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A Closer Look: Comparing at CMS’ Final Rules with C-TAC’s Recommendations

CMS recently finalized three rules that C-TAC commented on. In many cases, they followed our recommendations. Below is a summary of the highlights from these final rules:

  • Final FY 2020 Medicare Hospital Inpatient Prospective Payment System (IPPS) and Long Term Acute Care Hospital (LTCH) Prospective Payment System Proposed Rule and Request for Information
    • Opioid measures- CMS continues to struggle with the balance of supporting the appropriate use of opioids with concerns that any use could be problematic. As a result, they finalized the measure Safe Use of Opioids, which C-TAC supported as it includes the appropriate exemption of those with cancer or receiving palliative care. However, they did not finalize the proposed new mesure of Hospital Harm –Opioid-Related Adverse Events, which we supported and they have removed the Communication about Pain measure from yet another Medicare program despite our noting that such action was not based on evidence and eliminates the evaluation of an important aspect of care. We will continue to urge CMS to pursue measures that adequately capture a hospital’s performance on pain management.
  • Final FY 2020 Hospice Wage Index and Payment Rate Update and Hospice Quality Reporting Requirements
    • Rate increases- Despite our suggestion to keep the routine home care rate flat with  and increase the other levels of care to meet budget neutrality requirements, CMS cut routine home care rate while increasing rates for the three higher-acuity levels of care.
    • Election statement- While helping patient and familes better undertand what drugs and treatments the hospice will or won’t cover is needed, the proposed solution of changing the election statement would have been administratively difficult for hospices to implement and C-TAC suggested clearer guidance on what they consider unrelated services. Unfortunately, the rule was finalized as proposed and submission of this document will become a condition for payment.
    • Request for information- C-TAC  emphasized that short hospice stays continue to be a problem and that CMS should explore all possible ways to address them in cases where a longer length of stay would benefit the patient and family.
  • Final FY 20/20 Prospective Payment System and Consolidated Billing for Skilled Nursing Facilities; Updates to the Quality Reporting Program and Value-Based Purchasing Program
    • CMS finalized two new quality measures in FY 2020 to assess whether certain health information is provided by the SNF at the time of transfer or discharge. The two measures are: 1) Transfer of Health Information to the Provider-Post-Acute Care and 2) Transfer of Health Information to the Patient-Post-Acute Care, which C-TAC had supported.
    • In addition, CMS is adopting a number of standardized patient assessment data elements, each of which assesses one of the following categories: cognitive function and mental status, special services, treatments and interventions, medical conditions and comorbidities, impairments, or social determinants of health (race and ethnicity, preferred language and interpreter services, health literacy, transportation, or social isolation). We suggested CMS consider including an assessment of family caregiver as a possible future social risk. CMS acknowledged this suggestion in the final rule and will consider this feedback as they continue to improve and refine this area.

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