Continuum of Care

About Continuum of Care

Post-acute care — often provided at inpatient rehabilitation facilities, long-term care hospitals, skilled-nursing facilities, and at patients’ homes — is vital to the health care delivery system. These providers deliver essential medical and rehabilitative services following hospital care. Hospital case managers help support, and connect patients, families, and caregivers through communication and coordination with post-acute care providers and home and community-based services. This includes the development of a discharge or transition plan that addresses the patient’s goals, needs and treatment preferences, and prepares patients and caregivers for post-discharge care.

CHA Issues Summary of FFY 2025 LTCH PPS Final Rule

What’s happening: CHA has issued a summary of the finalized payment updates and policies for long-term care hospitals (LTCHs) for federal fiscal year (FFY) 2025.  

What else to know: The policy and payment provisions are generally effective for FFY 2025 discharges, beginning Oct. 1.   

New CMS Requirements for Reporting of Hospital Respiratory Data to NHSN

What’s happening: Beginning on Nov. 1, the Centers for Medicare & Medicaid Services (CMS) will require acute care hospitals and critical access hospitals to electronically report information via the National Healthcare Safety Network (NHSN) about COVID-19, influenza, and respiratory syncytial virus (RSV). 

What else to know: CMS will also require hospitals to provide a weekly snapshot of hospitalizations, admissions, bed capacity and occupancy, and weekly totals for new admissions for COVID-19, influenza, and RSV to provide situational awareness of the impact of these respiratory diseases.  

Summaries Available: FFY 2025 Post-Acute Care Payment Final Rules

What’s happening: The Centers for Medicare & Medicaid Services (CMS) issued its final payment rules for inpatient rehabilitation facilities (IRFs), skilled-nursing facilities (SNFs), and hospices for federal fiscal year (FFY) 2025. CHA has issued members-only summaries of each rule.   

What else to know: In general, the payment updates were slightly higher than proposed, but still inadequate relative to input price inflation.  

CHA Comments on DMHC Network Adequacy Standards

What’s happening: CHA continues its work to hold insurance companies accountable for providing timely, comprehensive patient care. Last week, CHA submitted a letter to the Department of Managed Health Care urging it to expand network adequacy standards to reflect patients’ current health care needs and hold plans accountable for making those life-changing, lifesaving services available. 

What else to know: In the letter, CHA supports the department’s efforts to update the network adequacy standards to reflect the current needs and range of services required by enrolled beneficiaries, including updating standards for access to mental health services, and expanding the list of required provider types. CHA also urged the department to develop and implement specific measures and clear standards to ensure plan compliance. 

Office of Inspector General to Examine Medicare Advantage Use of Prior Authorization for Post-Acute Care

What’s happening: The U.S. Health and Human Services Agency has announced that the Office of Inspector General (OIG) will investigate the use of prior authorization for post-acute care services by Medicare Advantage (MA) plans.   

What else to know: CHA members have reported that they encounter significant challenges in obtaining authorizations from MA plans for access to the most appropriate level of post-acute care (PAC).  

DMHC Provides Additional Guidance Regarding Post-Stabilization Care Requests

What’s happening: The Department of Managed Health Care (DMHC) has issued All Plan Letter (APL) 24-012, which reminds plans that they may not require a hospital to make more than one telephone call to request authorization to provide post-stabilization care to plan members.   

What else to know: The APL reiterates the requirements of Health & Safety Code 1371.4, which states that plans must provide hospitals with one telephone number to serve as the point of contact for 24-hour access for post-stabilization authorization requests. Plans may not require a hospital to contact the plan in any way other than the plan’s designated phone number.   

Congress Reintroduces Legislation to Streamline Prior Authorization

What’s happening: Congressional leaders have reintroduced bipartisan legislation to address concerns regarding prior authorization (PA) and timely access to care for beneficiaries enrolled in Medicare Advantage (MA) plans.   

What else to know: The Improving Seniors’ Timely Access to Care Act would establish an electronic PA standard, reduce the amount of time a health plan is allowed to consider a PA request, and require MA plans to report on their use of PA, including rates of approvals and denials.  

CMS Issues Guidance on New Staffing Requirements

What’s happening: The Centers for Medicare & Medicaid Services (CMS) has issued updated guidance to state survey agencies and providers regarding facility assessment requirements for long-term care facilities.     

What else to know: The revised guidance updates the survey and assessment process as implemented under the Minimum Staffing Standards for Long-Term Care Facilities and Medicaid Institutional Payment Transparency Reporting final rule.  

CMS Proposes Inadequate Home Health Payment Update

What’s happening: The Centers for Medicare & Medicaid Services issued a proposed calendar year (CY) 2025 home health prospective payment system.  

What else to know: CMS estimates payments to home health agencies, as a result of the changes in the proposed rule, will decrease by $280 million (1.7%). Other key provisions of the proposed rule include: