The development of Medicare cost measures for post-acute care is moving too quickly to account for the complex nature of the issues, worried provider groups say.
The proposed measures, called for as part of the Improving Post-Acute Care Transformation (IMPACT) Act of 2014, include specific measures to evaluate resource use for skilled nursing facilities, home health agencies, long-term care hospitals and inpatient rehabilitation facilities. Providers’ cost efficiency would be gauged against the national median for other providers in the same setting.
The Centers for Medicare & Medicaid Services is accepting public comments on the draft — which was released by research firm Acumen LLC on January 13 — through Wednesday (Jan. 27). That has left stakeholders just two weeks to dissect the draft and offer their feedback.
That timeline isn’t nearly long enough, said Cheryl Phillips, M.D., LeadingAge senior vice president for advocacy, to McKnight’s.
“It’s fairly complex. We certainly support the idea of resource use comparison but in terms of these exact measures, we haven’t had a chance to dig into it,” Phillips explained. “Once again, CMS is throwing out these measures with very, very inadequate review time.”
The quick turnaround puts providers and other groups that the cost measures would affect the most at a disadvantage, said Dan Ciolek, associate vice president of therapy advocacy for the American Health Care Association.
“We are very concerned that the measure development process is moving along so quickly that a) relevant information of sufficient detail is not being shared with stakeholders, and b) that CMS is not permitting sufficient time to stakeholders to provide thoughtful comments,” Ciolek said in a statement to McKnight’s.
Ciolek also expressed concern that the proposed measures are setting-specific, instead of an overarching per-beneficiary post-acute care measure.
The setting-specific measures come with “plusses and minuses,” Phillips said. One advantage would be the ability to compare and analyze resource use between similar providers, she noted.
Other organizations have expressed concerns that the measures don’t account for race or socioeconomic status of beneficiaries, or detail any outcomes measures.
“These are just resource utilization measures and tell us nothing about how good that care was or whether it was appropriate or not,” Ashish Jha, M.D., MPH, director of Harvard’s Global Health Institute, told Modern Healthcare. “Tying it in with robust outcomes measures, such as functional status and self-reported health outcomes is critical.”
Both Phillips and Ciolek agreed that while the measures are an important step in the right direction, the guidelines need to be developed more deliberately. A pilot test of the measures also would be beneficial to weed out any “looming” mistakes like inadvertent double counting of costs, Phillips said.
“I would start with a pilot and test it to make sure you’re actually measuring what you want to measure,” she emphasized. “I think this is really messy. CMS wants to push these out quickly and invariably runs into hiccups they didn’t anticipate.”
