day episode Est. savings by ensuring overall spending doesn't exceed [100 minus X]% over a 10-year period Comprehensive Care Payment Innovation Act (H.R. 3796) Voluntary program Bundle across inpatient and post-acute care Hospital convener? 90 day episode Est. savings as an alternative pay model under SGR Rep. Black Rep. McKinley

10 10 Regulatory Update

11 FY 2015 LTCH PPS Proposed Rule AHA MEMBER CALL: Thursday, June 5 at 1:00ET COMMENTS Due June 30 Net update of 0.8% (+$44m) o +2.7% market basket o -0.4% productivity cut (ACA) o -0.2% (ACA) o -1.3% (final of 3 BNA cuts) Interrupted Stay Change ICD-10 delayed until October 2015 BiBA/PAMA Provisions o 25% Rule relief; o Moratorium; and o HCC returning to TEFRA o Requests Feedback on Site-Neutral Rollout (Oct 2015) o HCC/TEFRA payments o LTCH Quality Reporting 11

12 LTCH Interrupted Stays Interrupted Stays Up to 3 days Interrupted Stays 4 days Within Threshold Interrupted Stays Beyond Threshold 1 LTCH payment LTCH covers costs from interrupted stay The off-site days count for the LTCH LOS. 1 LTCH PPS payment Other provider bills separately Thresholds: IPPS: 4-9 days IRF: 4-27 days SNF: 4-45 days 2 LTCH PPS Payments Other provider bills separately Proposed Change: Common Threshold of 30 days Impact of Proposed Change: Cases day interruption only eligible for 1 LTCH Payment 12

13 FY 2015 LTCH PPS Proposed Rule BiBA/PAMA Provisions 25% Rule relief 4 years of relief from Moratorium April 1, 2014 through Sept 30, 2017 Reinstates MMSEA exceptions No exceptions for bed expansions Calvary LTCH TEFRA-like adjustment beginning FY

14 14 AHA Comment Letter TOP ISSSUES BiBA Site-Neutral Reforms How to weight LTCH claims How to structure outlier payments Interrupted Stays Proposed new function QMs Other?

15 15 LTCH Quality Reporting Program

16 Long-Term Care Hospital Quality Reporting (LTCHQR) Submit quality measures for FY 2014 Compliance is tied to 2 percent of the annual update Measure Central-Line Associated Blood Stream Infection (CLABSI) FY FY FY FY FY X X X X X Catheter-Associated Urinary Tract Infection (CAUTI) X X X X X Percent of nursing home residents with pressure ulcers X X X X X that are new or worsened Percent of nursing home residents who were assessed and appropriately given the seasonal influenza vaccine Influenza vaccination coverage among healthcare personnel Methicillin-resistant Staphylococcus aureus (MRSA) bacteremia X X X X X X Clostridium difficile (C Diff) X X Unplanned all-cause, all condition readmissions within X X 30 days to LTCHs. Percent of residents experiencing one or more falls with major injury (Long stay) Functional Status: Percent of LTCH Patients with an Admission and Discharge Functional Assessment and a Care Plan that Addresses Function Functional Status: Change in mobility among LTCH patients requiring ventilator support Ventilator-Associated Event Outcome Measure X X X P P P X = Previously Finalized P = Proposed

17 LTCHQR Proposals Measure Updates Patient flu vaccination measure CMS proposes that LTCHs report the measure at the same submission deadlines as other LTCH CARE data set measures Payment Determination Data Collection Timeframe Data Submission Deadline FY 2016 Oct. 1, 2014 Dec. 31, 2014 Feb. 15, 2015 Jan. 1, 2015 Mar. 31, 2015 May 15, 2015 FY 2017 Oct. 1, 2015 Dec. 31, 2015 Feb. 15, 2016 Jan. 1, 2016 Mar. 31, 2016 May 15, 2016 Falls with Major Injury Measure collection delayed until Apr. 1, 2016 to accommodate planned updates to LTCH CARE data set Thus, for FY 2018 payment determination, CMS would require only 3 quarters of data But would be 4 quarters for FY 2019

18 FY 2018 LTCHQR Measure Proposals: Ventilator-associated events (VAEs) Assesses the rate of several healthcare associated infections (HAIs) associated with mechanical ventilator support Included infections: Ventilator-Associated Pneumonia (VAP) Pulmonary edema Acute respiratory distress syndrome Sepsis Atelectasis Would be reported using the CDC s NHSN Not yet-nqf endorsed, but supported by the MAP

19 FY 2018 LTCHQR Measure Proposals: Functional Status Assessments Assesses the percentage of LTCH patients who have functional status assessments completed on admission and discharge and that have care plan assessing function Does not measure functional status change, just completion of assessments LTCH CARE data set would be updated with appropriate items to collect assessments Clinicians score level of independence on self-care, mobility, cognition, communication and continence items To demonstrate a care plan assesses function, at least one assessment item needs a numerical goal Not NQF-endorsed, and MAP urged additional development

