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Medicare pays long-term care hospitals less than half the cost of care for site-neutral cases under the LTCH prospective payment system, AHA told the Centers for Medicare & Medicaid Services Friday. “Our analyses show that these substantial underpayments are occurring because, contrary to CMS’s projections, the acuity level and cost of care for LTCH site-neutral cases far exceed those of comparable inpatient PPS cases,” wrote the AHA. Given these concerns, AHA urged CMS in the LTCH PPS proposed rule for fiscal year 2019 to remove the second budget neutrality adjustment applied to LTCH site-neutral cases and to permanently withdraw the LTCH 25% Rule.