The American Hospital Association on June 21 urged the Centers for Medicare & Medicaid Services to revise its proposed rule for the long-term care hospital prospective payment system for fiscal year 2013. "While we greatly appreciate several provisions in the rule, such as a delay in full implementation of the '25% Rule' and a three-year phase-in of the so-called 'one-time' budget neutrality adjustment, we have strong concerns with several aspects of these changes, as well as other elements of the regulation," AHA wrote.
For example, the association said it is "deeply disappointed" the proposed 25% Rule delay would not begin for one-third of LTCHs until July 2013, one year after the 25% Rule takes effect for these facilities. Among other concerns, AHA said the methodology used to calculate overpayments for the budget neutrality adjustment "has yielded an erroneous over correction" and should be modified to account for other payment policy changes implemented since 2003.
The association encourages hospital leaders to submit their own comments to CMS by the June 25 deadline, using the AHA letter as a model.