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Report Issued on Unified Post-Acute Care Reimbursement Model

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The Centers for Medicare & Medicaid Services (CMS) and the Office of the Assistant Secretary for Planning and Evaluation (ASPE) have issued their “Report to Congress: Unified Payment for Medicare-Covered Post-Acute Care.”  

The report, which was required by the Improving Medicare Post-Acute Care Transformation Act of 2014, includes analysis and development of a prototype unified post-acute care (PAC) prospective payment system (PPS). 

Under the draft model, patients are initially categorized and placed into one of 32 unified PAC clinical groups (UPCG) based on their primary reason for PAC care. Each UPCG is then divided into PAC case-mix groups  based on the patient’s functional status and primary diagnosis.  Additional case mix adjusters account for additional factors, such as clinical complexity/co-morbidities, type of PAC setting, and rural settings. Notably, Congress would need to pass new legislation to implement a unified PAC PPS.  

The current analysis is based on data collected from 2017 through 2019, preceding the implementation of major changes in PAC payment methodology and the COVID-19 pandemic, which have had a significant impact on PAC access, utilization, and costs. The use of this outdated data limits the value of the current analysis and the ability to assess its impact in the future. CMS and ASPE acknowledge this limitation and recommend recalibration of the draft model using updated data.  

The authors make several additional recommendations, including further development of quality reporting programs and value-based purchasing programs, additional analysis of the need to collect standardized patient assessment items at acute hospital discharge, and consideration of a patient navigator.