NAHC & Allies Send Letter to Congress Urging Changes to Proposal on Value Based Purchasing in Post-Acute Care Settings
September 16, 2016 09:40 AM
On September 15, NAHC and other members of the post-acute care (PAC) community sent a letter to House Ways & Means Chairman Kevin Brady (R-TX), Health Subcommittee Chairman Pat Tiberi (R-OH) and Congressman Ron Kind (D-WI) to urge that important changes be made to the Medicare Post-Acute Care Value-Based Purchasing Act of 2015 (H.R. 3298).
The legislation would create an incentive pool for four post-acute settings – home health agencies, skilled nursing facilities, inpatient rehabilitation facilities and long-term care hospitals. When the legislation was first introduced in 2015, NAHC and other post-acute care organizations expressed concerns with the program. Concerns included that the program does not adhere to the implementation timeline that was established under the Improving Medicare Post-Acute Care Transformation (IMPACT) Act of 2014, quality measures (rather than just a focus on spending) should be narrow and include at least one measure focused on patient outcomes, and the withhold amount in a program should not be more than two percent at full implementation.
While NAHC and its allies remain committed to advancing PAC value-based purchasing (VBP), we cannot support the bill without changes that will improve it for patients and providers. We would like to see the following changes made to the bill:
VBP scores should be focused on patient outcomes, not resource use. No more than ten percent of a provider’s score should be based on resource use. Implementation of a PAC VBP program should be delayed until the outcomes measures, called for by the Improving Medicare Post-Acute Care Transformation (IMPACT) Act of 2014, are implemented and shown to be good indicators of quality.
Wait for the appropriate cross-setting IMPACT Act measures to be fully-implemented. H.R. 3298 should adhere to the IMPACT Act’s implementation timeline, ensuring that the cross-setting measures that would be necessary for implementing this legislation have been fully developed, validated and vetted. Post-acute payment reform must be informed by the evidence.
Make the PAC VBP program budget-neutral. A PAC VBP program should be focused solely on improving quality of care and the best way to do that is to reinvest all withheld payments in the form of incentive payments to be redistributed into the particular payment system from which they came.
Make the payment withhold percentage fair and consistent with other VBP programs.
The withhold percentage should be consistent with the hospital VBP program. Therefore, we recommend it being at one percent in year one, rising in quarter-percentage increments to two percent in year five.
Remove the geographic resource use comparison so patients have equitable access to post-acute services nationwide. If too much attention is placed on provider costs, providers and beneficiaries in some areas of the country will be at a significant disadvantage because of variations in labor and property costs, regardless of the quality of care they are providing.
You can read the text of the letter here.
NAHC will continue to monitor the legislation, express concerns and provide suggestions to the Ways & Means Committee.