Advocacy Alert

Urge Your Lawmakers to Support Essential Health System Designation

Association Comments on FY 2024 IPPS Proposed Rule

Faridat Animashaun
June 9, 2023

In a June 9, 2023, letter to the Centers for Medicare & Medicaid Services (CMS), America’s Essential Hospitals responded to annual updates to the Inpatient Prospective Payment System.

The fiscal year (FY) 2024 proposed rule included several payment policies and quality reporting proposals of interest to essential hospitals. America’s Essential Hospitals urged CMS to:

  • Increase the proposed annual hospital payment update to account for rapidly rising hospital costs.
  • Use its authority to maintain stability in total Medicare disproportionate share hospital (DSH) payments, including capturing uncompensated care costs hospitals incur and ensuring transparency of the DSH methodology.
  • Finalize a 90-day reporting period in the Promoting Interoperability period for calendar years 2024 and 2025.
  • Continue refining the Hospital Inpatient Quality Reporting Program measure to ensure measures that accurately represent care quality.
  • Ensure measures in the Hospital Value-Based Purchasing Program are risk stratified and minimally burdensome.
  • Finalize revalidation proposals for the Hospital-Acquired Condition Reduction Program.
  • Finalize proposed changes to the severity level designation for Z codes describing homelessness.

CMS also included a request for information regarding how to best define safety net hospitals and the challenges these hospitals face. The association urged CMS to:

  • Adopt a safety net hospital definition that uses the Medicare disproportionate patient percentage, a measure of hospitals’ relative uncompensated care costs, and Medicaid deemed DSH status.
  • Adopt payment policies that recognize the unique role of essential hospitals and protect these hospitals from the adverse effects of payment cuts and other policies that affect patient access.

Contact Director of Policy Rob Nelb, MPH, at or 202.585.0127 with questions.

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