CENTER FOR POST-ACUTE ARE - California Hospital Association · Center for Post-Acute Care Advisory...
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CENTER FOR POST-ACUTE CARE ADVISORY BOARD MEETING Wednesday, February 15, 2017 1:00 pm – 5:00 pm HILTON WATERFRONT BEACH RESORT TIDES ROOM 21100 Pacific Coast Highway Huntington Beach, CA 92648
Transcript of CENTER FOR POST-ACUTE ARE - California Hospital Association · Center for Post-Acute Care Advisory...
CENTER FOR POST-ACUTE CARE
ADVISORY BOARD MEETING
Wednesday, February 15, 2017
1:00 pm – 5:00 pm
HILTON WATERFRONT BEACH RESORT
TIDES ROOM 21100 Pacific Coast Highway
Huntington Beach, CA 92648
CENTER FOR POST-ACUTE CARE
AGENDA
Wednesday, February 15, 2017
1:00 PM - 5:00 PM
Hilton Waterfront Beach Resort – Tides Room
Huntington Beach, CA
TEM SUBJECT REPORTING TIME PAGE *Action Item
I. CALL TO ORDER/INTRODUCTIONS
Working Agreements/Rules of Engagement
Darvish 1:00
5
II. MINUTES OF PREVIOUS MEETING Darvish 1:05
A. Post-Acute Care Advisory Board Meeting
October 26, 2016 Meeting Minutes*
Recommendation: Approve meeting minutes
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III. CHAIR REPORT
1:10 11
A. 2017 Advisory Board & Icebreaker
Activity
Post-Acute Care Advisory Board Roster
Darvish
13
B. CHA Board of Trustees
Darvish/Starr
IV. VICE PRESIDENT REPORT
1:40 17
A. Review Resource/Orientation Materials
Blaisdell
B. Center Operations Update
Blaisdell
C. Annual Meeting Activities Review Blaisdell
Center for Post-Acute Care Advisory Board Meeting Agenda
February 15, 2017 Page 2
V. STRATEGIC PLANNING
A. 2016 Objectives Review and Update
CPAC Action Steps
Education Proposal
All 2:00 19
21
23
Break 3:00
VI. CURRENT ISSUES
3:15 27
A. Federal Update
ACA Talking Points
MediCal Coverage Chart
Federal Regulatory Report
Keefe/Blaisdell
31
33
35
B.
C.
State Update
Provider Updates
Blaisdell
All
VII. IMPACT ACT
Keefe/All 4:00 39
CHA Highlights IMPACT Act
IMPACT ACT QRP Slides
41
43
VIII. NEW BUSINESS
All 4:30
IX. NEXT MEETING
WEDNESDAY, APRIL 26, 2017
10:00 A.M. – 2:00 P.M.
CALIFORNIA HOSPITAL ASSOCIATION
BOARD ROOM
CONFERENCE CALL: 800-882-3610
PASSCODE: 4920025#
2017 Meeting Dates
Blaisdell
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X. ADJOURNMENT
Darvish 5:00
Working Agreements/ Rules of Engagement for Advisory Board Meetings
1. Be honest, open and transparent with each other
2. Welcome new ideas
3. Be respectful
4. Don’t “sit” on things that need surfacing (bring them up)
5. Use judgement about using electronics - trust each other to do that
6. Leave room if needed to take calls or address urgent issues
7. It’s okay to admit when we need help and/or stop and go back
8. Start and finish on time
9. Build in time for networking and stick to schedule
10. Stick to agendas
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Center for Post-Acute Care Advisory Board Meeting
Meeting Minutes
Wednesday, October 26 2016 10:00 am – 2:30 pm
California Hospital Association
Board Room 1215 K Street, Suite 800 Sacramento, CA 95814
Present: P. Chevreaux, A. Darvish, W. Hekimian, S. Necke, M. Alpasan,
L. Biscaro, L. Harrold, S. Ramirez, T. Starr, R. Walters, M. Bedi, J. Potts, P. Reger
By Phone: S. Brown, L. Edwards, P. Bishop, M. Samora, M. Howard Staff: D. Grellmann, A. Keefe, P. Blaisdell, R. Lauborough Regional Association Staff: J. Yates
I. CALL TO ORDER Chair Chevreaux called the meeting to order at 10:00 am.
II. MINUTES OF PREVIOUS MEETING The minutes of the July 21, 2016 meeting were reviewed and approved.
III. CHAIR REPORT A. Advisory Board Membership Update
Chair Chevreaux provided an update on membership. Members of the advisory board approved the nominations of Cindy Calvillo, Executive Director, Utilization and Resource Management, Kaiser Permanente and David Brown, System Director, Rehabilitation Services, Sharp Healthcare and the re-appointment of current board members Sheila Brown, Paul Giles, Walter Hekimian, and Robert Walters.
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Meeting Minutes – October 26, 2016 Center for Post-Acute Care Advisory Board Page 2
B. CHA Board of Trustees
Chair Chevreaux provided an update on the most recent meeting of the CHA Board of Trustees.
IV. VICE PRESIDENT REPORT
A. Annual Meeting Staff Blaisdell provided an update on planning for the 2017 annual meeting.
B. Strategic Planning Discussion Staff Blaisdell discussed with the committee, goals and activities developed during strategic planning retreats and subsequent meetings.
C. Education/Resource Proposal Staff Blaisdell summarized recent discussions updating a proposed educational resources and solicited additional input. Staff Blaisdell will summarize the comments of the board members and develop a
proposal for consideration.
V. STATE AFFAIRS Staff Blaisdell provided an update on the recently completed legislative session.
A. Continuum of Care Bill Summary Several bills of interest to hospitals and post-acute care providers have been introduced in the current legislative session. Particular bills discussed were AB 323, AB 1518, and SB 1076.
VI. FEDERAL UPDATE
A. Legislative & Regulatory Update Staff Keefe gave an extensive update on legislative and regulatory activity for 2016. Special emphasis was given on the MACRA final rule, Home Health final rule, and Episode Payment Model final rule for Cardiac Bundling and CJR Updates. The CMS final rule on Emergency Preparedness was also discussed at length. Staff Blaisdell to provide information updating CHA resources to board members.
Meeting Minutes – October 26, 2016 Center for Post-Acute Care Advisory Board Page 3
B. IMPACT ACT Patient Assessment Data
Staff Blaisdell and Keefe provided an update on the implementation of the IMPACT Act of 2014, including current requests from CMS for input updating standardized assessment instruments. Staff Blaisdell and Keefe requested that board members review the RAND report
regarding IMPACT Act measures and provide input regarding implementation in their settings. Staff Blaisdell will send out a follow-up email with additional materials.
