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Long-term care hospitals paymentbasics

payment system

Revised: Patients with clinically complex problems, Defining the long-term care hospital
October 2009 such as multiple acute or chronic product Medicare buys
conditions, may need hospital care for
relatively extended periods of time. Some Under the LTCH prospective payment
are admitted to long-term care hospitals system (PPS), Medicare pays for the
(LTCHs), which must have an average operating and capital costs associated
Medicare length of stay greater than 25 with hospital inpatient stays in LTCHs.
days. Payments to LTCHs were about $4.5 Medicare sets per discharge payment
billion in 2008; Medicare beneficiaries rates for different case-mix groups
accounted for about 70 percent of these called Medicare severity long-term care
hospitals’ revenues. In 2007, almost diagnosis related groups (MS–LTC–DRGs)
114,300 Medicare beneficiaries had based on the expected relative costliness
129,200 discharges from LTCHs, and 398 of treatment for patients in the group.
facilities were Medicare certified.1 LTCHs Patients are assigned to these groups
are not distributed evenly through the based on their principal diagnosis, up
nation. to eight secondary diagnoses, up to six
procedures performed, age, sex, and
Beneficiaries transferred to an LTCH from discharge status. The MS–LTC–DRGs
an acute care hospital pay no additional are the same groups used in the acute
deductible. However, beneficiaries inpatient PPS but have relative weights
admitted from the community are specific to LTCH patients, reflecting the
responsible for a deductible—$1,068 in average relative costliness of cases in the
2009—as the first admission during a spell group compared with that for the average
of illness, and for a copayment—$267 LTCH case.3
per day—for the 61st through 90th days.
Beneficiaries treated in LTCHs are covered
Setting the payment rates
for 90 days of hospital care per illness,
with a 60-day lifetime reserve.2 The PPS payment rates cover all operating
and capital costs that LTCHs would be
Since October 2002, Medicare has paid
expected to incur in furnishing covered
LTCHs predetermined per discharge
services. The initial payment level (base
rates based primarily on the patient’s
rate) for a typical discharge is $39,897 for
diagnosis and market area wages. Before
fiscal year 2010.
then, LTCHs were paid for furnishing care
to Medicare beneficiaries on the basis of The base rate is adjusted to account for
their average costs per discharge, as long differences in market area wages (Figure
This document does not as they did not exceed a facility-specific 1). The labor-related portion of the
reflect proposed legislation limit that was adjusted annually. base payment amount—76 percent—is
or regulatory actions.
multiplied by a version of the hospital
Under the PPS, discharges are assigned to
wage index and the result is added to the
case-mix groups containing patients with
nonlabor portion.4 For LTCHs in Alaska and
similar clinical problems that are expected
Hawaii, the nonlabor portion is adjusted
to require similar amounts of resources.
601 New Jersey Ave., NW by a cost of living adjustment (COLA) and
Each case-mix group has a national
Suite 9000 added to the labor-related portion.5 The
relative weight reflecting the expected
Washington, DC 20001 adjusted rate for each market is multiplied
costliness of treatment for a patient in
ph: 202-220-3700 by the relative weights for all MS–LTC–
that category compared with that for the
fax: 202-220-3759 DRGs to create local PPS payment rates.
average LTCH patient.
www.medpac.gov
FIGURE
1 Long-term care hospital prospective payment system
Figure 1 Long-term care hospital prospective payment system

If patient is High-
Full
Adjusted for Adjusted for Payment cost
LOS extraordinarily
geographic factors case mix outlier
costly
(payment
Base rate +
LTCH 76% 24% adjusted outlier
MS–
base adjusted + Non-labor for x payment)
LTC–DRG
rate by area related geographic weight
wages portion factors

If LOS
Short-
MS– ≤5/6 of
stay
LTC–DRG* geometric
outlier**
mean LOS

Patient characteristics:
Hospital
Principal diagnosis Age
wage
Secondary diagnoses Sex
index
Procedures Discharge status

Note: LTCH (long-term care hospital), MS–LTC–DRG (long-term care diagnosis related group), LOS (length of stay).
* MS–LTC–DRGs comprise base DRGs subdivided into one, two, or three severity levels.
** Payments generally are reduced for short-stay patients.

