TRICARE; Reimbursement of Long Term Care Hospitals
2016-09-27 2015-03-18 2016-09-08
DOD-2012-HA-0146-0006 DOD-2012-HA-0146-0002 DOD-2012-HA-0146-0005
04:00:00 04:00:00 04:00:00
https://api.regulations.gov/v4/comments/DOD-2012-HA-0146-0006 https://api.regulations.gov/v4/comments/DOD-2012-HA-0146-0002 https://api.regulations.gov/v4/comments/DOD-2012-HA-0146-0005
Anonymous Anonymous Anonymous
Anonymous Anonymous Anonymous
When CMS adopted the site-neutral payment method in the 2015 IPPS Final Rule, CMS-1607-R, they set one requirement for a preceding 3 day ICU stay at an acute care hospital. CMS then issued MLN Matters 9015 which changed that requirement to IPPS hospital. As a result, civilian long term acute care hospitals are rejecting patients from a VA or military hospital because the preceding ICU stay was not at an IPPS hospital. This is depriving military and veteran patients access to LTACH because of that small change. Can you clarify this? Because of the low number of inpatient cases to LTCHs, we can conclude that the change of payment methods would do very little to affect the amount that Medicare pays and therefore the proposed rule should not be implemented. The LTCHs do not rely on the payments of TRICARE at all. Based off of average amounts per year, less than four TRICARE beneficiaries are served at LTCHs. Furthermore, 73% of billed charges were people not affiliated with the TRICARE program which proves that a change in reimbursement is completely unnecessary because of the lack of utilization by TRICARE beneficiaries. If we were to adopt this rule, the reimbursement system would need to change completely which could potentially create confusion for both the patients and hospitals. Also, the system has not already been created and would be different than Medicares reimbursement system because they would have to recalculate how to charge for short term stays. In conclusion, the low number of cases that would benefit from this reimbursement should not completely change the program simply because it would just be too impractical.  As an active duty service member, I can understand the need to decrease costs related to long term stays in long term care hospitals and inpatient rehabilitation units.  My opinion is that if there is to be a cost-share that the service member will be required to pay out of pocket, then an alternate means of insurance should be made available for purchase to the service member or retiree to cover these costs even though they are considered to be minimal utilizing catastrophic caps.  I believe this is important because it is not unrealistic that many service members injured either during training or down range will require these services.  It is not something that can be based solely on age related injuries or illnesses alone.  Also, if utilization of VA services are an option that will not require the service member to pay out of pocket costs, they should be made aware and these services should be comparable to services provided at a private/civilian facility.  This is simply because these service members have put their life in danger for this country and for that, they have earned the right to the best possible care they can receive without putting their family in debt.