Advocacy Alert

Urge Your Lawmakers to Support Essential Health System Designation

Association Comments on FY 2025 IPPS Proposed Rule

Faridat Animashaun
June 11, 2024

In a June 10 letter to the Centers for Medicare & Medicaid Services (CMS), America’s Essential Hospitals responded to the agency’s proposed annual update to the Inpatient Prospective Payment System. The letter also includes new analysis of CMS’ proposed safety net definition and how it compares to the measures the association endorsed in the Reinforcing Essential Health Systems for Communities Act (H.R. 7397).

The association called on CMS to use its authority to codify a federal designation for essential hospitals and use the designation to target funding and other support to essential health systems across CMS programs. In addition, the association commented on the proposed payment policies and quality reporting proposals of interest to essential hospitals. Specifically, 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.
  • Prioritize the distribution of new resident slots to safety net providers.
  • Allow voluntary participation in the proposed Transforming Episode Accountability Model and provide upfront infrastructure payments and other flexibility to essential hospitals.
  • Support all essential hospitals’ efforts to decarbonize and develop climate resilience.
  • Support essential hospitals with funding and technical assistance to implement tailored maternal health programs.
  • Continue refining the Hospital Inpatient Quality Reporting Program measure to ensure measures that accurately represent care quality.
  • Finalize proposed changes to the severity level designation for Z codes describing inadequate housing and housing instability.

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

Keep up with the pulse of America's Essential Hospitals

Members: Sign up for email updates.