VII. REPORTS
A. Inpatient Rehabilitation & Therapy Services Forum Chair Walters provided the members an update regarding issues impacting inpatient rehabilitation facilities (IRFs) and therapy services. A CARE Tool has been implemented and a revision of the tool will be made effective, December, 2016.IRF-PAL, QRP and Therapy CPT Codes were discussed.
B. Skilled Nursing & Subacute Care Forum
Chair Hekimian provided members an update regarding issues impacting hospital-based skilled nursing units and subacute care units with regards to SNF PPS, Patient Assessment Changes, and the revised Long Term Care conditions of participation. Hekimian also shared current challenges associated with new requirements for payroll-based journal reporting.
C. Home Health & Hospice Forum Staff Blaisdell provided an update regarding issues impacting home health agencies and hospices. Included in the discussion were Home Health PPS, Hospice Proposed Rule, and communication with key stakeholders and staff of the California Department of Public Health regarding requirements for home health social workers.
D. LTCH Staff Blaisdell provided an update regarding issues affecting long-term acute care hospitals.
E. CHA Case Management Committee Biscaro provided the committee an update regarding issues and activities of the CHA Case Management Committee. Discussions on DME, Cal-MediConnect/CCI, Workforce Planning, and Discharge Delay were all discussed with the members.
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Meeting Minutes – October 26, 2016 Center for Post-Acute Care Advisory Board Page 4
VIII. OTHER BUSINESS
A. Member Updates
IX. NEW BUSINESS
X. NEXT MEETING
Conference Call Wednesday, December 14, 2016 11:00 a.m. – 12:00 p.m. Call-in: (800) 882-3610; Passcode: 4920025#
XI. ADJOURNMENT
PLUS / DELTA: Committee members provided input about the meeting. Plus: It was a more interactive meeting. Good Contacts. Good Food. Nice Group. Member engagement, great discussions. Great meeting, very interactive. Delta: Mix some good news with bad news.
February 15, 2017 TO: Center for Post-Acute Care Advisory Board FROM: Adam Darvish, Chair SUBJECT: CHA Center for Post-Acute Care Chair Report SUMMARY Adam Darvish chairs the Advisory Board of the Center for Post-Acute Care. Darvish and Chair-elect Tory Starr represent the Center on the CHA Board of Trustees. The Advisory Board consists of no more than 24 members, representative of the types, location, and size of institutional members. ACTION REQUESTED
To provide an update on advisory board membership, and to welcome new 2017 board members
To provide an opportunity for board members to meet each other To provide an update on CHA Board of Trustees activity
DISCUSSION The Center for Post-Acute Care represents the interests of CHA member post-acute care providers, including inpatient rehabilitation hospitals and units, long-term acute care hospitals, distinct-part skilled-nursing facilities, and home health agencies. As a part of CHA, the Center for Post-Acute Care serves as the primary public policy arm of the hospital association for post-acute care issues. Joining the advisory board as new members for 2017 are Cindy Calvillo, Executive Director, Utilization and Resource Management, Kaiser Permanente, David Brown System Director, Rehabilitation Services, Sharp HealthCare, Kirk Watson, Vice President, Business Development, Barlow Respiratory Hospital, and Terri Warren, Regional Executive Director, Senior & Community Services, Providence Health & Services, California Region. Additionally, Yameeka Jones, CEO, Vibra Hospital of San Diego, will serve the board as an ex-officio member as liaison to the American Hospital Association Section on Long Term Care and Rehabilitation. Attachment
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CENTER FOR POST-ACUTE CARE
2017 Advisory Board Roster
Chair Chair-Elect Adam Darvish Sr. Vice President, Hospital Division Kindred Healthcare 200 Hospital Circle Westminster, CA 92683 Phone: 714-893-4541 x5147 Fax: 714-899-5057 [email protected]
Term: 2011-2019
Tory Starr, MSN, PHN, RN Vice President of Care Management Sutter Health/Valley Area 2890 Gateway Oaks Drive, Suite 110 Sacramento, CA 95833 Phone: 916-649-4120 [email protected]
Term: 2015-2017
Past-Chair Pamela Chevreaux, MA Vice President, Ambulatory Services Long Beach Memorial Medical Center 2801 Atlantic Avenue Long Beach, CA 90806 Phone: 562-933-9010 Cell: 562-233-2556 Fax: 562-933-1904 [email protected]
Term: 2011-2017
Members Maria Cecilia Alpasan, MA, OTR/L Quality and Education Coordinator, Department of Rehabilitation Cedars-Sinai Medical Center 8700 Beverly Blvd. Los Angeles, CA 90048 Phone: 310-423-5243 [email protected]
Term: 2015-2017
Monique Bedi, BA, CRRN Acute Physical Rehab Services Coordinator Lodi Memorial Hospital 975 South Fairmont Avenue Lodi, CA 95240 Phone: 209-333-3092 [email protected]
Term: 2016-2018
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Laura Biscaro, RN Director of Care Management Santa Barbara Cottage Hospital PO Box 689 Santa Barbara, CA 93102 Phone: 805-324-9131 [email protected]
Term: 2016-2018
Patricia Bishop, MBA, RN Director of Nursing Ojai Valley Community Hospital 1306 Maricopa Highway Ojai, CA 93023 Phone: 805-640-2345 [email protected]
Term: 2016-2018
David Brown System Director of Rehabilitation Services Sharp Healthcare 2999 Health Center Drive San Diego, CA 92123 Phone: 858-939-3085 Cell: 858-722-0890 [email protected]
Term: 2017-2019
Sheila Brown, RN, MBA, FACHE Vice President, Continuum Care Palomar Health 125 Vallecitos De Oro, Suite A San Marcos, CA 92069 Phone: 760-739-2990 Cell: 858-613-4360 Fax: 760-510-8352 [email protected]
Term: 2014-2019
Cindy Cavillo, RN, BSN, MBA Executive Director, Utilization and Resource Management Kaiser Foundation Health Plan/Hospitals, Southern California Region 393 E. Walnut Street, 2nd Floor Pasadena, CA 91188 Phone: 626-405-5968 [email protected]
Term: 2017-2019
Lyndon Edwards, MBA, MHS Vice President and Administrator Loma Linda University Medical Center 25333 Barton Road Loma Linda, CA 92354 Phone: 909-558-4000 [email protected]
Term: 2016-2018
Paul Giles Director of Home Health Finance Dignity Health 20525 Via Lerida Yorba Linda, CA 92887 Phone: 415-987-6623 Fax: 415-591-2432 [email protected]
Term: 2014-2019
Linda Glomp, RN, BSN, MBA Executive Director St. Joseph Health, Home Health, Hospice, Infusion Pharmacy, Private Duty 1100 West Stewart Drive Orange, CA 92863 Phone: 714-712-7236 Fax: 714-712-7157 [email protected]
Term: 2011-2017
Ann Gors Chief Executive Officer Kentfield Rehabilitation & Specialty Hospital 1125 Sir Francis Drake Boulevard Kentfield, CA 94904 Phone: 415-485-3521 Fax: 415-485-3696 [email protected]
Term: 2015-2017
Lisa Harrold, LCSW Director, Rehabilitation and Skilled Nursing Services Kaweah Delta Health Care District 840 S Akers Road Visalia, CA 93277 Phone: 559-624-3854 Fax: 559-741-4725 [email protected]
