While LTACH rates are proposed to increase CMS has proposed a decrease in reimbursement levels for 2012 acute hospital reimbursement: Acute Hospitals receive a .5% reduction in reimbursement rates for inpatient stays.

In addition to issuing the annual Medicare payment updates, CMS also addressed numerous proposals designed to meet Affordable Care Act provisions.

LTACH Quality Reporting:

The most prominent of these proposals is that of the new LTACH quality reporting program designed to improve quality processes at all LTACHs by mandating quality reporting. The Affordable Care Act requires the application of a 2% reduction to the annual payment update for LTACHs that fail to report quality data appropriately. This reduction process will start in 2014.  CMS anticipates the collection of quality data to occur from October 1^st through December 31, 2012 for the LTACH payment determination in 2014.

The following are the proposed quality measures that focus on patient safety:

• CAUTI (Catheter Associated Urinary Tract Infection) rate per 1000 urinary catheter days for ICU patients
• CLABSI Central Line Associated Blood Stream Infection rate per 1000 Central Line Days
• Pressure Ulcers that are New or Have Worsened. This is the percentage of patients who have one or more stage 2-4 pressure ulcers that are new or worsened from a previous assessment

CMS plans on expanding the quality reporting program as has proposed various methodologies accordingly.

Medicare Advantage:

CMS is proposing the specific inclusion of Medicare Advantage in the average length of stay calculation to further clarify the current requirement to include Medicare Advantage. Apparently, this issue is being handled inconsistently by LTACH providers therefore CMS is proposing language to eliminate confusion and set forth a uniform methodology. The calculation of the average length of stay is to specify all data on all Medicare inpatient days, including MA days.

ALOS and Change of Ownership:

LTACHs that change ownership must show a >25-day ALOS for the period of at least 5 months of the 6 months immediately preceding the change of ownership. Failure to meet the ALOS would result in the new owner being paid under the acute care PPS and LTCH certification would be lost.

LTACH   Moratorium Loop Hole closed:

CMS is also proposing clarification of the moratorium of bed increases to include LTACHs within the "in development" classification. All LTACHs whether in operation or in development are prohibited from increasing their bed count unless the exception is met until the end of the moratorium: December 29, 2012.

Quality Goals for Future Years

Overarching Goal: Safety and Healthcare Acquired Conditions -- HAIs

HAI reporting for:

·       Ventilator-associated Pneumonia

·       Surgical site infection rate

·       Multi-drug resistant organism infection

Overarching Goal: Safety and Healthcare Acquired Conditions: Avoidable Adverse

Events and Serious Reportable Events

·       Unplanned acute care hospitalizations

·       Mortality

·       Blood Incompatibility

·       Foreign object retained after surgery

·       Manifestation of poor glycemic control

·       Air Embolism

·       Falls and trauma

·       Venous Thromboembolism

·       Injuries secondary to Poly-pharmacy

·       Injuries related restraint use

Overarching Goal:  Safety -- NQF Endorsed Nursing Sensitive Care Measures

·       Patient Fall Rate

·       Falls with Injury

·       Pressure Ulcer Prevalence

·       Restraint Prevalence (vest and limb only)

·       Skill mix (Registered Nurse [RN], Licensed Vocational/Practical Nurse [LVN/LPN], unlicensed assistive personnel [UAP], and contract). Nursing care hours per patient day (RN, LPN, UAP)

·       Voluntary turnover for RN, APN, LPN, UAP

·       Practice Environment Scale-Nursing Work Index

CMS shall be accepting comments on this proposed rule until June 20, 2011 and will respond to them in the final rule to be issued by August 1, 2011. Please call Murer Consultants with any questions or comments regarding the aforementioned proposed changes at 815-727-3355.

Please feel free to Murer Consultants at (815) 727-3355 if you have any questions, comments
or concerns regarding the aforementioned proposed changes.  We will be happy to assist you.