Long Term Care Hospitals
Site Neutral Payment

Lisa Grabert, MPH

February 28th, 2020

In 2013, Congress passed revised Long-Term Care Hospital (LTCH) criteria which reimagined the LTCH sector and required LTCHs to focus on the highest-acuity patients.

Prior to enactment of the new criteria, LTCHs had ten years to prepare for “site-neutral” payments (lower LTCH payments for lower-acuity patients) and the “50/50 Rule” (lower payments for LTCHs who treated more lower-acuity, site-neutral patients than higher-acuity, criteria-compliant patients).

In 2020, as the pandemic unfolded, Congress was looking to add hospital capacity and suspended LTCH site-neutral payment (SNP) and the LTCH 50/50 rule as part of the Coronavirus Aid, Relief, and Economic Security (CARES) Act of 2020. The suspension of both these rules will continue as long as the COVID-19 Public Health Emergency (PHE) continues. Once the PHE expires – possibly in summer 2022 – both LTCH rules will return. Some LTCHs would like to see the SNP rules suspended indefinitely. Here we examine the arguments for and against.