Post-Acute Care

Overview

Home Health

Home health care is a formal, regulated program of care delivered by a variety of health care professionals in the patient’s home for the treatment of a medical condition, illness or disability. Home health is provided through certified home health agencies (HHAs).

As components of the post-acute continuum of care, HHAs provide essential health care services. This specialized support allows patients to remain at home when they would otherwise have to be admitted to a costly institutional setting, such as a skilled-nursing facility or hospital.

CHA’s Center for Post-Acute Care represents the interests of CHA member post-acute care providers,  including inpatient rehabilitation hospitals and units,  long-term acute care hospitals, distinct-part skilled-nursing facilities and home health agencies.  As a part of CHA, the Center for Post-Acute Care serves as the primary public policy arm of the hospital association for post-acute care issues. The center also advocates for hospital-based post-acute care services  in the federal and state legislative and regulatory arenas.

CHA News Article

CMS Provides Updates for Post-Acute Care Quality Reporting

The Centers for Medicare & Medicaid Services (CMS) regularly provides important updates for post-acute care quality reporting programs, including training opportunities, public reporting details and reminders of data submission and review deadlines.  

Inpatient Rehabilitation Facilities 
Provider Preview Reports
Updated inpatient rehabilitation facility (IRF) provider preview reports are now available. Providers have until Oct. 8 to review their 2017 quality measure performance data prior to their posting to the IRF Compare website in December. Corrections to the underlying data will not be permitted during this time. However, providers can request CMS review if they believe the data scores displayed are inaccurate. 

Four new quality measures will be reported on IRF Compare: 

  • Assessment-based measures:
    • Application of Percent of Long-Term Care Hospital Patients With an Admission and Discharge Functional Assessment and a Care Plan That Addresses Function (NQF #2631)
    • Application of Percent of Residents Experiencing One or More Falls with Major Injury (NQF #0674)
  • Claims-based measures: 
    • Medicare Spending Per Beneficiary
    • Discharge to Community
CHA News Article

CMS Issues Interpretive Guidance for Revised Home Health CoPs

The Centers for Medicare & Medicaid Services (CMS) has released the attached interpretive guidelines addressing the new Conditions of Participation (CoPs) for home health agencies. The guidelines will be incorporated into Appendix B of the state operations manual.

The revised CoPs were published on Jan. 13, 2018, with an anticipated effective date of July 13, 2017. The effective date was subsequently delayed until Jan. 13, 2018. CMS provided state survey agencies with draft interpretive guidelines in January 2018, pending clearance of the final document.

CHA News Article

CMS Provides Updates for Post-Acute Care Quality Reporting

The Centers for Medicare & Medicaid Services (CMS) regularly provides important updates about post-acute care quality reporting programs (QRPs), including training opportunities, public reporting, and reminders of data submission and review deadlines.  

Inpatient Rehabilitation Facilities 
QRP training
CMS will host two webinars for inpatient rehabilitation facilities (IRFs) on proper coding of Section M Skin Conditions (Pressure Ulcer/Injury) and Section N of the IRF Patient Assessment Instrument Version 2.00. Updated reporting requirements for Sections M and N became effective on Oct. 1 for IRF providers. See the IRF Quality Reporting Training web page for details.   

Long-Term Acute Care Hospitals  
Provider preview reports
CMS has informed long-term acute care hospitals (LTCHs) that previous provider preview reports for the Discharge to Community – PAC measure contained an error. Preview data released in June 2018 incorporated only seven of eight required quarters of data. Data from October through December 2016 were inadvertently omitted.

CMS has reissued the LTCH provider preview reports, and corrected reports are now available via CASPER system folders. LTCH providers have until Aug. 31 to preview the corrected data in advance of public reporting for the September 2018 LTCH Compare Refresh. 

Overview

Hospice

Hospice provides comprehensive and interdisciplinary health care to terminally ill patients, as well as bereavement and support services to the patients’ loved ones. Patients receiving hospice care forgo curative treatments. Hospice care is provided through certified hospice programs, and may be delivered in any patient care setting, but is most often provided in the patient’s home.

CHA provides state and federal representation and advocacy in the legislative and regulatory arenas to improve access to quality, cost-effective hospice health care services.
 

CHA News Article

CMS Provides Updates for Post-Acute Care Quality Reporting

The Centers for Medicare & Medicaid Services (CMS) regularly provides important updates for post-acute care quality reporting programs, including training opportunities, public reporting details and reminders of data submission and review deadlines.  