Term: 2015-2017
Walter Hekimian, MBA Administrator Edgemoor DPSNF 655 Park Center Drive Santee, CA 92071 Phone: 619-596-5597 Fax: 619-596-5501 [email protected]
Term: 2014-2019
Shelly Necke, RN, BSN Vice President, Post-Acute Care Services PIH Health 15050 Imperial Highway La Mirada, CA 90638 Phone: 562-698-0811 x65014 [email protected]
Term: 2015-2017
Jan Potts, RN, MBA Chief Clinical Executive Sutter Care at Home 4830 Business Center Drive, Suite 140 Fairfield, CA 94534 Phone: 707-864-4556 Fax: 707-863-9043 [email protected]
Term: 2011-2017
Martha Samora, RN, CPHQ, FACHE Chief Executive Officer HealthSouth Bakersfield Rehabilitation Hospital 5001 Commerce Drive Bakersfield, CA 93301 Phone: 661-864-4073 Fax: 661-633-5254 [email protected]
Term: 2015-2017
Robert Walters, PT, MBA Director, Inpatient Rehabilitation Services John Muir Health 3480 Buskirk Avenue, #150 Pleasant Hill, CA 94523 Phone: 925-947-5252 [email protected]
Term: 2016-2019
Terri Warren Regional Executive Director, Home Health & Hospice, Transitions Programs Providence Health 501 S. Buena Vista St. Burbank, CA 91505 [email protected]
Term: 2016-2018
Kirk Watson Vice President, Business Development Barlow Respiratory Hospital 2000 Stadium Way Los Angeles, CA 90026 Phone: 213-304-7008 Fax: 213-202-6801 [email protected]
Term: 2016-2017
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Ex-Officio Patty Haggen Executive Director, Neurosciences, Orthopedics & Rehabilitation John Muir Health 1601 Ygnacio Valley Road Walnut Creek, CA 94598 Phone: 925-941-4050 Fax: 925-947-3380 [email protected]
Yameeka J. Jones Chief Executive Officer Vibra Hospital of San Diego 555 Washington Street San Diego, CA 92103 Phone: 619-686-4554 Cell: 619-405-8187 [email protected]
Regional Association Representatives David Serrano Sewell Regional Vice President Hospital Council of Northern & Central California 235 Montgomery St., Ste 1158 San Francisco, CA 94104 Phone: 415-616-9990 [email protected]
Jaime Garcia Regional Vice President Hospital Association of Southern California (HASC) 515 S Figueroa St, Suite 1300 Los Angeles, CA 90071-3300 Phone: 213-538-0700 [email protected]
Judith Yates Senior Vice President Hospital Association of San Diego & Imperial Counties 5575 Ruffin Road, Suite 225 San Diego, CA 92123 Phone: 858-614-1557 [email protected]
Staff
Patricia L. Blaisdell, FACHE Vice President, Continuum of Care California Hospital Association 1215 K Street, Suite 800 Sacramento, CA 95814 Phone: 916-552-7553 Fax: 916-554-2253 [email protected]
Rosie Lauborough Administrative Assistant California Hospital Association 1215 K Street, Suite 800 Sacramento, CA 95814 Phone: 916-552-7546 [email protected]
February 15, 2017 TO: Center for Post-Acute Care Advisory Board FROM: Patricia Blaisdell, Vice President, Continuum of Care SUBJECT: CHA Center for Post-Acute Care Report SUMMARY The CHA Center for Post-Acute Care offers representation for CHA members who provide inpatient rehabilitation, long-term acute care, skilled nursing, and home health and hospice services. ACTION REQUESTED
To provide an overview and update on CHA activities and role of the Center for Post-Acute Care.
To provide an update on Center operations, including provider forums. To review annual meeting activities and advisory board member responsibilities.
DISCUSSION
The Vice President for the Post-Acute Care provides support to the Center for Post-Acute Care and members of the advisory board.
The Center operates as a specialty center of the CHA, and provides input to CHA’s board of trustees and to CHA’s advocacy positions. Members of the advisory board will receive additional information regarding CHA structure, resources and achievements, as well as Center operational guidelines and guidelines for advisory board service.
The Center hosts regular provider forums open to employees of CHA member hospitals, and chaired by a designated member of the advisory board. For 2017, the forum chairs are: inpatient rehabilitation and therapy services: Martha Samora; skilled nursing and subacute care; Lisa Harrold; home health and hospice: Jan Potts.
The Center presents an annual conference each year, with educational sessions and policy updates of interest to the hospital community and post-acute care providers. This year’s meeting, “Making Connections: creating the community of care,” takes place after the current board meeting, on February 16 and 17, 2017.
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February 15, 2017 TO: Center for Post-Acute Care Advisory Board FROM: Patricia Blaisdell, Vice President, Post-Acute Care Services SUBJECT: Strategic Planning SUMMARY During previous meetings, advisory board members identified priorities for board activity for 2016. During the current meeting, board members will be asked to review and discuss current status of those priorities and next steps.
ACTION REQUESTED To conduct an in-depth discussion on the role of the Center for Post-Acute Care To review and previously established goals and activities. To discuss and identify next steps for Center Activity.
DISCUSSION The CHA Center for Post-Acute Care was created in 2011, with the following goals: (1) represent and support hospital-based post-acute providers, (2)foster communication and collaboration among and between member PAC provider groups, and (3)serve in an advisory capacity to the CHA Board of Trustees. Moreover, the operating guidelines of the Center provide that it will (a) provide advice and expert analysis on issues of importance, (b) cooperate with CHA on programs and activities and to support the positions and services of CHA, (c) communicate with members on matters of importance, and (d) conduct other activities approved by the CHA Board of Trustees. Board members are asked to review and update Center goals and activities that were developed in the 2016 strategic planning retreat, in a two-part process: Discussion Topic 1: Center Role and Responsibilities Advisory board members will be asked to discuss and share their perspectives on the role and responsibilities of the Center for Post-Acute Care, in the context of various constituencies. Specifically, advisory board members are asked to consider, discuss and respond to the following questions:
1. What is (or should be) the role of the Center in regards to CHA member post-acute providers? What are the major activities associated with this role?
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Federal Update February 15, 2017
Page 2
2. What is (or should be) the role of the Center in regards to non-post-acute care CHA
members? What are the major activities associated with this role?
3. What is (or should be) the role and responsibilities of the Center in regards to external groups (e.g., other PAC providers, home and community based services, consumer groups)? What are the major activities associated with this role?
