The site-neutral policy under the LTCH PPS is indicating that not all admissions to a LTCH are admissions that qualify for LTCH PPS rates. Therefore, the payment rate should instead be at the IPPS rate (acute care inpatient) or reasonable cost (charges * CCR), whichever is less. However, does this policy fully create a site-neutral payment policy?

The criteria excludes admissions where the the principle diagnosis relates to a psychiatric diagnosis or to rehabilitation. Should admissions with a psychiatric diagnosis have a reimbursement rate similar to the IPF PPS payment rate? Should admissions with a principle diagnosis that relates to rehabilitation have a reimbursement rate similar to IRF PPS?

Is this something CMS should explore? Would the cross-utilization of all the different PPS for various settings cause even more complexity and confusion? Could a site-neutral payment strategy for all healthcare settings be implemented with a simplified payment system(s)?