Inpatient Rehabilitation Facilities 
Provider Preview Reports
Updated inpatient rehabilitation facility (IRF) provider preview reports are now available. Providers have until Oct. 8 to review their 2017 quality measure performance data prior to their posting to the IRF Compare website in December. Corrections to the underlying data will not be permitted during this time. However, providers can request CMS review if they believe the data scores displayed are inaccurate. 

Four new quality measures will be reported on IRF Compare: 

  • Assessment-based measures:
    • Application of Percent of Long-Term Care Hospital Patients With an Admission and Discharge Functional Assessment and a Care Plan That Addresses Function (NQF #2631)
    • Application of Percent of Residents Experiencing One or More Falls with Major Injury (NQF #0674)
  • Claims-based measures: 
    • Medicare Spending Per Beneficiary
    • Discharge to Community
CHA News Article

CMS Issues FFY 2019 Hospice Wage Index Final Rule

The Centers for Medicare & Medicaid Services (CMS) has issued its final rule updating the hospice wage index for federal fiscal year (FFY) 2019. CMS finalized a 1.8 percent hospice payment update based on a 2.9 percent inpatient hospital market basket update, reduced by a 0.8 percent productivity adjustment and a 0.3 percentage point adjustment mandated by the Affordable Care Act. The agency estimates the payment update will result in a $340 million increase in hospice payments compared to FFY 2018.

CMS also finalized several changes to the Hospice Quality Reporting Program and, as required by the Bipartisan Budget Act of 2018, expanded the definition of a “hospice attending physician” to include physician assistants in addition to physicians and nurse practitioners. Additional information is available in a CMS fact sheet.

CHA News Article

Post-Acute Care Facilities Notified of Non-Compliance With Quality Reporting

The Centers for Medicare & Medicaid Services (CMS) has identified inpatient rehabilitation facilities, long-term care hospitals, skilled-nursing facilities and hospices that are not in compliance with quality reporting program requirements for calendar year 2017, and sent those facilities notices of non-compliance on July 9. The non-compliance determination will affect the annual increase factor for fiscal year 2019 reimbursement rates.

The notifications were both mailed to the facilities and placed in their Certification and Survey Provider Enhanced Reports folders in the Quality Improvement and Evaluation System. Facilities that receive a letter of non-compliance may submit a request for reconsideration to CMS via email no later than 11:59 p.m. (PT) on Aug. 7. Instructions for requesting a reconsideration are included in the notification letter.  

Overview

Inpatient Rehabilitation & Therapy Services

Medical rehabilitation focuses on improving or restoring functional independence for individuals with disabilities resulting from injury, illness or a medical condition.

Medical rehabilitation is provided at all levels of the health care continuum, including general acute-care hospitals, inpatient rehabilitation facilities (IRFs), skilled-nursing facilities, long-term-care hospitals, outpatient programs and home health agencies.Services may range from coordinated interdisciplinary programs to individual therapy disciplines.

CHA News Article

CMS Provides Updates for Post-Acute Care Quality Reporting

The Centers for Medicare & Medicaid Services (CMS) regularly provides important updates for post-acute care quality reporting programs, including training opportunities, public reporting details and reminders of data submission and review deadlines.  

Inpatient Rehabilitation Facilities 
Provider Preview Reports
Updated inpatient rehabilitation facility (IRF) provider preview reports are now available. Providers have until Oct. 8 to review their 2017 quality measure performance data prior to their posting to the IRF Compare website in December. Corrections to the underlying data will not be permitted during this time. However, providers can request CMS review if they believe the data scores displayed are inaccurate. 

Four new quality measures will be reported on IRF Compare: 

  • Assessment-based measures:
    • Application of Percent of Long-Term Care Hospital Patients With an Admission and Discharge Functional Assessment and a Care Plan That Addresses Function (NQF #2631)
    • Application of Percent of Residents Experiencing One or More Falls with Major Injury (NQF #0674)
  • Claims-based measures: 
    • Medicare Spending Per Beneficiary
    • Discharge to Community
CHA News Article For Members

CHA Issues Summary of Physician Fee Schedule Proposed Rule
Register for CHA’s member forum, to be held Aug. 30

CHA has released the attached summary of the calendar year 2019 physician fee schedule (PFS) proposed rule, which also outlines proposed provisions implementing the third year of the Quality Payment Program (QPP) for physician payment.

