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CHA Comments on Long-Term Care Hospital PPS Proposed Rule for FFY 2020

For Reimbursement Staff

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CHA has submitted a comment letter on the Centers for Medicare & Medicaid Services’ (CMS) federal fiscal year (FFY) proposed rule for the long-term care hospital (LTCH) prospective payment systems (PPS). 

In the letter, CHA expresses concern about the impact of a duplicative budget-neutral adjustment to the site-neutral rate that is applied to some LTCH patients under the dual rate system established for cost reporting periods beginning after Oct. 1, 2015.

CHA also comments on CMS’ proposals to add multiple new standardized patient assessment data elements (SPADEs) to the LTCH care data set and recommends that CMS reduce the speed and scope of SPADE implementation, create a transparent data analysis plan, develop a framework to prioritize SPADEs, and adopt a staged implementation plan. The comment letter also addresses how proposed changes to the area wage index would impact post-acute care providers in California.