20 FY 2018 LTCHQR Measure Proposals: Change in mobility function Assesses the change in mobility functional status scores between admission and discharge for patients on ventilator support Data derived from mobility functional status scores collected using LTCH Care Data set Score would be risk-adjusted to permit comparisons LTCH CARE data set would incorporate information to perform risk adjustment Measure still under development, and not NQFendorsed. MAP also urged additional development

21 Proposed Data Completeness Requirements (for FY 2016 payment) CMS proposes thresholds for data completeness under its authority to require measure submission in a form, manner and time designated by the Secretary of HHS LTCHs that do not meet requirements subject to 2 percent reduction to annual payment update CMS would require 80 percent complete data for LTCH CARE data set items That is, 80 percent of assessments include 100 percent of required quality data items CMS would require 100 percent complete data for HAI measures submitted via NHSN Must complete all data fields required for measure numerator and denominator

22 LTCHQR Measure Validation Proposal (for FY 2016 payment determination) CMS will validate only the pressure ulcer measure, but indicates interest in expanding to other measures Process CMS randomly selects sample of 260 LTCHs each year CMS randomly selects 5 LTCH CARE assessments from each LTCH in the validation sample CMS contractor sends written request to LTCHs to submit patient medical record information Contractor compares data elements in patient record to data submitted on the LTCH CARE assessment LTCHs must achieve 75 percent validation score to avoid 2 percent reduction The reconsideration process for LTCHQRs updated to provide chance for LTCHs to appeal findings of noncompliance

23 LTCHQR Proposals: Discussion questions Do you support CMS s FY 2018 measurement proposals? How could they be improved? Do you support the data completeness and validation proposals? Are the thresholds fair? Is there other information CMS should provide to educate the field on its process? What other measurement topics should CMS address in future years? 27

24 24 AHA Webinar Series

25 25 AHA Webinar Series: Emerging Partnerships Between General Acute-Care Hospitals and Post-Acute Providers WEBINAR SERIES Provide a policy context Highlight innovations in the field Hospital perspective PAC perspective Discussion with lead innovators AHA members may register at: com/s/njqsbfs

26 26 Questions & Discussion

27 27 References On Recent Legislative Changes for LTCHs

28 LTCH Provisions in Bipartisan Budget Act Two-tiered payment system: Begins with cost reports starting on or after Oct 1, LTCH PPS Payment Criteria: 1. Cases immediately transferred from the IPPS hospital to an LTCH that received 3+ ICU/CCU days in IPPS Hospital; OR 2. Cases immediately transferred from the IPPS hospital to an LTCH, which were later discharged from the LTCH with an MS-LTC-DRG for 96+ hours of ventilator services. Site-Neutral Treatment of Non-LTCH PPS Cases Site-Neutral Cases: Cases not meeting LTCH PPS criteria and discharges with a psychiatric or rehabilitation principal diagnosis; Cases would be paid lesser of IPPS per diem rate (plus outlier) or 100% of cost. Cases would be removed from 25+ -day ALOS requirement. Phase-in: Blended payment for two years. (FYs 2016 & 2017: 50% site-neutral + 50% LTCH PPS.) LTCH Facility Cap: 50+% of all discharges must be paid LTCH PPS by FY 2020, and thereafter, or all payments in subsequent year drop to IPPS rate. (Still studying this provision.) 25% Rule 4 Years of Relief: Cost reporting periods beginning from Oct 1, 2013 through Sept 30, 2017; Hospital-within-hospital LTCHs: 50 percent threshold; Rural and MSA-dominant LTCHs: 75 percent threshold; Freestanding LTCHs: No 25% Rule during relief period; Grandfathered LTCHs: Permanent exemption from policy. 2+-year moratorium on LTCH facilities/beds. Jan 1, 2015 Sept

29 29 LTCH Provisions in PAMA LTCH DISCHARGE CAP Modifies the BiBA requirement that at least 50 percent of an LTCH s discharges must be paid under the LTCH PPS for cost reporting periods beginning in fiscal year (FY) Specifically, the PAMA clarifies that no more than 50 percent of an LTCH s Medicare fee-for-service discharges may be paid a site-neutral rate, or the LTCH will be paid the inpatient PPS rate for all discharges for future cost reporting periods. LTCH MORATORIUM Accelerates BiBA s start date of the LTCH moratorium on new facilities, satellites and beds from Jan. 1, 2015 to April 1, Re-instates the MMSEA moratorium exceptions for LTCH hospitals and satellites. No moratorium exceptions were granted for LTCH bed expansions. RESTRICITON FOR NEW LTCHS Limits regulatory relief for site-neutral cases for only LTCH certified as of Dec. 10, Specifically, LTCHs certified on or after this dates will not be allowed to exclude site-neutral and MA cases from their annual average length-of-stay calculation for cost reporting periods that begin on or after Oct. 1, 2015.