The summary provides detailed information on a number of proposed policies, including payment for non-excepted off-campus provider departments, reduced administration burden for evaluation and management services, a reduction of payment for new Part B drugs and the implementation of Bipartisan Budget Act of 2018 provisions related to therapy and telehealth services.

The summary also details proposed updates to the Merit-based Incentive Payment System (MIPS) under the QPP, including an expanded definition of MIPS-eligible clinicians, a reduction of the MIPS measure set and proposed testing of the Medicare Advantage Qualifying Payment Arrangement Incentive Demonstration.

Comments on the proposed rule are due Sept. 10 by 2 p.m. (PT).

CHA will host a member forum on Aug. 30 at 10:30 a.m. (PT) in anticipation of submitting comments.

CHA News Article

CMS Provides Updates for Post-Acute Care Quality Reporting

The Centers for Medicare & Medicaid Services (CMS) regularly provides important updates about post-acute care quality reporting programs (QRPs), including training opportunities, public reporting, and reminders of data submission and review deadlines.  

Inpatient Rehabilitation Facilities 
QRP training
CMS will host two webinars for inpatient rehabilitation facilities (IRFs) on proper coding of Section M Skin Conditions (Pressure Ulcer/Injury) and Section N of the IRF Patient Assessment Instrument Version 2.00. Updated reporting requirements for Sections M and N became effective on Oct. 1 for IRF providers. See the IRF Quality Reporting Training web page for details.   

Long-Term Acute Care Hospitals  
Provider preview reports
CMS has informed long-term acute care hospitals (LTCHs) that previous provider preview reports for the Discharge to Community – PAC measure contained an error. Preview data released in June 2018 incorporated only seven of eight required quarters of data. Data from October through December 2016 were inadvertently omitted.

CMS has reissued the LTCH provider preview reports, and corrected reports are now available via CASPER system folders. LTCH providers have until Aug. 31 to preview the corrected data in advance of public reporting for the September 2018 LTCH Compare Refresh. 

Overview

Long-Term-Care Hospitals

Long-term-care hospitals (LTCHs) provide hospital-level care for medically complex, long-stay patients. LTCHs meet the same requirements as general acute-care hospitals, but have significantly longer average lengths of stay of 25 days or greater. LTCHs may be freestanding facilities or be co-located within hospitals, and treat a wide variety of conditions, including respiratory failure with ventilator dependency, infections, complex wounds and trauma.

CHA’s Center for Post-Acute Care represents the interests of CHA member post-acute care providers,  including inpatient rehabilitation hospitals and units,  long-term acute care hospitals, distinct-part skilled-nursing facilities and home health agencies.  As a part of CHA, the Center for Post-Acute Care serves as the primary public policy arm of the hospital association for post-acute care issues. The center also advocates for hospital-based post-acute care services  in the federal and state legislative and regulatory arenas.

CHA News Article

CMS Provides Updates for Post-Acute Care Quality Reporting

The Centers for Medicare & Medicaid Services (CMS) regularly provides important updates for post-acute care quality reporting programs, including training opportunities, public reporting details and reminders of data submission and review deadlines.  

Inpatient Rehabilitation Facilities 
Provider Preview Reports
Updated inpatient rehabilitation facility (IRF) provider preview reports are now available. Providers have until Oct. 8 to review their 2017 quality measure performance data prior to their posting to the IRF Compare website in December. Corrections to the underlying data will not be permitted during this time. However, providers can request CMS review if they believe the data scores displayed are inaccurate. 

Four new quality measures will be reported on IRF Compare: 

  • Assessment-based measures:
    • Application of Percent of Long-Term Care Hospital Patients With an Admission and Discharge Functional Assessment and a Care Plan That Addresses Function (NQF #2631)
    • Application of Percent of Residents Experiencing One or More Falls with Major Injury (NQF #0674)
  • Claims-based measures: 
    • Medicare Spending Per Beneficiary
    • Discharge to Community
CHA News Article

CMS Issues FFY 2019 Long-Term Care Hospital PPS Final Rule

Late last week, the Centers for Medicare & Medicaid Services (CMS) issued its federal fiscal year (FFY) 2019 long-term care hospital (LTCH) prospective payment system (PPS) final rule.

