Response to Comments

Response to Comments on the Burden Estimates for the FY 2025 LTCH QRP Proposals*
The FY 2025 IPPS/LTCH PPS Notice of Proposed Rulemaking (89 FR 36345 through 36350) was
published on May 2, 2024. In response to the NPRM, CMS received four comments related to the
proposed burden estimate. CMS responded to those comments in the FY 2025 IPPS/LTCH PPS Final
Rule that was published on August 2, 2024. Please see the response to comments document.
Comment: A couple of commenters acknowledged there would be an increase in burden, however,
one of these commenters said that while they expect the administrative burden on their LTCHs to
increase as a result of the proposed four SDOH new assessment items, they still support the proposal
because the adoption of consistent, standardized questions will reduce the burden of implementation
and have a positive impact on discharge planning. The other commenter noted that the additional
burden on their LTCHs will be relatively low because they are already collecting most of this
information through their electronic medical record system.
Two commenters did not support the proposal to collect the new SDOH assessment items and noted
significant concerns about the cumulative collection burden on critically ill patients, the cost of
updating the data collection systems, and training staff members. One of these commenters noted that
asking the proposed SDOH assessment items will increase burden on their only discharge planner and
reduce the time they can spend on actual discharge planning. Another one of these commenters noted
that their facility already has concerns with the high administrative burden of LCDS data collection
and its impact on patient care, particularly considering ongoing workforce challenges.
Response: We acknowledge the addition of four new SDOH assessment items will increase the
burden associated with completing the LCDS, and we carefully weigh the burden of collecting new
assessment items against the benefits of adopting those assessment items for the LCDS. We agree
with the commenters who support the proposal because the adoption of consistent, standardized
questions will reduce the burden of implementation and have a positive impact on discharge planning.
We strive to promote high quality and efficiency in the delivery of healthcare to the beneficiaries we
serve. We prioritized balancing the reporting burden for LTCHs with our policy objective to collect
additional SDOH standardized patient assessment data elements that will inform care planning and
coordination and quality improvement across care settings. For instance, LTCHs are already required
by our regulation at § 482.43 to develop and implement an effective discharge planning process to
ensure an effective transition of the patient from hospital to post-discharge care and reduce the
reduction of factors leading to preventable hospital readmissions.
As we noted in section IX.E.4.b., the proposed new SDOH assessment items were identified in either
the 2016 NASEM report 1 or the 2020 NASEM report2 as impacting care use, cost, and outcomes for
Medicare beneficiaries. In addition, Healthy People 20303 and related work across HHS 4 underscores
that social risk factors and unmet social needs contribute to wide health and health care disparities
and inequities. Stakeholders across the health care spectrum have a role to play in addressing SDOH.
We believe by integrating the proposed new SDOH assessment items into routine practice and, when
indicated, facilitating referrals to downstream interventions informed by patient data, then the risk for
1
 National Academies of Sciences, Engineering, and Medicine. 2016. Accounting for Social Risk Factors in
Medicare Payment: Identifying Social Risk Factors. Washington, DC: The National Academies Press.
https://doi.org/10.17226/21858.
2
National Academies of Sciences, Engineering, and Medicine. 2020. Leading Health Indicators 2030: Advancing
Health, Equity, and Well-Being. Washington, DC: The National Academies Press. https://doi.org/10.17226/25682.
3
Healthy People 2030 Framework. Healthy People 2030. https://health.gov/healthypeople/about/healthy-people2030-framework.
4
Green K, Zook M. When Talking About Social Determinants, Precision Matters. HealthAffairs. Published October
29, 2019. https://www.healthaffairs.org/do/10.1377/hblog20191025.776011/full/
*Medicare and Medicaid Programs and the Children's Health Insurance Program; Hospital Inpatient Prospective
Payment Systems for Acute Care Hospitals and the Long-Term Care Hospital Prospective Payment System and
Policy Changes and Fiscal Year 2025 Rates; Quality Programs Requirements; and Other Policy Changes. 89 FR
50956. https://www.federalregister.gov/d/2023-16050/p-983

negative outcomes, such as hospital readmissions, can be reduced. Collection of these new SDOH
items will provide key information to LTCHs to support effective discharge planning.
In response to the commenters with concerns about the cumulative collection burden on critically ill
patients, we want to remind LTCHs that the DRAFT new and modified assessment items posted on
the LTCH QRP Measures and Technical Information webpage include additional response options for
patients that decline to respond or are unable to respond. We encourage LTCHs to assess all patients
and select the appropriate response options for the SDOH.
In response to the commenters with concerns about the cost of updating the data collection systems,
CMS continually looks for opportunities to minimize the cost to LTCHs associated with collection
and submission of the LCDS through strategies that simplify collection and submission requirements.
This includes standardizing instructions, providing a help desk, hosting a dedicated webpage,
communication strategies, free data specifications, and free on-demand reports.
Finally, in response to the commenters with concerns about training their staff on collecting the
proposed new SDOH assessment items, we plan to provide training resources in advance of the initial
collection of the assessment items to ensure that LTCHs have the tools necessary to administer the
new SDOH assessment items in a respectful way and reduce the burden to LTCHs in creating their
own training resources. These training resources may include online learning modules, tip sheets,
questions and answers documents, and/or recorded webinars and videos, and would be available to
providers as soon as technically feasible, allowing LTCHs several months to ensure their staff take
advantage of the learning opportunities

*Medicare and Medicaid Programs and the Children's Health Insurance Program; Hospital Inpatient Prospective
Payment Systems for Acute Care Hospitals and the Long-Term Care Hospital Prospective Payment System and
Policy Changes and Fiscal Year 2025 Rates; Quality Programs Requirements; and Other Policy Changes. 89 FR
50956. https://www.federalregister.gov/d/2023-16050/p-983