CHA News Article

CMS Issues Interim Final Rule for LTCHs
Comments due June 17

The Centers for Medicare & Medicaid Services (CMS) has issued the attached interim final rule to implement section 231 of the Consolidated Appropriations Act of 2016, which establishes a temporary exception for certain wound care discharges from the site-neutral payment rate for certain long-term acute care hospitals (LTCHs). The interim final rule, which was released in conjunction with the LTCH prospective payment system proposed rule, will be open for public comment through June 17.

In the rule, CMS establishes that a rural LTCH that “participated in Medicare as an LTCH and was co-located with another hospital as of September 30, 1995, that currently meets the requirements of section 412.22(f) of the Social Security Act” qualifies for relief. The relief applies to patients who received treatment in the LTCH for “severe wound” cases and were discharged prior to Jan. 1, 2017.

Because the legislative criterion describing severe wounds does not align with ICD-10 guidelines, CMS establishes unique definitions for qualifying cases, including:

  • “Wounds with morbid obesity” — wounds in those with morbid obesity that require complex, continuing care including local wound care occurring multiple times a day.
  • “Infected wounds” — those that require complex, continuing care including local wound care occurring multiple times a day.

To identify these cases, CMS will use “payer-only condition codes” issued by the National Uniform Billing Committee. LTCHs must flag these cases for their Medicare administrative contractors to receive a code on the claim, which will result in an LTCH prospective payment system payment, rather than a site-neutral payment.

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