Post-Acute Care ‘Food Fight’ Brewing in Washington

There’s a political food fight brewing in the nation’s capital, health care policy insiders told Home Health Care News.

And a possible overhaul to the entire post-acute care (PAC) sector is to blame.

“One of the things I’m hearing out of Washington is that there are some stakeholders in the post-acute care space interested in pushing for policy that would delay some of the [provisions] included in the IMPACT Act of 2014,” Lisa Grabert, a research professor at Georgetown and Marquette universities, told HHCN. “In particular, there is some movement on an attempt to get a delay of unified post-acute payment.”


The Improving Medicare Post-Acute Care Transformation (IMPACT) Act of 2014 was signed into law roughly five years. Broadly, the legislation is meant to create standardized data requirements for all PAC stakeholders, including long-term Care Hospitals (LTCHs), skilled nursing facilities (SNFs) home health agencies and others.

In addition to uniform data structures, the IMPACT Act also provided a timetable for a unified post-acute care payment model. Specifically, the act calls on the Centers for Medicare & Medicaid Services (CMS) to propose such a design before 2024.

Currently, LTCHs, SNFs and home health agencies are all reimbursed under setting-specific payment systems. A unified model would change that, effectively paying all providers through a single, overarching framework.


While some have couched a unified payment model as a pipe dream, others have said it’s likely to happen sooner rather than later.

“We have a real future threat coming in the unified post-acute payment [mechanism],” April Anthony, CEO of Encompass Health’s (NYSE: EHC) home health and hospice segment, said during the 2019 HHCN Summit. “I think that could really turn into the next [Patient-Driven Groupings Model] — and I think it could happen sooner than PDGM even settles out.”

The Medicare Payment Advisory Commission (MedPAC) — the entity charged with advising Congress on Medicare issues — has been on the unified payment model bandwagon for years. MedPAC last provided insight into what a theoretical unified payment model would look like in June.

Based on MedPac’s recommended approach, SNFs appear to gain the most in a unified post-acute care payment system, with in-patient rehabilitation facilities (IRFs) losing the most. The impact to home health providers would likely be somewhere in between, depending on circumstances.

Currently, it appears to be the facility-based providers leading the charge on a delay, according to Grabert.

“The push seems to be a little bit more from the hospital-based side of post-acute care, so more from the in-patient rehab facilities and the long-term care hospitals,” she said. “And it seems that they’re more squarely in the camp of wanting to see a delay for quite a long time, but that may create a bit of a food fight because there may be some other stakeholders who see this as a big opportunity to gain new volume and new revenues under Medicare not necessarily available to them in the past.”

Arguably, a delay of the unified payment model makes sense for multiple reasons.

For starters, CMS still has a ways to go on some of the unified-data aspects of the IMPACT Act. On top of that, CMS already has its hands full with major payment reform in the SNF space with the Patient-Driven Payment Model (PDPM) and in the home health space with PDGM.

“I think that that has taken up a lot of [CMS’s] time and effort internally,” said Grabert, lead author of PDGM. “And those pieces were not really contemplated when Congress initially mandated the IMPACT Act.”

Clarity surrounding the status of a unified payment model should be coming soon.

On Nov. 18, CMS is set to convene its second Technical Expert Panel (TEP) to discuss how it might eventually proceed with the possibility.

“They’ll be having their second big meeting on that, which is followed by an open request-for-information comment period,” Grabert said. “So, [policymakres] are going to be talking about some of the comments they received from stakeholders and posing more questions to the panel on how they can put together the unified system moving forward.”

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