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Association Comments on FY 2022 IPPS Proposed Rule

In a June 28 letter to the Centers for Medicare & Medicaid Services (CMS), America’s Essential Hospitals responded to annual updates to the Inpatient Prospective Payment System.

The fiscal year (FY) 2022 proposed rule included several policy proposals of interest to essential hospitals. America’s Essential Hospitals urged CMS to:

  • accurately calculate the amount of Medicare disproportionate share hospital payments it will distribute to hospitals in FY 2022 and ensure the methodology it uses captures the full range of uncompensated care costs hospitals sustain when caring for disadvantaged patients;
  • finalize its proposal to repeal collection of market-based payment rate information on hospital cost reports;
  • adopt policies that will encourage the training of health professionals in underserved areas;
  • withdraw its proposal to change the calculation of reimbursable organ acquisition costs at transplant centers;
  • implement policies that reduce administrative burden on hospitals in the Medicare Promoting Interoperability Program and allow hospitals to dedicate their resources to providing patient-centered care;
  • address the impact of the COVID-19 public healt emergency on quality measures across its programs and work with stakeholders to adopt a permanent suppression policy for use in future pandemics; and
  • 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, including health equity.

CMS also included a request for information regarding closing the health equity gap in hospital quality programs. As providers of care for marginalized and underrepresented communities, essential hospitals deeply understand the need to identify gaps in care quality that exist and to eliminate disparities as a matter of public health. The association urged CMS to:

  • encourage efforts to collect demographic data in a culturally appropriate and standardized way;
  • work with stakeholders to ensure any measure of hospital equity accurately reflects the ongoing efforts by essential hospitals to address the specific needs of their patient population; and
  • examine social risk factors beyond dual eligibility and race and ethnicity in order to inform hospital efforts to identify disparities.

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


About the Author

Abigail Painchaud is a policy associate at America's Essential Hospitals.

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