Discussion Topic 2: Please review the Action Steps document, considering the following questions.
1. Are the objectives and goals still appropriate and relevant? What changes or additions would you make, if any?
2. Are the identified activities still relevant? Can you suggest additional activities?
3. Which activities do you believe are most important for the Center’s work in 2017?
Attachment
CHA
Cent
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r Pos
t-Ac
ute
Care
Goa
ls a
nd A
ctiv
ities
Prio
rity:
Adv
ocac
y –
Influ
ence
Leg
isla
tion
and
Regu
latio
n
Su
gges
ted
Actio
n St
ep
Ong
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Act
ivity
N
ext s
teps
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e fr
ame
“I
ssue
s” p
aper
to c
omm
unic
ate
with
legi
slato
rs
CHA,
CPA
C de
velo
ps is
sue
pape
rs o
n le
gisla
tive
issue
s as t
hey
arise
.
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l Adv
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a co
mm
ents
on
prop
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rule
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mm
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Dist
ribut
e fe
dera
l iss
ue p
aper
s re
: pos
t-ac
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care
re
form
; by
6/1/
2016
Co
ntin
ue o
ngoi
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dvoc
acy
on st
ate
and
fede
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issue
s; o
ngoi
ng
Cons
isten
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to c
are
at a
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as
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adv
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s; o
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stat
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d fe
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s ind
icat
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pro
pose
d ru
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IMPA
CT
impl
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ass
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catio
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s reg
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ongs
t acu
te h
ospi
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and
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le su
mm
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ana
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re p
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t all
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regi
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tions
re: o
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21
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te M
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for j
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OPS
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ater
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avai
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st-b
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nsiti
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pare
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taSu
ite R
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ts
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ablis
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ips a
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s the
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ater
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ssio
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re: i
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ifyin
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rtne
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ps; T
BD.
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hat a
bout
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at p
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DATE: February 15, 2017 TO: Center for Post-Acute Care Advisory Board FROM: Pat Blaisdell, Vice President, Continuum of Care SUBJECT: Proposal for Development of Post-Acute Care Educational Resource/Toolkit This communication proposes the development of comprehensive member resources regarding post-acute care services, including their role in delivery system reform, financial implications for hospitals, and associated strategies for partnership and integration. In creating this resource, the Center for Post-Acute Care seeks to provide meaningful support to CHA members at all levels of the care continuum. The project would be funded through use of existing assets that have been designated for education or research related to rehabilitation services. Background Post-acute care plays a critical role in the health care delivery system. By providing essential medical and rehabilitative care to individuals following an acute hospital stay, post-acute providers, including long term acute hospitals (LTCHs), inpatient rehabilitation facilities (IRFs), skilled nursing facilities (SNFs) and home health agencies (HHAs), contribute to achievement of optimal patient outcomes while reducing health care costs. PAC services have been demonstrated to be critical to the financial and clinical success of hospitals. For example, CMS has reported that successful ACOs demonstrated significantly reduced utilization of PAC services1. Additionally, data from the Bundled Payment for Care Improvement (BPCI) pilots reveals that financial savings in orthopedic bundles are attributable to decreased use of institutional PAC services and do not result in a negative impact on quality of care or outcome2. Previous CHA educational programs have recognized the important role of post-acute care services. Last year’s Population Health Management series identified post-acute care services as a component of PHM. Among the “new required competencies” outlined in CHA’s “Transforming for Tomorrow” is the development of provider networks and improved care coordination and transitions of care. Additionally, management of post-acute care was a significant component of the successful CHA seminar on the Comprehensive Care for Joint Replacement (CJR) program. 1. CMS (2015), Medicare Shared Savings Program Webinar; Performance Year 2014 Quality Performance and Financial
Reconciliation for ACOs with 2012, 2013,, and 2014 start dates 2. CMS Bundled Payments for Care Improvement initiative Model 2-4. Year 2 Evaluation & Monitoring Annual Report, The
Lewin Group, August 2016
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2 Proposal for Development of Post-Acute Care Education Resource/Toolkit February 15, 2017
Previous CHA educational programs have recognized the important role of post-acute care services. Last year’s Population Health Management series identified post-acute care services as a component of PHM. Among the “new required competencies” outlined in CHA’s “Transforming for Tomorrow” is the development of provider networks and improved care coordination and transitions of care. Additionally, management of post-acute care was a significant component of the successful CHA seminar on the Comprehensive Care for Joint Replacement (CJR) program. Despite PAC’s key role, understanding of post-acute care is limited. While many/most CHA members own and operate at least one post-acute care service, operational and financial management of PAC often remains separate from acute care, with limited communication and collaboration. Similarly, hospital leaders often lack the information and strategies needed to effectively partner with both internal and community-based PAC providers. Proposal Members of the CHA Center for Post-Acute Care advisory board advisory board members provided input regarding the goals, content and design of the proposed project. Audience The program/resource will be directed toward key members and leadership of CHA member hospitals and health systems. Specific job categories identified as targets include CEOs, COOs, CFOs, and CNOs, as well as chief strategy officers. Board members felt strongly that the materials/program should also be directed toward CMOs and other key members of physician leadership. Case management personnel and leadership will also be included. Content Role and value of post-acute care services Member input regarding content focused on the communication of value and perceived value of post-acute care services to the target audience(s). Members were in agreement that hospital leadership is most interested in the financial implications of post-acute care and how PAC utilization will impact the bottom line. One commenter observed that the program should include “how PAC services can 1) decrease costs, 2) improve outcomes, and 3) keep patients happy.” An effective program will communicate the contribution of PAC to alternative payment models such as ACOs, episodic payment models, as well as implications for population health management. Post-acute care services
• Current configuration of PAC services and providers (IRFs, LTCHs, SNFs, and HHAs), including regulatory requirements and reimbursement.
• Discussion of anticipated changes to PAC payment, in particular the likely design and implementation of a unified PAC PPS and related financial and clinical implications.
3 Proposal for Development of Post-Acute Care Education Resource/Toolkit February 15, 2017
Associated topics • The integral role of the physician and physician leadership and the implications of
MACRA. • Other non-PAC services areas to consider: palliative care, case management. • Implications for information systems, including data exchanges, electronic medical
records, etc. • The role of home and community based services • Inclusion of patient stories and narratives to support content • Management of the complex patient • Social determinants of health.
