Elderly person at a crossroads of healthcare decisions.

Medicare's Site-Neutral Payment Policy: Will It Limit Access to Long-Term Acute Care?

"A new study examines how Medicare's payment policy affects long-term acute care hospitals and access for older adults."


Long-term acute care hospitals (LTACHs) play a vital role in the healthcare system, providing specialized care for patients with complex medical needs. However, concerns about unnecessary admissions and rising costs have led to the implementation of new policies aimed at optimizing resource allocation. One such policy is the Centers for Medicare and Medicaid Services (CMS) site-neutral payment policy, designed to reduce reimbursements for less-ill individuals admitted to LTACHs.

A recent observational study delved into the potential effects of this site-neutral payment policy, focusing on its impact on LTACH admissions and access to care for older adults. By analyzing national Medicare data from 2011-2012, researchers sought to understand how the policy might affect different regions and hospitals with varying LTACH utilization rates.

The study's findings shed light on the proportion of LTACH admissions subject to site-neutral payment and the potential consequences for both high- and low-use regions and hospitals. The results offer valuable insights for healthcare providers, policymakers, and patients alike, as the industry navigates the evolving landscape of post-acute care.

AI Search Multiple angles on this topic

Measuring LTCH Use and Impact

The study "Effect of Site-Neutral Payment Policy on Long-Term Acute Care Hospital Use" analyzed national 5% Medicare data from 2011-12. The CDC's National Health Statistics Reports, Number 208, used data from the 2020 National Post-acute and Long-term Care Study, including CMS administrative data on long-term care hospitals. CMS reports that more than 420 long-term care hospitals submit data through its Long-Term Care Hospital Quality Reporting Program.

Medicare's Foundational Structure

Medicare and Medicaid were enacted in 1965 as Title XVIII and Title XIX of the Social Security Act. The milestone expanded health coverage to almost all Americans aged 65 or older and provided health care services to specified low-income populations. Today, Original Medicare consists of Part A and Part B: Part A covers inpatient hospital, skilled nursing facility, hospice, and some home health care, while Part B covers physician and outpatient services, durable medical equipment, and many preventive services.

Site-Neutral Payment: A Double-Edged Sword?

Elderly person at a crossroads of healthcare decisions.

The study revealed that a significant 41% of LTACH admissions would be subject to the site-neutral payment policy. This considerable proportion suggests a broad impact across the LTACH sector. However, the effect varies greatly among individual LTACHs, with a median of 40% of admissions potentially affected (ranging from 22% to 60%).

While the policy aims to curb unnecessary admissions, its consequences may disproportionately affect certain regions and hospitals:

  • High-Supply Regions: LTACHs in areas with greater market supply (more beds per capita) could see a greater impact, with approximately 47% of admissions affected.
  • High-Use Hospitals: Facilities with higher LTACH utilization rates might also experience a larger impact, potentially affecting 43% of their admissions.
  • Low-Supply Regions and Hospitals: Despite the policy's focus on high-use areas, nearly one-third of admissions in low-supply regions and hospitals could still be subject to lower payments.
AI Search Multiple angles on this topic

Current LTCH Research

Research on the clinical course after LTAC admission among older Medicare beneficiaries reported that these patients were anticipated to have lower LTAC access starting in 2020. MedPAC identifies long-term care hospitals as part of its research on post-acute care, Medicare spending and financing, and beneficiaries and coverage. CMS provides LTCH prospective payment system reports, data files, and documentation for Medicare payment and quality reporting.

Coverage and Access Concerns

A 2026 analysis described Medicare's impact and limitations while comparing it with other health care plans. A June 11, 2026 report by the HHS Office of Inspector General examined denials of requests for long-term acute care and inpatient rehabilitation among 19 Medicare Advantage plans. The report identified prior authorization denials for post-acute care after a hospital stay as an area of concern and highlighted variation in denial and overturn rates.

LTACHs and Alternative Settings

Medicare.gov describes long-term care hospitals as facilities for critically ill and medically complex patients who require extended hospital care, with many patients transferred after time in intensive or critical care. Research comparing LTACHs with skilled nursing facilities notes that LTACH use varies considerably across the United States and that skilled nursing facilities are the principal post-acute alternative. The same study reports that LTACHs provide more intensive care and receive over triple the reimbursement of skilled nursing facilities for comparable diagnoses.

This raises concerns about access to LTACH care in areas where it is already limited. The policy could inadvertently lead to consolidation or closure of LTACHs in these regions, potentially hindering recovery for older adults with complex medical needs.

Navigating the Future of Long-Term Acute Care

The site-neutral payment policy presents both opportunities and challenges for the LTACH sector. While it may help reduce unnecessary admissions and control costs, it also carries the risk of limiting access to care, particularly in underserved regions.

