The American Hospital Association has informed the Medicare Payment Advisory Commission that it supports "cautious exploration" of a site-neutral payment policy for inpatient rehabilitation facilities and skilled nursing facilities.
The AHA would only support such a policy if it applied exclusively to patients who are clinically similar and could be treated safely in either a SNF or IRF setting, according to a letter to MedPAC written by Linda Fishman, AHA senior vice president of public policy analysis and development.
Ms. Fishman wrote in response to a March presentation MedPAC gave on potential site-neutral payment approaches for IRFs and SNFs. "We are concerned that MedPAC has not targeted appropriate patients and urge the commission to refine its approach," she wrote.
The AHA recommends that MedPAC use the most recent data available when comparing the mix of patients treated in more than one post-acute care setting. Additionally, the AHA wants MedPAC to refine its analysis so it doesn't rely only on the prior acute-care hospital discharge diagnosis to identify similar IRF and SNF patients.
Additionally, Ms. Fishman wrote any site-neutral payment policy should include "robust" risk adjustment and factor in longer average lengths of stay at SNFs. The AHA also urges MedPAC to only apply site-neutral payments to lower-acuity conditions that aren't encompassed by the IRF 60 percent rule. That rule specifies at least 60 percent of an IRF's total inpatient population must require treatment for one or more of 13 medical conditions, such as stroke, spinal cord injury and major multiple trauma.
The AHA also recommends that MedPAC ease Medicare requirements for IRFs if site-neutral payments are enacted. "Current Medicare statutes and regulations require IRFs to provide hospital-level care, and,
therefore, they must be paid hospital-level rates," Ms. Fishman wrote. "If in the future, IRF and SNF rates for targeted conditions are made on a site-neutral basis, then the service and regulatory expectations for the site-neutral cases treated in IRFs should be lowered."
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