Partnership Members observed that providers are interested in establishing effective partnerships with post-acute care providers, including any PAC services the hospital/health system owns and operates as well as non-hospital based providers such as free-standing SNFs and independent HHAs. The proposed program will include strategies and models for approaching these partnerships as well as examples of best practices. Format Members suggested that a resource book/tool-kit be developed for distribution and issued in association with a member webinar. The webinar would provide a broad overview of the role and value of post-acute care services and key issues, and the resource book would include in-depth information and reference material. The materials would be provided at minimal or no cost to members, so as to ensure broad access and dissemination. Funding The project would be funded by existing unrestricted net assets of $128,900 which are currently held in the California Health Foundation and Trust (CHFT) (please see accompanying schedule). The funds were contributed in 2006 when the medical division of the California Rehabilitation Association (CRA) merged with CHA and the CHA Center for Medical Rehabilitation Services (CMRS) was created. Under the terms of the merger agreement, the funds are to be used for educational or research purposes, based upon the recommendation of the CMRS advisory board. In 2011, CMRS was integrated into the CHA Center for Post-Acute Care. The advisory board of the Center for Post-Acute Care has recommended that CHA pursue this educational project. Implementation plan An external consultant would be hired to develop the program content, managed by Pat Blaisdell with input from the Center for Post-Acute Care advisory board. Graphic design or other external resources may be necessary to develop program materials. The education and publications department would provide support for publication and delivery of the associated webinar. As noted previously, these external resources would be funded through use of existing assets that have been designated for education or research related to rehabilitation services.
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4 Proposal for Development of Post-Acute Care Education Resource/Toolkit February 15, 2017
Summary The CHA Center for Post-Acute Care proposes the development of resources for CHA member hospitals and health systems providing essential information regarding the role and value of post-acute care and effective strategies to integrate and partner with providers across the continuum of care. The content of the program will focus on the needs of CHA member hospitals and health systems and will build on previous educational and resource information provided by CHA.
February 15, 2017 TO: Center for Post-Acute Care Advisory Board FROM: Pat Blaisdell, VP Continuum of Care SUBJECT: Current issues/ legislative and regulatory updates SUMMARY Regulatory and legislative activities at both the federal and state levels have significant implications for CHA member post-acute care providers. The advisory board of the CHA Center for Post-Acute Care monitors relevant issues on an ongoing basis, with a goal of providing important information to post-acute care members as well as informing CHA state and federal advocacy. ACTION REQUESTED To provide an update regarding the current status of legislative efforts to repeal and
replace the Affordable Care Act. To provide an update on CA state budget and impact on hospitals, including implications
for the Cal MediConnect (CMC) and the Coordinated Care Initiative (CCI). To discuss the upcoming legislative session and anticipated legislation of interest to
hospitals and post-acute care providers. To provide updates and status reports on provider issues and other areas of interest.
DISCUSSION
A. Federal Update The 115th Congress convened on Jan. 3 in Washington, DC. President Trump was sworn in on January 20.
Affordable Care Act/“Repeal and Replace” One of the first items on the agenda for the Republican majority in Congress is to move quickly to repeal the Affordable Care Act (ACA). CHA has developed talking points and additional materials, with a focus on the increased access to services provide by the ACA, as well as the financial impact on hospitals of repeal.
Regulations President Trump has issued several executive orders or other directives that may result in
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Current Issues February 15, 2017
Page 2
delays or changes in the communication and implementation of new regulations. The impact of these directives on recent or pending rules and regulations is unclear. CHA maintains a full-time presence in Washington, D.C., to effectively advocate on legislative and regulatory policy, and will provide additional information to CHA members as needed.
B. State Update The California Legislature returned on Jan. 4 to Sacramento for the 2017-18 legislative session. Additionally, Governor Brown released his 2017-18 budget proposal on January 10.
Budget The Governor has released his state budget plan of $177 billion for the 2017-18 fiscal year. In presenting the plan, the Governor stressed the need to practice fiscal prudence, as California’s growth has slowed down with revenues coming in below projections by $1.3 billion.
The budget continues implementation of federal health care reform, which includes the expansion of Medi-Cal to cover childless adults with incomes up to 138 percent of the federal poverty level. Caseload in Medi-Cal has increased from 7.9 million in 2012-13 to a projected 14.3 million in 2017018, covering over one-third of the state’s population. Beginning this year, the state assumes a 5 percent share of cost for the optional expansion population. For now, this budget continues to reflect existing state and federal law. In regards to the Coordinated Care Initiative (CCI), the budget concludes that CCI does not meet statutory savings requirements and therefore discontinues several specific provisions of CCI that address IHHS. The components proposed to be discontinued are: (1) remove IHSS benefits from plan capitation rates, (2) eliminate statewide authority responsible for bargaining IHSS workers’ wages and benefits in the seven CCI counties; and (3) re-establish the state-county share of cost arrangement for the IHSS program that existed prior to the implementation of CCI. The net result of these three changes is a General Fund savings of $626.6 million in 2017-18. However, the budget proposes to extend the Cal MediConnect program, continue mandatory enrollment of dual eligibles, and the integration of long-term services and supports, except IHSS, into managed care. It also encourages plans and counties to continue collaboration on care coordination.
The release of the Governor’s budget begins the formal budget process. Over the next several months budget subcommittees will hold hearings on the various aspects of the budget. In mid-May the Governor will release a revised budget plan that reflects the most up-to-date revenue and expenditure information as well as any changes affecting health care coming out of Washington, D.C.
Legislation CHA monitors proposed legislation and will identify and track bills of particular interest to CHA member hospitals. At this early stage of the legislative session, bill proposals are in the process of being introduced.
Current Issues February 15, 2017
Page 3
Unrepresented Patient A 2015 court decision, California Advocates for Nursing Home Reform (CANHR) v. Chapman (Director of the Department of Public Health), declared unconstitutional a California statute that permits skilled nursing facilities (SNFs) to use an interdisciplinary team to make medical decisions for a patient who lacks capacity and has no family or other representative to make these decisions. During the 2016 recent legislative session, the California Department of Public Health (CDPH) proposed legislation on this issue, but withdrew the bill from consideration when they were unable to adequately address stakeholder concerns. CHA has been working in coordination with the California Association of Health Facilities (CAHF) and the California Medical Association (CMA) to develop legislative language and to introduce legislation during the current legislative session.
C. Provider Issues The CHA Center for Post-Acute Care continues to monitor issues that impact post-acute care providers in the hospital community. Issues are identified based on federal and state legislative and regulatory action, or in responses to issues and concerns identified by members. Provider forums provide an opportunity to monitor these issues and engage in discussion an action planning when necessary.
Among the current issues that are being followed are: third party reimbursement denials based on therapy utilization (IRF), readmission measures and value based purchasing (SNF), and revised conditions of participation (home health).
Durable Medical Equipment At CHA’s request, CMS Region IX conducted a webinar for hospital case managers regarding policies and procedures for ordering and obtaining durable medical equipment, prosthetics, orthotics and supplies (DMEPOS). The content, which was developed in consultation with CHA, included coverage policies, documentation, identification of a supplier, and complaint/problem resolution. The webinar was part of CHA’s ongoing work to address member concerns regarding delays and other issues encountered when ordering medically necessary durable medical equipment (DME) since the initiation of the Centers for Medicare & Medicaid Services (CMS) Competitive Bidding Program.
