LTACH 2012 Final Rule

Good News for LTACHS

The 2012 Final Rules were released by CMS on Monday, August 1, 2011. Murer Consultants is in the process of analyzing more than 1509 pages that pertain to IPPS and LTACH's. However Murer Consultants wanted to provide a brief overview of its initial findings. The 2012 Final Rules are good news for long term acute care hospitals. Here are some of the highlights of the 2012 Final Rules for LTACH:

It is estimated FY 2012 LTACH payments will increase by a net 2.5% or $126 million rather than the proposed 1.9% or $95 million.
Final 2012 LTACH Rules show an increase in the LTACH base rate from FY 2011 and is more than the 2012 proposed rate:
- FY 2011 Rate = $39,599.95
- 2012 Proposed Rate = $40,082.61
- 2012 FINAL RATE for LTACH = $40,222.05

The fixed loss amount threshold for LTACH's decreased as well (decrease is a good thing). It is down from the current 2011rate and dropped significantly from the 2012 proposed rate:

LTACH Fixed Loss Amount 2011 = $18,785
LTACH Proposed 2012 Amount = $19,270
LTACH Final 2012 Amount = $17,931

Note: The lower threshold allows LTACH to accumulate less cost prior to qualifying for a high cost outlier payment.

The moratorium continues to remain in place until at December 2012.
A pay for reporting program for the following quality measures was established. The first measure for reporting will take effect October 2012. A 2% payment penalty for non reporting will begin October 2013. These quality measures include:

Catheter-associated urinary tract infection
Central line catheter- associated bloodstream infections
New or worsening pressure ulcers

Murer Consultants will continue to review the details of the Final FY 2012 Rules for long term acute care hospitals and update its clients as needed.

Hospitals within Hospitals

Although not part of the final rule there is added good news as it relates to the 25% Rule. On Tuesday, August 2, 2011, Senators Pat Roberts (R-KS) and Bill Nelson (D-FL) introduced the Long Term Care Hospital Improvement Act. This legislation would replace the current 25% threshold rule, which arbitrarily prohibited a fixed percentage of LTACH patients from receiving care at long term acute care hospitals. The bill ,which was quietly introduced, would provide a comprehensive patient and facility criteria alternative. This act would allow LTACH's to treat those very sick patients for which LTACH's were designed. Murer Consultants will continue to monitor this bill and update its clients with new developments.

In the meantime if you have any questions or comments please do not hesitate to contact Murer Consultants at (815) 727-3355.

We will be happy to assist you.

Murer Consultants