AHCA, DC

Dear Administrator Berwick: The American Health Care Association (AHCA) appreciates the opportunity to comment on the Centers for Medicare & Medicaid Services (CMS) notice, Medicare Program; Prospective Payment System and Consolidated Billing for Skilled Nursing Facilities for FY 2011; Notice, 75 Federal Register, 42886, (July 22, 2010). Our comments focus on four items within the notice, including: implementation of Hybrid Resource Utilization Group Version 3 (HR-III), the RUG-III to HR-III/RUG-IV budget neutrality adjustment methodology, the market basket forecast error correction policy, and the wage index budget neutrality adjustment methodology. As the nation’s largest association representing long term and post-acute care providers, our nearly 11,000 members include non-profit and proprietary skilled nursing facilities, assisted living residences, sub-acute centers, and homes for people with developmental disabilities that range from small, independently-owned facilities to regional, multi-facility corporations. AHCA’s detailed analysis and specific recommendations are below (See attached). We stand ready to respond to any questions that you might have with respect to our research and the findings provided to you in these comments. We would also be pleased to answer any questions you might have regarding any of our recommendations. Sincerely, Bruce Yarwood President & CEO