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America’s Essential Hospitals Submits Comments on FQHC Proposed Rule

America’s Essential Hospitals submitted comments Nov. 18 on the proposed rule for a Medicare prospective payment system (PPS) for federally qualified health centers (FQHCs). America’s Essential Hospitals expressed concern that several provisions in the rule could challenge the ability of FQHCs to integrate care and address patient needs. Specifically, America’s Essential Hospitals is concerned about a Centers for Medicare & Medicaid Services (CMS) proposal to pay a single encounter-based rate for all FQHC services provided per beneficiary, per day. In its comments, the association stated that the PPS should allow FQHCs to bill for multiple encounters for different conditions on the same day to encourage care integration. In addition, America’s Essential Hospitals urged CMS to add an adjustment in the national single encounter-based payment rate for provider-based FQHCs to ensure that payments to provider-based FQHCs account for the fact that provider-based FQHCs experience higher costs.

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