CMS projects that LTCH PPS payments will increase by approximately 0.9 percent ($39 million) in FFY 2019 compared to FFY 2018. This includes a finalized standard rate net increase of 1 percent ($35 million) and a net increase of 0.4 percent ($4 million) for LTCHs paid the site-neutral rate.

The final rule permanently eliminates the 25 percent threshold policy. CHA strongly supported this proposal in comments sent to CMS in June.

The proposal to expand exemptions of separateness and control requirements for LTCHs co-located with another inpatient prospective payment system (IPPS)-excluded hospital — which CHA also strongly supported — is finalized. IPPS-excluded satellite providers will be exempt from separateness and control requirements effective Oct. 1. IPPS-excluded hospitals will be allowed to operate inpatient rehabilitation and inpatient psychiatric units starting with cost reporting periods that begin on or after Oct. 1, 2019.

CHA News Article

CMS Provides Updates for Post-Acute Care Quality Reporting

The Centers for Medicare & Medicaid Services (CMS) regularly provides important updates about post-acute care quality reporting programs (QRPs), including training opportunities, public reporting, and reminders of data submission and review deadlines.  

Inpatient Rehabilitation Facilities 
QRP training
CMS will host two webinars for inpatient rehabilitation facilities (IRFs) on proper coding of Section M Skin Conditions (Pressure Ulcer/Injury) and Section N of the IRF Patient Assessment Instrument Version 2.00. Updated reporting requirements for Sections M and N became effective on Oct. 1 for IRF providers. See the IRF Quality Reporting Training web page for details.   

Long-Term Acute Care Hospitals  
Provider preview reports
CMS has informed long-term acute care hospitals (LTCHs) that previous provider preview reports for the Discharge to Community – PAC measure contained an error. Preview data released in June 2018 incorporated only seven of eight required quarters of data. Data from October through December 2016 were inadvertently omitted.

CMS has reissued the LTCH provider preview reports, and corrected reports are now available via CASPER system folders. LTCH providers have until Aug. 31 to preview the corrected data in advance of public reporting for the September 2018 LTCH Compare Refresh. 

Overview

Skilled-Nursing Facilities / Distinct Part Nursing Facilities

Skilled-nursing facilities (SNFs) have the staff and equipment to provide skilled nursing, medical management and therapy services to individuals, on a 24-hour basis, who do not require high-intensity services provided in the hospital setting.

CHA News Article

CMS Provides Updates for Post-Acute Care Quality Reporting

The Centers for Medicare & Medicaid Services (CMS) regularly provides important updates for post-acute care quality reporting programs, including training opportunities, public reporting details and reminders of data submission and review deadlines.  

Inpatient Rehabilitation Facilities 
Provider Preview Reports
Updated inpatient rehabilitation facility (IRF) provider preview reports are now available. Providers have until Oct. 8 to review their 2017 quality measure performance data prior to their posting to the IRF Compare website in December. Corrections to the underlying data will not be permitted during this time. However, providers can request CMS review if they believe the data scores displayed are inaccurate. 

Four new quality measures will be reported on IRF Compare: 

  • Assessment-based measures:
    • Application of Percent of Long-Term Care Hospital Patients With an Admission and Discharge Functional Assessment and a Care Plan That Addresses Function (NQF #2631)
    • Application of Percent of Residents Experiencing One or More Falls with Major Injury (NQF #0674)
  • Claims-based measures: 
    • Medicare Spending Per Beneficiary
    • Discharge to Community
CHA News Article

FDA Reminds Providers About Safety With Tubing Connectors

The U.S. Food and Drug Administration (FDA) has issued a guidance letter in response to continued reports of misconnections with enteral devices. The FDA recommends that hospitals and clinicians use enteral devices with connectors that meet the International Organization for Standardization (ISO) 80369-1 or ISO 80369-3 standard, or that are otherwise designed to reduce the risk of misconnections. (The FDA also notes that some currently marketed enteral connectors that meet the 80369-3 standards use the tradename ENFit).

The letter also recommends that health care professionals:

  • Check the labeling or check with the distributor or manufacturer to determine whether connectors meet the ISO standards.
  • Organize a plan to implement the use of these new devices.
  • Do not modify or adapt devices, because that may defeat their safety system.
  • Minimize the use of transition adapters.
  • Do not use cross-application connectors.
  • Trace all lines back to their origin when reconnecting devices.
  • Route tubes and catheters that have different purposes in unique and standardized directions to avoid accidental misconnections.

