CHA has submitted comments to the Centers for Medicare & Medicaid Services (CMS) on its release of preliminary findings from the national beta test of standardized patient assessment data elements (SPADEs).
Late last year, CHA participated in a meeting hosted by CMS and the RAND Corporation, where an overview of the findings was presented. CHA is still reviewing the information and intends to provide additional comment. In this initial comment letter, CHA urges CMS to release the beta test data set so that other stakeholders can conduct analysis for the agency’s consideration. In addition, CHA raises concerns about the patients for whom data was not collected, particularly those with cognitive impairments or whose primary language is not English. CHA will continue to engage with CMS and members on these and other important issues.
The beta test was conducted in 143 post-acute care (PAC) facilities, across 14 markets, from November 2017 to September 2018. CMS is currently working to develop, implement and maintain standardized PAC patient assessment data. This test was intended to determine the reliability, validity and ease of use of data elements in four PAC settings: home health agencies, skilled-nursing facilities, inpatient rehabilitation facilities and long-term care hospitals. The data collected by SPADEs, if found to be reliable and valid, will enable CMS to compare patients’ clinical characteristics across PAC settings, beyond existing claims and patient assessment data. It would also be used to inform future payment reforms, such as a unified PAC prospective payment system.
CHA appreciates CMS’ efforts to make available early findings for review and discussion, and urges continued dialogue with stakeholders in the implementation of the Improving Medicare Post-Acute Care Transformation (IMPACT) Act.