The CMS is proposing new measures to better track frequency of care and spending in skilled-nursing facilities, home health agencies, inpatient rehabilitation facilities and long-term-care hospitals in an effort to curb rising costs.
The Improving Post-Acute Care Transformation Act of 2014 mandates the HHS secretary to measure how often certain services should be used in post-acute care settings based on the risk of a provider's population. The CMS also proposes evaluating a provider's efficiency by tracking per-beneficiary spending.
The measures would be implemented by Oct. 1, 2016, for skilled-nursing facilities, inpatient rehabilitation facilities and long-term-care hospitals and Jan. 1, 2017, for home health agencies.
The CMS is trying to control Medicare post-acute care spending, which between 2001 and 2013 grew at an annual rate of 6.1% and doubled to $59.4 billion. Payments to inpatient hospitals grew at an annual rate of 1.7% over this same period, according to federal data.
In 2013, the last year federal data are available, 1.7 million Medicare beneficiaries received skilled-nursing inpatient rehabilitation facilities services, 3.5 million beneficiaries received home health agency services, 122,000 beneficiaries received long-term-care hospital services, and 338,000 beneficiaries received inpatient rehabilitation services.
Stakeholders have largely opposed the draft measures. A common concern is that the race or socio-economic status of patients is not taken into account.
As a result, providers that serve minority or low-income populations could be unfairly evaluated under the system, according to Momotazur Rahman, assistant professor of health services, policy and practice in the Brown University School of Public Health.
Others agreed. “There is a significant body of evidence showing the link between provider performance on outcomes, such as readmissions and cost, and socio-economic factors like poverty, education and insurance status,” said Akin Demehin, senior associate director of policy at the American Hospital Association.
Further the document doesn't mention if outcomes measures are also being developed. Without those, the CMS won't be getting the full picture of care being offered by these providers.
“These are just resource utilization measures and tell us nothing about how good that care was or whether it was appropriate or not,” said Dr. Ashish Jha, director of Harvard's Global Health Institute. “Tying it in with robust outcomes measures, such as functional status and self-reported health outcomes is critical.”
Others were troubled by the CMS developing four separate setting-specific episode cost measures instead of a per-beneficiary post-acute care cost measure as specified in the new law, according to Dan Ciolek, associate vice president of therapy advocacy at American Health Care Association, a nursing-home industry group.
Also it appears the CMS is giving stakeholders little time to digest and understand the new measures before they go into effect.
A CMS representative did not respond to a request for comment.
The agency posted a draft on the measures (PDF) on Jan.13 and is taking comments on the document until Jan. 27.