Annual LTCH Guidance

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For more than ten years, our firm has provided ongoing guidance to LTCH clients and non-clients throughout the year to keep them informed of federal legal and policy developments that may affect their operations. 

We provide this more comprehensive LTCH guidance for a single fixed fee at the beginning of the year. This guidance covers more developments and is more in-depth than the guidance we send to firm clients generally. 

With the resumption of site neutral payment for many LTCH cases, continued pressure on high cost outlier reimbursement, and the push toward value-based care, among other issues, LTCHs continue to face significant challenges. 

The detailed information we provide helps LTCHs prepare for and navigate these issues. Even if you belong to a trade association or get information from other sources, the detailed information and analysis we provide will add value to your hospital. The feedback from LTCHs has been very positive, particularly by independent LTCHs and LTCHs in small and midsized chain organizations. 

For one annual fee we provide comprehensive LTCH guidance throughout the year in the form of:

(1) Written guidance on LTCH legal and policy developments as they arise. We track developments at HHS, MedPAC, Congress, the courts, etc., and send written summaries by email whenever a new legal or policy issue arises that could impact LTCHs, including changes to IRF, IPF and SNF policies, since LTCHs can operate these units. Copies or links to relevant materials are included in these emails.

(2) Monthly conference calls with regulatory, legislative, and judicial updates, written materials and Q&A. We provide a regulatory update, a congressional update, and a judicial update by phone each month with a more in-depth discussion of legal and policy developments during the prior month, any new developments, and what to expect in the near future. We also provide more context (the “bigger picture”) for these developments. We end calls with questions and answers. Our PowerPoint presentation is provided in advance of each call.

(3) Legal memorandums analyzing the proposed and final rules for the annual LTCH PPS payment update. We send two legal memorandums—one in the spring and one in the summer—with a detailed analysis of the proposed and final rules for the LTCH PPS payment update. Participating companies often share these memorandums with senior management.

(4) Uniform comment letter to LTCH PPS proposed rule.  We prepare a comment letter to CMS on the LTCH PPS payment update proposed rule addressing the primary areas of concern for LTCHs for your hospital(s) to submit to CMS.

Please let me know if you are interested in obtaining this comprehensive LTCH guidance in 2024. I look forward to hearing from you.