Inpatient rehabilitation providers say regulators shouldn’t change Medicare’s reimbursement for early relocation to home care, even though it could save the federal government nearly $ 1 billion. ..
In a letter to the Medicare and Medicaid Service Center scheduled for Tuesday, healthcare providers would add such a policy, resulting in underpayment for inpatient rehabilitation care and impeding access to patient care. Said that it would be. The provider argued that home care is a continuation of care for inpatient rehabilitation facilities and is not a replacement.
“Payment cuts of this magnitude will most likely lead to reduced access to care, which IRF and other providers are facing increased costs and burdens due to the COVID-19 pandemic. That’s why it’s especially true now, “says a letter from Select Medical. We operate inpatient rehabilitation hospitals in 12 states. “Still, there is no clear benefit to patient care or beneficiary access that is likely to result from the extension of the IRF forwarding policy.”
The 2002 CMS decided to reduce the payment of inpatient rehabilitation facilities for patients discharged before the average length of stay for patients with similar diagnoses and to reduce the incentive to be discharged before they are ready. Although the cost of early transfer to another rehabilitation hospital, inpatient hospital, skilled nursing facility, or long-term care hospital can be reduced, this policy does not apply to patients who are discharged early to a home care facility.
By applying the transfer policy to early home care discharges, Medicare could have saved approximately $ 933 million between 2017 and 2018. This is due to a December report from the Inspector General’s Health and Welfare Department. The Medicare Hospital Insurance Trust Fund is expected to run out by 2026.
The CMS said it would consider adding home care to its transfer payment policy, as recommended by HHS inspectors, and asked for feedback on the latest payment proposals for inpatient rehabilitation facilities to add in future rules. rice field.
The provider responded with a clear “no”. According to the healthcare provider, home care is an extension of rehabilitation care for inpatients, not an alternative, and therefore differs from the care settings already included in the transfer policy. The transfer policy is intended to be applied to alternative care for rehabilitation, the CMS said in a previous rule.
The University of Pittsburgh Medical Center Rehabilitation Institute includes home care in its early transfer policy to provide outpatient services when healthcare providers unnecessarily delay patient discharge until average length of stay or when home care is better for patients. He said it could be encouraged.
“Many of our patients have successfully rehabilitated programs and subsequent home care support can maintain functional levels in the home environment. Home care should not be considered a transfer, but it is available regardless. It is part of a patient support network that can do it. Details of the patient’s length of stay if the patient needs these services. ”
Encompass Health, which operates 147 rehabilitation hospitals nationwide, added in its own letter that the goal of rehabilitation for inpatients is to return patients to their homes and communities as soon as possible.
Adding home health care to the early relocation policy violates the Byden administration’s goal of increasing access to home care, said Kate Beller, vice chairman of policymaking and government relations for the American Association of Medical Rehabilitation Providers. rice field.
“A policy that discourages healthcare providers from leaving patients in their home health when they are ready to return home safely does not really make sense from a clinical and patient safety perspective. I think, “Beller said in an interview. ..
AMRPA also had problems with the way the Inspector General conducted the December investigation. Industry groups said in a comment letter that they did not consider that inpatient rehabilitation facility payments were based on overall average patient stay. According to the AMRPA comment letter, the facility will have to pay for patients who stay longer than average, and just considering early discharge will distort payments. In addition, the group’s own analysis did not detect a significant difference in the discharge timeline between patients discharged to home care and a larger patient population.
Other providers have urged the CMS to consider the quality and outcome of care, including hospital readmission data. The inspector general’s general report points out that the provider is only looking at billing data.
However, opposition to policy changes is not universal. Value-based care company Signify Health said it is unclear how adding home care to the transfer policy will affect patient access to services.
“Currently, as the transition policy to home health care reads, early discharge decisions can be affected by incentives to release beds while still receiving full capacity. [case-mix group] payment. However, patients who do not need or become intolerable of skilled treatment for 3 hours a day should return home on the earliest day based on their medical needs, “Signify Health said in a comment letter to the CMS. I am saying.
The CMS has not proposed a formal policy change, but the proposed 2023 inpatient rehabilitation facility payment rules will combine industry comments and institutional analysis with the possibility of future rulemaking. He said he wanted.