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Revisiting the Affordable Care Act Talking Points
January 4, 2017
California hospitals have long supported affordable health coverage for all Californians. CHA’s priority is preserving coverage for the 3.7 million Californians and 21 million Americans who gained coverage under the Affordable Care Act (ACA) through the Medicaid expansion, and millions more who purchased insurance because of the premium subsidy. CHA supports keeping existing coverage for millions of Californians until a viable replacement is passed by Congress and signed into law. Key delivery system reforms, adequate payment rates and quality improvement efforts must be maintained. If policymakers choose to repeal the ACA without offering a replacement bill, it is essential that they either put the savings from repeal into a reserve fund to be used for future replacement efforts, or eliminate the payment reductions for hospital services that were part of the ACA.
A new study from Dobson|DaVanzo found that, if the ACA is repealed without an accompanying bill providing simultaneous coverage, the net impact to hospitals nationwide from 2018 to 2026 would be $165.8 billion from the loss of coverage.
Hospitals also sustained reductions — as did other stakeholders — under the ACA that were
redeployed to help fund coverage for millions of Americans. The Dobson|DaVanzo study found that, if the ACA is repealed and Medicare inflation update reductions for inpatient and outpatient hospital services are not restored, funding would be reduced by $289.5 billion between 2018 and 2026 nationwide (more than $50 billion in cuts to California hospitals)
On top of that, failing to fully restore both Medicare and Medicaid disproportionate share hospital
(DSH) payments would add another $102.9 billion in cuts to hospitals.
The combined losses from the Medicare and Medicaid cuts cited above, $50 billion in California, would be devastating. Many hospitals’ viability would be threatened, and millions of Californians would lose access to care.
The Medicare Payment Advisory Commission estimated in March 2016 that hospital Medicare margins would drop to an all-time low of negative 9 percent in 2016. Cuts described above could push the losses to an estimated negative 15 percent margin by 2026.
For many hospitals and health systems, these cuts are not sustainable.
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Infants
1-18
19-44
45-54
55-64
65-74
75-84
85 - Over
Californians
of all ages
benefit from
the Medi-Cal
expansion
• 1 in 3 California residents rely on Medi-Cal for coverage
• 3.7 million children, family members and seniors gained
coverage through the Medi-Cal expansion
• The Medi-Cal expansion provides coverage for more than an
estimated 1 million children, nearly a half million seniors, and
more than 1 million low-income working individuals
• The Medi-Cal expansion covers a diverse population,
including nearly 2.4 million Latinos, African Americans and
Asian Californians
California Counties
Estimated
Enrollment
Allowed Under
the ACA
Expansion
Alameda 94,033 Alpine 97 Amador 2,319 Butte 23,797 Calaveras 3,428 Colusa 2,477 Contra Costa 74,448 Del Norte 4,146
El Dorado 10,485 Fresno 141,916 Glenn 3,404 Humboldt 18,479 Imperial 26,477 Inyo 1,468 Kern 108,463 Kings 16,200 Lake 10,760 Lassen 2,688 Los Angeles 1,050,790 Madera 19,404 Marin 13,280 Mariposa 1,362 Mendocino 13,788 Merced 45,463 Modoc 1,082 Mono 930 Monterey 54,584 Napa 10,438 Nevada 7,307 Orange 280,643 Placer 17,067 Plumas 1,631 Riverside 229,771 Sacramento 157,036 San Benito 2,697 San Bernardino 234,212 San Diego 242,852 San Francisco 55,821 San Joaquin 50,573 San Luis Obispo 20,046 San Mateo 41,520 Santa Barbara 42,564 Santa Clara 119,784 Santa Cruz 25,507 Shasta 22,686 Sierra 204 Siskiyou 6,191 Solano 41,730 Sonoma 40,830 Stanislaus 104,225 Sutter 11,477 Tehama 7,351 Trinity 1,673 Tulare 71,677 Tuolumne 4,136 Ventura 74,805 Yolo 18,886 Yuba 8,889
Total 3,700,000
Californians Gained Stability and Access to
Health Care From the Medicaid Expansion
December 8, 2016 coverage estimates include estimated allocations and distribution information from DHCS enrollment by county, age and ethnicity found on the DHCS website at www.dhcs.ca.gov.
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February 7, 2017 TO: Center for Post-Acute Care Board FROM Alyssa Keefe, Vice President Federal Regulatory Affairs [email protected] or 202-488-4688 SUBJECT: Federal Regulatory Report
1. Trump Administration Executive Actions as of February 7th. As President Trump awaits confirmation of his cabinet and congressional action on the Affordable Care Act, he has taken a number of executive actions that have implications for health policy and federal regulatory activity going forward. Among the executive actions include an executive order related to reducing burden under the Affordable Care Act, as well as executive orders and presidential memorandums directing a temporary freeze on federal regulatory activity, and requirements to reduce regulatory burden. The environment in Washington has been dynamic and unpredictable in the early weeks of the Trump Administration, and the information in this report is current as of February 7, but is subject to change. President Trump has indicated that he will unveil additional health policy plans following the confirmation of his nominee for Secretary of Health and Human Services (HHS), Rep. Tom Price, and Centers for Medicare & Medicaid Services (CMS) Administrator, Seema Verma. Obama Administration HHS Deputy Secretary Norris Cochran is serving as Acting HHS Secretary, and Patrick Conway, former Deputy Administrator for Innovation and Quality & CMS Chief Medical Officer, is serving as Acting CMS Administrator until the confirmation of Tom Price and Seema Verma. CHA is carefully tracking and analyzing all executive actions, which are listed on our Federal Regulatory Tracker. CHA will continue to inform members of additional executive actions through CHA News. A short summary of specific executive actions is below.
• Executive Order to Reduce Regulatory Burden: The executive order requires federal agencies to identify two regulations to be eliminated for each new regulation issued. It also requires that the cost of planned regulations be managed and controlled through the budgeting process. For federal fiscal year (FFY) 2017, the executive order requires the incremental cost of new regulations to be offset by the removal of existing regulations so that the total incremental cost of new regulations is no greater than zero. Beginning in FFY 2018, as part of the Presidential budget process, the Office and Management and Budget (OMB) is instructed to identify a total amount of incremental cost that will be allowed for each agency in issuing new regulations and repealing existing regulations for the next fiscal year. On Feb. 2, OMB issued interim guidance on Section 2 of the executive order, which describes the requirements for FFY 2017. The guidance clarifies that the executive order applies to “significant regulations,” defined as regulations that impose an annual economic cost of $100 million or more. The guidance states that federal spending rules that primarily cause income transfers from tax payers to program beneficiaries, such as Medicare spending rules, are considered transfer rules and not subject to the executive order. However, if the rules also impose requirements — such as reporting requirements — on non-federal entities, the agency would be required to offset those costs. In addition, the executive order’s application to significant guidance or interpretive documents will be addressed on a case-by-case basis.
