NAHC, other Post-Acute Care Organizations, Express Concerns on House Proposal to Establish Single Value-Based Purchasing Program
Letter offers recommendations and modifications to make the proposed legislation acceptable to post-acute care community
October 16, 2015 08:53 AM
On Tuesday, October 6, the National Association for Home Care & Hospice (NAHC), along with a coalition of other post-acute care and provider organizations, sent a letter to House Ways & Means Health Subcommittee Chairman Kevin Brady (R-TX) and Congressman Ron Kind (D-WI) regarding legislation the lawmakers introduced earlier this year that would establish a single value-based purchasing program (VBP) for all post-acute care (PAC) services. The legislation is called the Medicare Post-Acute Care Value-Based Purchasing Act of 2015 (H.R. 3298). (For a summary of H.R. 3298, see previous NAHC Report article here). In the letter, NAHC and others expressed concern with the design of the VBP program and that the legislation does not adhere to the implementation timeline that was established under the Improving Medicare Post-Acute Care Transformation (IMPACT) Act of 2014, which has not yet been fully implemented.
The letter explains that the IMPACT Act established a “detailed process through which important data will be collected, analyzed and synthesized,” the result of which “could set the stage for significant future changes to existing post-acute care payment policies.” (For more information about the IMPACT Act, see previous NAHC Report article here). “We believe it is important for the process required under the IMPACT Act to be carried out in accordance with the law’s specified timeline,” NAHC and others stated in the letter. “H.R. 3298 is concerning because it does not adhere to the IMPACT Act’s implementation timeline. We conceptually support value-based purchasing and its application to post-acute care providers, though it should be informed by the data and evidence that is to be produced by the IMPACT Act.”
The letter provided several recommendations to help ensure that the design of a PAC VBP program “truly promotes the goals of tying Medicare payments to value and quality.” Following are the recommendations provided in the letter:
Quality Measures. The measure set in any Medicare quality reporting or payment program should be narrow and include at least one measure focused on patient outcomes such as a functional outcome measure (a key metric to assess success in the post-acute care settings). To the extent that a measure will be used across PAC settings, it should be validated for each setting. Measures should be meaningful to Medicare beneficiaries, and the provider should have the ability to modify its practices to improve its performance on the measure. For the purposes of an efficiency measure, such as Medicare Spending per Beneficiary (MSPB), post-acute care providers should not be held accountable for expenditures that occur during the acute care hospital portion of the episode. Initiation of PAC services should be the trigger of the episode for efficiency measurement purposes.
PAC Provider Performance. Given the differences among the types of PAC providers, the performance of each PAC provider type should be compared only to the same type of provider. Provider performance must take into account issues such as level of direct patient oversight within each setting. Further, each provider type cares for patients with different conditions and goals. It is inappropriate to hold individual providers accountable for performance of an entire hospital service area, and measure(s) and comparisons must be risk adjusted to reflect legitimate differences in patients and settings.
Withhold. The withhold amount in a PAC VBP program should not be more than two percent (2%) at full implementation, which is what is currently in place for the hospital Medicare VBP program and is included in the skilled nursing facility (SNF) VBP program, as well. Currently, all post-acute care providers are subject to various Medicare payment cuts with additional reimbursement dollars at risk under quality reporting programs.
Sunset. Any legislation should be time-limited and include a sunset provision. Moreover, the qualitative and quantitative impact on both Medicare providers and beneficiaries should be evaluated and modified where necessary before any programmatic extension.
NAHC and others further stated that they “remain hopeful that acceptable modifications can be made that could garner post-acute care support across our sectors.” To read the full letter, please click here.