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Association Comments on Annual Medicare Inpatient Payment Rule

America’s Essential Hospitals urged the Centers for Medicare & Medicaid Services (CMS) to implement its Medicare disproportionate share hospital (DSH) payment methodology and quality measurement programs in a way that accounts for the unique needs and patient populations served by essential hospitals.

In a June 25 letter on the fiscal year 2019 Inpatient Prospective Payment System (IPPS) proposed rule, the association recommended that CMS:

  • ensure that data used to implement the Affordable Care Act’s Medicare DSH payment methodology accurately capture the full range of uncompensated care costs hospitals sustain when caring for the disadvantaged;
  • examine ways to account for social risk factors in Medicare programs;
  • continue to refine the Hospital Readmissions Reduction Program risk-adjustment methodology to mitigate unintended consequences;
  • implement policies that reduce burden on hospitals in the Medicare and Medicaid Promoting Interoperability Programs (PIPs);
  • continue to refine the Inpatient Quality Reporting Program measure set so it contains only reliable and valid measures;
  • only include measures in the hospital value-based purchasing Program that have improved patient outcomes, do not overlap with existing measures, and adjust for social risk factors;
  • ensure the methodology and quality measures in the Hospital-Acquired Conditions Reduction Program do not disproportionately penalize certain types of hospitals;
  • reduce administrative burden related to supporting documentation requirements during submission of cost reports;
  • continue its imputed floor policy for all-urban states that do not have a rural floor;
  • ensure any efforts to improve transparency account for existing reporting requirements, as well as sociodemographic variation among patients served by essential hospitals; and
  • encourage improved communication between providers and patients, as well as improved care transitions, without putting further burden on essential hospitals by requiring additional information exchange through Conditions of Participation.

Contact Senior Director of Policy Erin O’Malley at or 202.585.0127 with questions.


About the Author

Rachel Schwartz is a former policy associate at America's Essential Hospitals.

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