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The executive order requires significant further guidance from OMB, and a number of unanswered questions related to how agencies will implement the order remain.
• Memorandum on Regulatory Freeze: White House Chief of Staff, Reince Priebus, issued a memo on Jan. 20 to the heads of all executive departments and agencies freezing new and pending federal regulatory activity until the President’s appointees or designees have had the opportunity to review any new, recently finalized or pending regulations. The memo, which is common for an incoming administration, addresses regulations that have been sent to the Office of the Federal Register but not yet published, as well as regulations that have been published in the Federal Register but were not yet effective on Jan. 20. The memo instructs federal agencies to withdraw any regulation not yet published for review and approval by the Trump Administration. In addition, it temporarily postpones the effective date of any regulations that were not yet in effect by Jan. 20 for at least 60 days following the issuance of the memo, subject to review and approval by Trump appointees. If the administration chooses to delay implementation beyond 60 days, it would be required to proceed through notice and comment. An OMB memorandum published on Jan. 24 provided additional instruction to agencies on the implementation of the freeze. A list of final regulations relevant for hospitals that have been published but have effective dates later than Jan. 20 is available on CHA’s website. CHA is currently monitoring all administrative activity on these matters and will advise the membership of any substantive deadline changes through CHA News.
• Executive Order on Reducing Affordable Care Act Burden: The executive order directs the Department of Health and Human Services (HHS) and other federal agencies to “exercise all authority and discretion available to them to waive, defer, grant exemptions from, or delay the implementation of any provision or requirement of the Act that would impose a fiscal burden on any State or a cost, fee, tax, penalty, or regulatory burden on individuals, families, healthcare providers, health insurers, patients, recipients of healthcare services, purchasers of health insurance, or makers of medical devices, products, or medications.” The order does not reference Medicaid specifically but directs the agencies to “provide greater flexibility to States and cooperate with them in implementing healthcare programs.” The executive order does not include specific details on the substance or timing of potential modifications to the ACA, and a number of unanswered questions remain.
2. Additional Federal Regulatory Updates
In the final weeks of the Obama Administration, a number of final rules were issued, including a regulation finalizing a new episode payment model for cardiac care, as well as the final rule limiting Medicaid managed care pass through payments, both described in more detail below. However the final rules are subject to changes to the effective date under the Trump Administration’s regulatory freeze, and CHA will notify members of any changes in timelines as information becomes available. In addition, the Obama Administration announced that it would not finalize its Medicare Part B payment model regulation and final HRSA guidance on the 340B program was withdrawn from consideration by OMB. However, the following outstanding Obama Administration regulations remain, and CHA expects they will be finalized in some form: Discharge Planning Conditions of Participation Final Rule, and the Antibiotic Stewardship, Infection Control, and Non-Discrimination Conditions of Participation Final Rule. In addition, a number of regulations issued during the Obama Administration remain subject to the Congressional Review Act (CRA), an oversight tool that allows Congress to consider a joint resolution of disapproval that provides the final rule shall not take effect. A provision in the CRA allows lawmakers in a new Congress to disapprove of any final rule that was submitted within 60
legislative days of adjourning the previous Congress. The Congressional Research Service estimates that any final rule published after May 30, 2016 could be subject to repeal. Policies that may be subject to CRA review include: requirements for long-term care facilities, policy and payment rate changes for outpatient and ambulatory surgical centers, emergency preparedness conditions of participation requirements, health IT certification, etc. Congress has yet to take action on any of these health care related regulations. Below is more information on Federal Regulatory Activity prior to the Trump Administration with a focus on the topics of interest to the CPAC Board
MedPAC Draft Recommendations for 2018 Payment Updates
The Medicare Payment Advisory Commission (MedPAC) has voted unanimously to pass draft recommendations on Medicare fee-for-service payment and policy changes as well as Medicare Advantage, as required by law. These recommendations, directed at Congress and the Department of Health and Human Services Secretary, are for calendar and federal fiscal year (FFY) 2018. MedPAC’s recommendations are available at www.calhospital.org/cha-news-article/medpac-releases-draft-recommendations-2018-payment-updates.
New Patient Status Notification Requirements
CMS has posted its final version of the Medicare Outpatient Observation Notice (MOON), a standard notice that all hospitals and critical access hospitals must provide to Medicare beneficiaries who receive outpatient observation services for more than 24 hours. All hospitals and critical access hospitals (CAHs) are required to provide the MOON beginning no later than March 8, 2017. Hospitals should note that recently signed state legislation requires hospitals to provide similar notice beginning Jan. 1, 2017. Per California law, hospitals will be required to provide a written notice to a patient on observation status who is cared for in a hospital’s inpatient unit or in an observation unit, or following a change in a patient’s status from inpatient to observation. The notification must be provided as soon as practicable. The law requires the notice to state that while on observation status, the patient’s care is being provided on an outpatient basis, which may affect his or her health care coverage reimbursement, but does not mandate a specific form. CHA is planning a member webinar tentatively scheduled for February 14. Registration information is available at http://www.calhospital.org/observation-services-notification-web
Report on Social Risk Factors in Medicare Quality Payment Programs
The Office of the Assistant Secretary for Planning and Evaluation (ASPE) at the U.S. Department of Health and Human Services (HHS) recently issued a long awaited report on the impact of social risk factors on Medicare pay-for-performance programs. The report, which was required by the Improving Medicare Post-Acute Care Transformation (IMPACT) Act of 2014, found that beneficiaries with social risk factors had worse outcomes on many quality measures, regardless of the providers they saw, and that dual enrollment in Medicare and Medicaid was the most powerful predictor of poor outcomes. It also found that providers that disproportionately served beneficiaries with social risk factors tended to have worse performance on quality measures. However, while the report found that some performance differences were driven by beneficiary
37
mix, some of the differences persisted even after adjustment for beneficiary characteristics. APSE recommended a three part strategy for addressing concerns regarding social risk factors in the performance programs. First, performance on quality and outcomes should be measured and reported specifically for beneficiaries with social risk factors. Second, high but fair quality standards should be set for all beneficiaries. Third, better outcomes for beneficiaries with social risk factors should be rewarded and supported with targeted financial incentives and technical assistance to providers. The full report is available for download at https://aspe.hhs.gov/sites/default/files/pdf/253971/ASPESESRTCfull.pdf
Home Health Conditions of Participation Finalized CMS has finalized revised conditions of participation (CoPs) outlining the minimum health and safety standards that a home health agency must meet to be certified for participation in the Medicare and Medicaid programs. The finalized changes include provisions on patient assessment, patient/caregiver communications, quality assessment and performance improvement, and care coordination. The final rule is available at www.calhospital.org/cha-news-article/cms-issues-new-cops-home-health-agencies.
