Skip to Main Content
Don't have an account? Create Account
Don't have an account? Create Account

Association Comments on FY 2020 IPPS Proposed Rule

In a June 24 letter to the Centers for Medicare & Medicaid Services (CMS), America’s Essential Hospitals responded to a proposed annual update of the Inpatient Prospective Payment System.

The proposed rule included several policy proposals of interest to essential hospitals. America’s Essential Hospitals urged CMS to:

  • ensure that data used to implement the Medicare disproportionate share hospital payment  methodology accurately capture the full range of uncompensated care costs hospitals sustain when caring for the disadvantaged;
  • implement policies that reduce administrative burden on hospitals in the Medicare and Medicaid Promoting Interoperability Programs;
  • provide additional funding to drive parity in wage index values, rather than redistributing funds across hospitals;
  • reinstitute the imputed floor policy;
  • continue to refine the hospital inpatient quality reporting program measure set so it contains only reliable, valid measures that provide an accurate representation of care quality;
  • continue to refine the hospital readmission reduction program risk-adjustment methodology, mandated by law, to mitigate unintended consequences for essential hospitals;
  • finalize its proposal to reclassify the Z code for homelessness as a comorbid condition; and
  • conduct thorough public testing of new social determinants of health data collection requirements for long-term care hospitals before using such information to inform measures and other purposes.

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.

Previous Next
Test Caption
Test Description goes like this