A California law prohibits hospitals and skilled-nursing facilities from using epidural, intravenous or enteral feeding connectors that can fit into connection ports other than the type for which they were intended. Hospitals and skilled-nursing facilities are now required to use reengineered tubing connectors, which work to prevent misconnections, eliminate human error and facilitate patient safety.

CHA News Article

Skilled-Nursing Facility Value-Based Purchasing Performance Reports Available
Correction requests must be submitted by Aug. 31

Annual performance score reports for the Skilled-Nursing Facility Value-Based Purchasing Program — which begins Oct. 1 — are now accessible via the Certification and Survey Provider Enhanced Reporting (CASPER) system. The confidential performance score reports contain the patient-level stays during the calendar year 2017 performance period that were used to calculate facility performance, as well as performance and ranking information that will be made publicly available on Nursing Home Compare. The deadline to submit correction requests is Aug. 31 at 11:59 p.m. (PT). More information is available in the attached memo. 

Overview

Subacute Care

Subacute-care units provide a specialized level of care to medically fragile patients. Subacute patients are individuals who do not need acute care, but who are too ill to be cared for by most skilled-nursing facilities. Frequently, these individuals are ventilator-dependent or require frequent respiratory treatments. While subacute beds are licensed as skilled-nursing beds, they are reimbursed differently and are subject to additional staffing and patient criteria requirements.

CHA provides state and federal representation and advocacy in the legislative and regulatory arenas to improve access to quality, cost-effective subacute-care services.

CHA News Article

CMS Provides Updates for Post-Acute Care Quality Reporting

The Centers for Medicare & Medicaid Services (CMS) regularly provides important updates for post-acute care quality reporting programs, including training opportunities, public reporting details and reminders of data submission and review deadlines.  

Inpatient Rehabilitation Facilities 
Provider Preview Reports
Updated inpatient rehabilitation facility (IRF) provider preview reports are now available. Providers have until Oct. 8 to review their 2017 quality measure performance data prior to their posting to the IRF Compare website in December. Corrections to the underlying data will not be permitted during this time. However, providers can request CMS review if they believe the data scores displayed are inaccurate. 

Four new quality measures will be reported on IRF Compare: 

  • Assessment-based measures:
    • Application of Percent of Long-Term Care Hospital Patients With an Admission and Discharge Functional Assessment and a Care Plan That Addresses Function (NQF #2631)
    • Application of Percent of Residents Experiencing One or More Falls with Major Injury (NQF #0674)
  • Claims-based measures: 
    • Medicare Spending Per Beneficiary
    • Discharge to Community
CHA News Article

Skilled-Nursing Facility Notice of Non-Coverage Revised

The Centers for Medicare & Medicaid Services (CMS) has issued the attached MLN Matters article about the recently revised Skilled-Nursing Facility Notice of Non-coverage form. With this revision, CMS is discontinuing five skilled-nursing facility denial letters, specified in the article, and the Notice of Exclusion from Medicare Benefits. The revised form will be required effective April 30, but facilities are encouraged to begin using it as soon as practicable.

CHA News Article

Guidance Reiterates Flu Prevention, Control in Long-Term Care Facilities
Subscriber alert reports no statewide shortage of antiviral medications

The California Department of Public Health (CDPH) today released the attached All Facilities Letter 18-08 addressing the state’s high rate of influenza activity. The guidance emphasizes infection control measures for long-term care facility residents with suspected or confirmed influenza and includes steps to take for implementation of droplet precautions. The department advises that residents should stay in their own rooms as much as possible, employees and visitors should be screened for illness, ill health care personnel should be furloughed and ill visitors discouraged from entering the facility. The guidance refers providers to the Centers for Disease Control and Prevention guidelines titled “Interim Guidance for Influenza Outbreak Management in Long-Term Care Facilities,” and the CDPH “Recommendations for the Prevention and Control of Influenza – California Long-Term Care Facilities.”

CDPH has also issued a subscriber alert on influenza antiviral recommendations and strategies to obtain influenza antivirals, reporting there does not appear to be a nationwide antiviral shortage. Pharmacies are encouraged to contact their wholesaler’s customer service desk to request drop shipments of antivirals from the manufacturers if the wholesaler is unable to supply needed medications in a timely manner.

Commands