On September 15, 2016 NASL joined with several post-acute provider organizations to send a letter to House Ways and Means Committee leadership, in which we requested their consideration of major changes to the Committee’s Medicare Post-Acute Care Value-Based Purchasing Act (H. R. 3298). This bipartisan bill would establish a value-based purchasing program across home health agencies, nursing homes, inpatient rehabilitation facilities and long-term care hospitals. Under the PAC VBP Program, reimbursement is withheld then redistributed through value-based incentive payments, based on a provider’s performance on measures specified by the IMPACT Act. The PAC VPB would apply to payments for services furnished on or after October 1, 2019, and begin in 2020. The bill would repeal the current SNF VBP program.
In the letter, the PAC coalition of provider groups recommended that the PAC VBP program be delayed until CMS fully develops outcomes measures mandated by the IMPACT Act. The letter also requested that the bill limit the withhold amounts to 2 percent and phase them in by the fifth year of the program. Furthermore, all withheld reimbursement should be reinvested in the form of incentive payments and be redistributed within the PAC sector.
As requested by the Committee, NASL sent the Committee a comment letter on September 20, 2016, which outlines NASL’s concerns. NASL’s letter stresses that the PAC VBP program relies too much on providers’ performance on resource use measures, including the Medicare Spending per Beneficiary (MSPB) measure that was specified in the Improving Medicare Post-Acute Care Transformation (IMPACT) Act of 2014. The PAC VPB is largely based on this measure until a second measure is added by 2021. The MSPB measure is extremely complex and combines various inclusions and exclusions and a complicated episode. Data collection on quality and resource use measures - including the MSPB - is just beginning October 1, 2016 for SNFs. Because data collection begins in a few days, and the measure specification is overly complex, the SNF community has not had an opportunity to accumulate data or experience in how the MSPB data will be reflected in the measures.
Read NASL’s letter; read the PAC Coalition’s letter.
