The Centers for Medicare & Medicaid Services (CMS) has released its Unified Post-Acute Care (UPAC) Prototype Payment System Report to Congress. The Improving Medicare Post-Acute Care Transformation Act of 2014 (IMPACT Act) mandated a UPAC Prototype Report be developed by MedPAC and CMS for Congress, but Congress is not required to act upon the report. ​

In the report, CMS describes its proposed approach but also discusses an extensive list of additional work areas needed before Congress should consider any action. Specifically, the report does not include legislative recommendations, as additional analyses would need to be done prior to testing or implementation of a unified PAC payment system. Importantly, CMS notes that the Agency would need Congressional statutory authority to enact UPAC which, in the short term, would be challenging.

CMS highlights that additional analysis would be needed for a more actional prototype. Most importantly from CMS’ list of needed additional analysis is the need for up-to-date data unimpacted by COVID-19. Acquiring such data will require considerable time due to the implementation of the SNF Patient-Driven Payment Model and the Home Health Patient-Driven Groupings Model – both of which were implemented during the pandemic.

CMS caveats the need for additional analysis, including:

• ​Recalibration of the prototype using newer data, including data collected after the COVID-19 public health emergency;
• Development of a Quality Metrics and Value-Based Purchasing Program to accompany the prototype design provided in this report;
• Further analysis of the existing PAC regulatory requirements that could be unified under a unified PAC payment system;
• Further exploration of how copayments and co-insurance would operate under a unified PAC payment system;
• Development of a uniform way of reporting the primary reason for treatment in each Medicare PAC setting (i.e., on the patient assessment instrument versus the Medicare claim form);
• Further analysis of the need for hospital collection of standardized patient assessment items at discharge; and
• Consideration of a patient navigator who could educate and support Medicare beneficiaries and their families by helping them to understand the handoffs and choices at admission and discharge across Medicare provider settings and whether that could be operationalized in fee-for-service Medicare.

A more thorough summary will be released soon. Please contact Mike Cheek​ with any questions.