A recent report from the Office of the Inspector General (OIG) within the Department of Health and Human Services (HHS) argues that skilled nursing care centers, or “nursing homes,” should be better monitored by the federal government when it comes to how frequently they send patients back to the hospital. OIG recommended that the Centers for Medicare and Medicaid Services (CMS) develop a quality measure to track and publicly report nursing centers’ hospitalization rates and to have state survey agencies review the measure as part of the survey and certification process. As the largest association representing skilled nursing care centers in the country, the American Health Care Association (AHCA) agrees. In fact, we do not think OIG goes far enough. We support linking Medicare payments to skilled nursing care centers based on their hospital readmission rates.

Frequent trips to the hospital are disrupting to seniors and put them at greater risk for complications and infections. It is also costly to the system, as the OIG report demonstrates. AHCA came to the same conclusion and is already acting on the issue. AHCA wrote to Congress earlier this year in support of measuring and publicly reporting hospitalization rates among skilled nursing centers when the legislative body requested comments on how to reform Medicare post-acute care payments.

We also support the expansion of CMS’ new inspection process, the Quality Indicator Survey (QIS), which includes a process to review a center’s hospitalization rates unlike the old survey process. However, only 26 states presently use the QIS process after CMS suspended nationwide implementation due to potential budget constraints. AHCA supports CMS continuing its expansion of the QIS to all states as designed, which will have surveyors review centers’ hospitalization rates as recommended by the OIG.

We’re not just encouraging measuring and reporting; we have also developed a hospitalization measure, which we have shared with the federal government. AHCA partnered with the data analytics company, PointRight, to calculate risk-adjusted hospital readmissions during the first 30 days of a skilled nursing stay. Previously, this data was not available to individual providers and was not risk adjusted. Instead, it was reliant on Medicare claims data which did not account for individuals covered by other insurance such as Medicaid, managed care, commercial insurance ,or private pay, and resulted in a two-year lag time before data were available.

By using the Minimum Data Set (MDS) 3.0 collected on all residents, regardless of payer status, in every nursing center in the country, the AHCA and PointRight measure allows skilled nursing providers to assess their rehospitalization data within four to six months of submitting their information to CMS. The measure is also adjusted for risk based on 33 different clinical characteristics. This timelier, risk-adjusted data provides more valuable information on a nationwide basis. AHCA is submitting this measure for consideration to the National Quality Forum to use in public reporting. We have also offered this information to CMS to post on Nursing Home Compare as recommended by OIG.

In addition, AHCA has made this hospital readmission measure available to our skilled nursing members through our online tool, LTC Trend Tracker, to track their own quality improvement efforts and address this issue head on. In February of 2012, AHCA announced a Quality Initiative which sets a number of goals for the profession, including one to safely reduce 30-day hospital readmissions from a skilled nursing stay by 15 percent before March 2015. Since launching the Quality Initiative, readmissions have been reduced by 3.3 percent. In just 18 months, nearly 40,400 individuals averted going back to the hospital, saving the health care system an estimated $420 million. Meanwhile, over 2,100 skilled nursing members of AHCA have already achieved this three-year goal of a 15 percent reduction. Quantifiable progress is being made in the area of readmissions thanks to the concerted efforts of providers and this comprehensive measure which allows centers to monitor their rates.

However, what truly sets the long term and post-acute care profession apart from other areas of health care and goes beyond OIG’s recommendations is that we are willing to tie our level of reimbursement to this indicator of quality care. AHCA has drafted bold legislation that would create a hospital readmission reduction program specifically for skilled nursing care centers that guarantees savings.

AHCA proposes reducing readmissions from these centers annually to save Medicare a total of $2 billion over the next 10 years. If skilled nursing care centers do not reach their goal each year, then they would take a rate cut to make up the difference, thus guaranteeing the targeted savings. We’re putting our money where our mouth is, something you rarely see from professional groups in Washington. We urge Congress to adopt this proposal, as it both saves Medicare money and improves the lives and outcomes of the individuals we care for every day.

While the OIG report recommends that the government must do more (which we agree), it ignores the fact that the profession has embraced this issue and is pushing for more to be done. We’re creating our own mandates, saving the system hundreds of millions and, most importantly, already improving the lives of tens of thousands of seniors. The government can’t be the only answer to every problem. Skilled nursing centers are the source for solutions, and we are getting something done.