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 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 by capturing uncompensated care costs hospitals incur and ensuring a transparent DSH methodology
- Prioritize the distribution of new resident slots to essential hospitals
- Consider the unique needs of essential hospitals participating in the Transforming Episode Accountability Model, including by providing targeted assistance and allowing hospitals to maintain safety net status for the entire model period
- Delay the addition of using Medicare Advantage data in the Hospital Readmissions Reduction Program
- Finalize the extraordinary circumstances exception policy
- Support essential hospitals with the transition to electronic quality measures
CMS also included a request for information regarding approaches and opportunities to streamline regulations and reduce burdens on those participating in the Medicare program. The association urged CMS to:
- Streamline and better align quality measures across programs, focusing on a targeted set of evidence-based measures that are clearly linked to improved health outcomes
- Review and revise obsolete, unnecessary, or burdensome provisions in conditions of participation and provide hospitals flexibility to shape their programs to most efficiently serve patients’ needs
- Consider ways to standardize and streamline prior authorization criteria and submission formats to facilitate documentation and approval
- Consider administratively simple ways to identify and exclude 340B drugs from the implementation of new Medicare inflation rebates added by the Inflation Reduction Act
- Use CMS data to better automate and streamline the process for annual recertification of 340B covered entities
Contact Director of Policy Rob Nelb, MPH, at rnelb@essentialhospitals.org or 202.585.0127 with questions.
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