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Statement on FY 2025 IPPS Proposed Rule

April 10, 2024

Statement attributable to:
Beth Feldpush, DrPH
Senior Vice President of Policy and Advocacy
America’s Essential Hospitals

WASHINGTON — We appreciate the ongoing interest of the Centers for Medicare & Medicaid Services (CMS) in improving health care quality and lowering costs, including through the Inpatient Prospective Payment System (IPPS).

A key ingredient in efforts to improve health care quality, access, and equity is creating a common language to guide sound policymaking — including for how we define hospitals that provide safety net care for disadvantaged people and communities.

While CMS recognizes the need to define these providers, the approach it takes in today’s IPPS proposed rule would not fully capture hospitals at the core of the nation’s safety net. These hospitals would be best defined by measures that capture the extent to which a hospital disproportionately serves low-income and uninsured patients and the amount of uncompensated care it provides — measures such as those in recently introduced legislation, the Reinforcing Essential Health Systems for Communities Act (H.R. 7397).

We look forward to working with CMS to establish a more robust definition for safety net providers to ensure the best outcomes for, and participation in, care improvement initiatives, such as the Transforming Episode Accountability Model.

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About America’s Essential Hospitals
America’s Essential Hospitals is the leading association and champion for hospitals dedicated to equitable, high-quality care for all, including those who face social and financial barriers to care. Since 1981, America’s Essential Hospitals has advanced policies and programs that promote health, health care access, and equity. We support our more than 300 members with advocacy, policy development, research, education, and leadership development. Communities depend on essential hospitals for care across the continuum, health care workforce training, research, public health and health equity, and other services. Essential hospitals innovate and adapt to lead all of health care toward better outcomes and value. Learn more at

Carl Graziano


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