AI Search Multiple angles on this topic

Payment Protections for Complex Care

The American Hospital Association describes LTCHs as serving Medicare beneficiaries with complex conditions who require extended hospitalization. Traditional Medicare reimburses this care through the LTCH prospective payment system. That system includes a high-cost outlier policy intended to help ensure payment for exceptionally costly cases.

A Coordinated Long-Term Care Future

MedPAC's March 2026 chapter on post-acute care provides analysis and policy advice on the Medicare program. The 2026 Long-Term Care Market Outlook identifies aging, caregiver shortages, rising costs, and increasing consumer expectations as pressures requiring an interconnected response. It argues that families remain central to care but cannot carry the responsibility alone, pointing toward coordination among insurers, providers, researchers, government agencies, employers, and technology organizations.

Care Beyond the Hospital

PAM Health is described in an AHA case study as a provider of long-term acute care, inpatient rehabilitation, and behavioral health. The organization serves more than 70 communities across the country and has operated for more than 20 years. A separate collection of long-term care case studies frames long-term care planning as an ongoing journey intended to help families and professionals prioritize quality of life and well-being.

It's essential to monitor the policy's impact on LTACH access, patient outcomes, and healthcare costs. Further research is needed to determine whether individuals diverted from LTACHs can be effectively cared for in alternative settings, such as skilled nursing facilities (SNFs), without compromising their recovery.

As the healthcare landscape continues to evolve, stakeholders must work together to ensure that older adults receive the appropriate level of care in the most cost-effective setting. This requires a nuanced approach that balances the need for fiscal responsibility with the importance of maintaining access to high-quality post-acute care services.

About this Article -

Written with AI assistance from published research, and reviewed by the Mystum team. See our About page for more information.

This article is based on research published under:

DOI-LINK: 10.1111/jgs.15539, Alternate LINK

Title: Effect Of Site-Neutral Payment Policy On Long-Term Acute Care Hospital Use

Subject: Geriatrics and Gerontology

Journal: Journal of the American Geriatrics Society

Publisher: Wiley

Authors: Anil N. Makam, Oanh Kieu Nguyen, Benjamin Kirby, Michael E. Miller, Lei Xuan, Ethan A. Halm

Published: 2018-10-03

Everything You Need To Know

1

What is the main purpose of the site-neutral payment policy?

The Centers for Medicare and Medicaid Services (CMS) site-neutral payment policy is designed to reduce reimbursements for less-ill individuals admitted to Long-Term Acute Care Hospitals (LTACHs). This policy aims to optimize resource allocation within the healthcare system. Its significance lies in its potential to impact the financial viability of LTACHs, potentially affecting their ability to provide specialized care to patients with complex medical needs.

2

What role do Long-Term Acute Care Hospitals (LTACHs) play in healthcare?

Long-Term Acute Care Hospitals (LTACHs) provide specialized care for patients with complex medical needs. These hospitals play a vital role in the healthcare system by offering a high level of care to those who require it. They are particularly important for older adults with complex conditions. The implications are that changes to LTACHs, such as those driven by payment policies, can directly affect the availability of this specialized care for vulnerable populations.

3

How does the site-neutral payment policy affect Long-Term Acute Care Hospitals (LTACHs)?

The site-neutral payment policy affects Long-Term Acute Care Hospitals (LTACHs) by potentially reducing their reimbursements for certain admissions. The study indicates that a significant portion, about 41%, of LTACH admissions could be subject to this policy. The specific effect varies among hospitals and regions. The implications of this policy are far-reaching and could impact the financial stability of LTACHs and influence their ability to operate, particularly in regions with limited access to care.

4

Are there regional differences in how the site-neutral payment policy affects hospitals?

The study highlights that the site-neutral payment policy could have varying impacts across different regions. Specifically, it suggests that LTACHs in high-supply regions and those with higher utilization rates might experience a greater impact from the policy. Also, a considerable portion of admissions in low-supply regions and hospitals could still be subject to lower payments. These variations may lead to disparities in access to care, with potential closures or consolidations of LTACHs in certain areas.

5

What are the potential implications of this policy for patients and healthcare access?

The implementation of the site-neutral payment policy could affect the healthcare landscape by potentially limiting access to care in underserved regions. This could happen through the consolidation or closure of Long-Term Acute Care Hospitals (LTACHs) if the policy reduces their financial viability. This is particularly concerning for older adults with complex medical needs who rely on these specialized services. The policy's overall impact requires careful consideration to ensure access to quality care is preserved, and potentially even expanded.

Newsletter Subscribe

Subscribe to get the latest articles and insights directly in your inbox.