Short-stay outliers—LTCHs are paid High-cost outliers—LTCHs are paid


adjusted PPS rates for patients who have outlier payments for patients who are
short stays. Short-stay outliers (SSOs) extraordinarily costly. High-cost outlier
are cases with a length of stay up to and cases are identified by comparing their
including five-sixths of the geometric costs to a threshold that is the MS–LTC–
average length of stay for the MS–LTC– DRG payment for the case plus a fixed
DRG. For SSOs, LTCHs are paid the least of: loss amount. In 2010 the fixed loss amount
is $18,425. Medicare pays 80 percent of
• 100 percent of the cost of the case,
the LTCHs’ costs above the threshold.
• 120 percent of the MS–LTC–DRG
High-cost outlier payments are funded by
specific per diem amount multiplied by
reducing the base payment amount for all
the length of stay for that case,
LTCHs by 8 percent.
• the full MS–LTC–DRG payment, or
• an amount that is a blend of the Interrupted stays—LTCHs receive one
inpatient PPS amount for the MS–DRG payment for “interrupted-stay” patients.
and the 120 percent of the LTCH per An interrupted stay is when an LTCH
diem payment amount. As the length of patient is discharged to an inpatient acute
stay for the SSO increases, the portion care hospital, an inpatient rehabilitation
of payment attributable to the LTCH per facility (IRF), or a skilled nursing facility
diem increases. (SNF), stays for a specified period, then

2 Long-term care hospitals payment system paymentbasics


goes back to the same LTCH. The specified patients discharged from the host acute
period of time is 9 days for an acute care care hospital.6 Patients from the host
hospital, 27 days for an IRF, and 45 days hospital who are outliers under the acute
for a SNF. Any LTCH discharge readmitted hospital PPS before their transfer to the
within three days is also considered an HWH do not count toward the threshold
interrupted stay. and continue to be paid at the LTCH
PPS rate even if the threshold has been
LTCHs that are co-located with other
reached.
Medicare providers are subject to the
interrupted-stay policy unless their Beginning in July 2007, CMS extended the
readmissions exceed 5 percent of the 25 percent rule to apply to all freestanding
LTCH’s total discharges. If this limit is LTCHs, limiting the proportion of patients
exceeded, the LTCH receives only one who can be admitted to an LTCH from
payment for each interrupted-stay patient any one acute care hospital during a cost
regardless of the amount of time spent reporting period. The extended policy was
at the intervening facility. (A separate to be phased in over three years, with the
5-percent threshold applies to cases applicable threshold for non-HWHs and
transferred to co-located SNFs, IRFs, and nonsatellites set at 75 percent for rate year
psychiatric facilities.) 2008.

The Medicare, Medicaid, and SCHIP


The 25 percent rule Extension Act of 2007 (MMSEA)
substantially changed the 25 percent
The 25 percent rule reduces payments for
rule by rolling back the phased-in
LTCHs that exceed established percentage
implementation of the 25 percent rule
thresholds for patients admitted from
for HWHs and satellites and preventing
certain referring hospitals during a cost-
application of the rule to freestanding
reporting period. The rule is intended to
LTCHs for three years.
help ensure that LTCHs do not function
as units of acute care hospitals and that
decisions about admission, treatment, and Payment updates
discharge in both acute care hospitals and
There is no mechanism in law for updating
LTCHs are made for clinical rather than
payments to LTCHs. CMS has stated that
financial reasons.
it intends to update LTCH PPS payment
When first implemented, the 25 percent rates based on the most recent estimate of
rule applied only to LTCH hospitals within the Rehabilitation, Psychiatric, and Long-
hospitals (HWHs) and satellites, limiting Term Care (RPL) market basket index
the proportion of Medicare patients (which measures the price increases of
who could be admitted from a HWH’s goods and services inpatient rehabilitation
or satellite’s host hospital during a cost facilities, inpatient psychiatric facilities,
reporting period. The policy was phased and LTCHs buy to produce patient care).
in over three years, with the threshold In recent years, CMS has adjusted the
for most HWHs and satellites set at 75 market basket increase downward to
percent for fiscal year 2006, 50 percent for account for improved coding practices
fiscal year 2007, and 25 percent for fiscal that result in higher case-mix indexes
year 2008. (Less stringent thresholds are (and higher payments) without correlative
applied to HWHs and satellites in rural increases in patient severity of illness. ■
areas or in urban areas where they are the
sole LTCH or where there is a dominant
1 Between 2006 and 2007, growth in spending and
acute care hospital.) After the threshold is discharges was slowed by large increases in the
reached, the LTCH is paid the lesser of the number of Medicare Advantage enrollees, who are not
included in these aggregate totals.
LTCH PPS rate or an amount equivalent
to the acute care hospital PPS rate for 2 Beneficiaries are liable for a higher copayment for each
lifetime reserve day—$534 per day in 2009.

3 Long-term care hospitals payment system paymentbasics


3 MS–LTC–DRGs with fewer than 25 cases are grouped 5 The COLA is intended to reflect the higher costs of
into 5 categories based on their average charges; supplies and other nonlabor resources in Alaska
relative weights for these 5 case-mix groups are and Hawaii. It increases the nonlabor portion of the
determined based on the average charges for the payment by as much as 25 percent.
LTC–DRGs in each of these groups.
6 During the year, the HWH will be paid the LTCH rate.
4 The wage index used to adjust LTCH payments During retrospective settlement at the end of an HWH’s
is calculated from wage data reported by acute cost report year, if the HWH is determined to be
care hospitals without the effects of geographic overpaid, CMS will collect the overpayments from future
reclassification. payments.

4 Long-term care hospitals payment system paymentbasics

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