1.     Patient severity classification: Each post-acute care venue has a different patient assessment instrument and unique set of quality measures. This is partly because each venue treats different kinds of cases in terms of condition and severity, and has different “rules of participation” (therapy requirements, allowable impairments, average length of stay, etc.). The result is that similar cases that are treated in different venues, at significantly different costs / reimbursements, are not able to be compared on a quality nor cost basis. MedPAC has been recommending the collection of uniform patient assessment information since 1999!

2.     Over Regulation: In their many efforts to control costs to the Medicare program and to distinguish the types of care delivered in the various post-acute care venues HHS/CMS has created many rules and policies that have made delivery of care less comparable and more difficult. Rules like the 60% Rule that requires an inpatient rehabilitation facility (IRF) take 60% of its cases from a list of pre-determined conditions while the other post-acute venues are not subject to this rule. Additionally, facilities in all venues of post-acute care are being asked to collect more data without clear guidelines for how the data will be used, summarized, or adjusted.

3.    Provider Burden: Post-acute care providers are already stretched to collect all the data required to process each patient. Now they are being required by HHS / CMS to collect more and more data, identified as Quality Indicators. In many cases, the data is duplicative to data they are already collecting. The most recent example is the inpatient rehabilitation facility (IRF) patient assessment instrument (IRF PAI) which has grown from 3 to 4 pages in 2012, from 4 to 8 pages in 2014 and from 8 to 18 pages in 2016. The burden on the providers comes in many forms. Additional FTEs, staff education and training, information and technology spending on data collection interfacing and transmission and facility compliance.

4.     Quality Measurement: No one in their right mind would argue with the need to measure the quality of care delivered in post-acute care. What is hard to understand is the quality measure development and deployment process. How can a facility be asked to collect the same construct (i.e. eating) on the same patient with two different data elements, using two different scales and two different risk-adjustment methodologies?  Additionally, how can a “quality measure” that is identified for one venue of care then be required of facilities in another venue of care in order to meet a deadline, without regard to its applicability to patients in that venue of care or its representativeness of quality delivered by providing facilities in that venue of care? We understand and support the desire to measure in a standardized way! We believe there are common elements to a patient’s “need for assistance” in their restoration process that can, and should be measured in a standardized way!