Post-Acute Care Groups Oppose Value-Based Purchasing Program
The value-based purchasing program for post-acute providers fall short of promoting quality improvement and fairly adjusting payments, claim several industry groups.
By - Eight healthcare industry groups recently told lawmakers that they oppose the proposed Medicare Post-Acute Care Value-Based Purchasing Program, which is scheduled to start on Oct. 1, 2019.
In a letter to the House Committee on Ways and Means, the American Health Care Association along with seven other organizations contend that the value-based care program would benefit from five key changes. These changes include budget neutrality and withholding percentages consistent with other Medicare value-based purchasing programs as well as an increased focus on patient outcomes, the addition of more appropriate quality measures, and the elimination of geographic resource use comparisons.
“Should these revisions be made, we will be better able to achieve support from our respective memberships,” stated the organizations. “If these changes are not made, we will be left with no choice but to oppose the legislation.”
In July 2015, House Ways and Means Committee Chairman Kevin Brady (R-TX) introduced the Medicare Post-Acute Care Value-Based Purchasing Act of 2015. The bill aimed to establish a value-based care program that would adjust Medicare reimbursement rates based on quality and cost performance for home health, skilled nursing, inpatient rehabilitation, and long-term care facilities.
However, the eight industry groups stated that the Post-Acute Care Value-Based Purchasing Program focuses too much on resource use and not enough on patient outcomes. Under the proposed value-based care model, post-acute care providers would be assessed solely on resource use in the first two years. Even when the program is fully implemented in the third performance year, participants would only be judged on resource use and functional status.
The organizations advised lawmakers to attribute no more than ten percent of a provider’s score to resource use and to include more outcome-based measures to acknowledge high-quality performance and provider improvement. Lawmakers should also restore a provision that would grant value-based incentive payments to providers that are able to improve their quality scores.
To develop the most appropriate outcome-based measures, the organizations urged the House committee to look to the IMPACT Act, which developed a government-controlled process for collecting, publishing, and analyzing data among post-acute care providers. The reports from the IMPACT Act may change care delivery processes for post-acute care providers as well as how providers are paid, so lawmakers should ensure that the value-based purchasing program aligns with the it.
The groups called on House representatives to adhere “to the IMPACT Act’s implementation timeline, thereby ensuring that the cross-setting measures that would be necessary for implementing this legislation have been fully developed, validated and vetted.”
The letter also stated that the Post-Acute Care Value-Based Purchasing Program should be budget neutral within each provider-specific payment system, such as the skilled nursing facilities or long-term care facilities prospective payment system.
Under the program, CMS would withhold a portion of reimbursements through annual payment reductions and allocate the funds to the Medicare Improvement Fund. CMS would withhold three percent of payments in 2019 and increase the proportion by one percentage point each year until the reduction reaches eight percent in 2025.
However, the organizations argued that there are no assurances that the withheld payments in the Medicare Improvement Fund would be redistributed to post-acute care providers.
“A PAC VBP [post-acute care value-based purchasing] program should be focused solely on improving care quality 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,” wrote the organizations.
Additionally, lawmakers should make the withheld payment proportions consistent with Medicare’s Hospital Value-Based Purchasing Program, contended the organizations. Like the hospital-based program, the withheld percentage should start at one percent of reimbursements in the first year and increase by 0.25 percentage points each year.
The value-based purchasing program would deprive post-acute care providers of critical resources necessary for quality improvement under the proposed withhold percentages, stated the letter.
The industry groups also urged lawmakers to eliminate geographic resource use comparisons under the value-based purchasing program. The Institute of Medicine has already advised Congress to stop using geographic resource use comparisons, the groups noted, because it causes low-value providers in high-value areas to be unfairly rewarded.
The comparisons would also be inappropriate for the post-acute care program because it spans four distinct post-acute care areas that each have their own healthcare costs and resource use trends.
Furthermore, providers in areas with long-term care hospitals and inpatient rehabilitation facilities may be unfairly penalized. Since long-term care hospitals and inpatient rehabilitation facilities are reimbursed by Medicare at a higher rate, these areas tend to have higher spending averages. The groups explained that post-acute care providers should not be penalized or rewarded based on the provider mix in their region.
While the American Health Care Association and several others expressed their disappointment, the American Hospital Association (AHA) also recently criticized the proposed Post-Acute Care Value-Based Purchasing Program. The organization argued that the program “too narrowly focuses on reducing provider payment rather than promoting ‘value’ – that is, the delivery of consistently high-quality care at a lower cost.”
Like the American Health Care Association, the AHA called on the House Committee on Ways and Means to make the value-based purchasing program budget neutral and include more quality-based measures to determine payment adjustments.
Dig Deeper:
• Understanding the Value-Based Reimbursement Landscape
• How to Manage ACO Risk with Value-Based Purchasing Programs
