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AHA March 19 urged the Centers for Medicare & Medicaid Services to modernize its high-cost outlier policy for the long-term care hospital prospective payment system to reflect a shrinking patient population and more acute patient mix under the new dual-rate LTCH PPS payment structure. 

“These trends, along with the increasing fixed-loss amount, have led to the current HCO policy becoming inadequate in meeting its goal of reasonably reducing the financial losses that would otherwise be incurred by hospitals when treating beneficiaries in need of the costliest care,” AHA wrote. “Further, this inadequacy is being exacerbated by other market dynamics, including inadequate payment updates, growth in Medicare Advantage, and a workforce crisis, resulting in payments that fall short of the cost of care and an uncertain future for the LTCH field.”