Wednesday, February 3, 2016

AHCA/NCAL Submits Comments on IMPACT Act Resource Use Measure

Dan Ciolek

Last week AHCA/NCAL submitted comments to the Centers for Medicare and Medicaid Services (CMS) measure development contractor, Acumen, LLC. In response to the Draft Specifications for the Medicare Spending Per Beneficiary – Post-Acute Care (MSPB-PAC) Resource Use Measures provided for public comment on January 13, 2016.  

The stated goal of this project is to develop resource use measures for PAC settings as mandated by the Improving Medicare Post-Acute Care Transformation (IMPACT) Act of 2014. These measures apply to skilled nursing facilities (SNFs), home health agencies (HHAs), long-term care hospitals (LTCHs), and inpatient rehabilitation facilities (IRFs). The stated purpose of the measures is to provide actionable, transparent information to support PAC providers’ efforts to gauge and improve the efficiency and coordination of patient care. A given PAC provider’s efficiency is evaluated relative to the efficiency of the national median PAC provider in the same setting. 

The objectives of the project are to 1) Produce MSPB-PAC measures that use a framework similar to the hospital MSPB measure used in the Hospital Value-Based Purchasing program, and 2) Prepare the measure for SNF, HHA, LTCH, and IRF quality reporting programs (QRPs).  

From a SNF perspective, the MSPB-PAC measure as proposed would use risk-adjustment to compare the total costs of care similar patients from the date of admission to the SNF, until 30 days after discharge. While there are certain costs that are being considered for exclusion, the proposed approach would permit resource use setting-specific cost comparisons (e.g. SNF-SNF). The proposed measure is not designed to compare care resource use between different PAC settings for similar patients (e.g. between SNF and IRF of hip fracture).

Per the IMPACT Act, this MSPB-PAC resource use measure is to be specified, and data collection to start on October 1, 2016. This will be followed by feedback reports being provided to providers starting October 1, 2017. Finally, the law requires the public reporting of MSPB-PAC resource use measures comparing individual providers performance against a national median starting October 1, 2018.

In the AHCA/NCAL submitted comments, we identified numerous concerns with the draft MSPB-PAC measure specifications, requested specific additional information, and provided recommended alternative solutions. The primary AHCA/NCAL concerns were related to 1) The alignment of the proposed measures with the IMPACT Act, 2) The lack of sufficient information and time provided to stakeholders to be able to provide informed and thoughtful comments, and 3) Inconsistencies in the draft measure specifications that confuse the terms “resource use” measures with “efficiency” measures.

AHCA/NCAL members with questions or comments can contact Dan Ciolek at    

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