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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 eomalley@essentialhospitals.org or 202.585.0127 with questions.

 

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About the Author

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

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