February 15, 2017 TO: Center for Post-Acute Care Advisory Board FROM: Patricia Blaisdell, Vice President, Post-Acute Care Services Alyssa Keefe, Vice President, Federal Regulatory Affairs. SUBJECT: IMPACT Act Data Collection and Measure Development SUMMARY The Improving Medicare Post-Acute Care Transformation (IMPACT) Act of 2014 requires the submission of standardized assessment data from post-acute care providers, including inpatient rehabilitation facilities (IRFs), long term acute care hospitals (LTCHs), skilled nursing facilities (SNFs), and home health agencies (HHAs). The act specifies specific assessment and quality domains, and that the “data be standardized and interoperable so as to allow for the exchange of such data among such post-acute care providers ……. in order to provide longitudinal information for such providers to facilitate coordinated care and improved Medicare beneficiary outcomes.” ACTION REQUESTED To provide an update regarding implementation of the IMPACT Act of 2014.
To solicit input on topics associated with the development of post-acute care cross-setting
standardized assessment data, to inform CHA input to the Centers for Medicare and Medicaid Services (CMS).
DISCUSSION
Implementation of the provisions of the Improving Medicare Post-Acute Care Payment Transformation (IMPACT) Act continues, including development and implementation of new quality measures and patient assessment requirements, and changes to requirements for discharge planning. On behalf of members, CHA continues to monitor these changes and to submit comments and input as indicated.
The Centers for Medicare & Medicaid Services (CMS) is soliciting comments on standardized post-acute care assessment-based data items. The items address cognitive function and mental status; special services, treatments, and interventions; medical conditions and co-morbidities; and impairments. CMS and their associated contractors have sent out multiple requests addressing
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IMPACT Act Data Collection and Measure Development February 15, 2017
Page 2
various aspects of measure development and implementation, often with short time frames for response. As a result, CHA member hospitals have been challenged to respond and provide meaningful input. In response to a request from CHA, CMS and CMS contractors have agreed to participate in a conference call discussion with CHA regarding IMPACT Act measure development and pilot testing. The call is scheduled for: Wednesday, February 22, from 10:00 to 11:30 am (Pacific Time)
February 15, 2017
The Improving Medicare Post-Acute Care Transformation Act of 2014
In late 2014, Congress passed The Improving Medicare Post-Acute Care Transformation (IMPACT) Act. The Act require post-acute care providers, including long-term acute care hospitals (LTCHs), inpatient rehabilitation facilities (IRFs), skilled-nursing facilities (SNFs) and home health agencies (HHAs) to collect and report standardized assessment data as a first step in developing recommendations for alternative post-acute care payment models. Included below are some of the major provisions and current implementation status: Standardized patient assessment data The Act requires PAC providers to report standardized patient assessment data at admission and discharge and shall include functional status, cognitive function and mental status, special services, medical condi-tion, impairments, prior functioning and any other categories as determined by the Secretary to be neces-sary and appropriate.
Current status: Significant changes to provider data sets implemented October 1, 2016. Additional changes pending.
New quality measure reporting The Act requires the identification of additional quality measures that shall address, at a minimum, func-tional status and change in function, skin integrity and changes in skin integrity, medication reconcilia-tion, incidence of major falls, and patient preference and discharge options.
Current status: Required reporting on several new measures began October, 2016; additional measures to be implemented in subsequent years; measure development and pilot testing is ongoing.
Resource use measures The Act also directs HHS to require the reporting of data on resource use. At a minimum, the resource use measures must address Medicare spending per beneficiary, discharge to community and risk-adjusted hospitalization rate of potentially preventable readmissions. The measure for spending per beneficiary must be standardized for geographic payment rate differences and must consider aligning the measure to episode length.
Current status: Measure development and pilot testing is ongoing.
Implications for Discharge Planning The Act requires that, by January 1, 2016, conditions of participation for general acute care hospitals, critical access hospitals, and PAC providers be revised to require that providers take into account quality, resource use, and other measures to inform discharge planning, and must include procedures to address patients’ treatment preferences and goals of care.
Current status: CMS has issued a proposed rule on changes to discharge planning requirements for hospitals and home health agencies. Comment period concluded January 4, 2016.
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The IMPACT Act of 2014 Highlights February 15, 2017
Page 2
Feedback Reports By October 1, 2017 for SNF, IRF and LTCH and January 1, 2018 for HHA, PAC providers shall receive confidential feedback reports on their performance with respect to all resource use measures under the applicable reporting provisions.
Current status: SNFs, IRFs and LTCHs have started to receive feedback reports on some measures. Public Reporting By October 1, 2018, for SNFs, IRFs, and LTCHs and by January 1, 2108, for HHAs, a procedure shall be established to make available to the public information regarding PAC provider performance related to the resource measures.
Current status: Some information is being publicly reported. IRF Compare and LTCH Compare websites are active. More measures and information will be added in the future.
Payment Consequences The Act creates payment consequences for failing to report standardized assessment data, quality, resource use and other measures under applicable reporting programs, and establishes a new “SNF Quali-ty Reporting Program” at the start of FY 2019, which will reduce the annual SNF market basket update by 2 percent for SNFs that fail to report quality measures or assessment data under the program. SNF value based purchasing, under which payment will also begin in FY 2019, based on readmission rates in 2017. Studies of Alternative PAC Payment Models The Act requires studies of alternative payment models for the provision of post-acute care services.
Current status: The first required report by the Medicare Payment Advisory Commission (MedPAC), was submitted to Congress in June, 2016. In the report, MedPAC concluded that that a unified post-acute care payment system is feasible, highly desirable, and within reach, and recommended a long term goal of developing a reimbursement system based on episode-based payments. In the short term, MedPAC recommended that CMS policy changes move toward payment based on patient characteris-tics, and consider flexibility on certain setting- specific requirements.
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CENTER FOR POST-ACUTE CARE ADVISORY BOARD
2017 MEETING SCHEDULE
WEDNESDAY, FEBRUARY 15, 2017 1:00pm – 5:00pm
Hilton Waterfront Resort Huntington Beach, CA
WEDNESDAY, APRIL 26, 2017
10:00am – 2:30pm CHA- Board Room
1215 K Street, Suite 800 Sacramento, CA 95814
WEDNESDAY, JULY 26, 2017
10:00am – 2:30pm St. Joseph Health – 2A Conference Room 200 W. Center Street Promenade, STE 200
Anaheim, CA 92805
WEDNESDAY, OCTOBER 25, 2017 10:00am – 2:30pm CHA- Board Room
1215 K Street, Suite 800 Sacramento, CA 95814
Wednesday, December 13, 2017
11:00am – 12:00pm Conference Call 800-882-3610 Pass Code: 4920025#
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