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Association Comments on Hospital COVID-19 Data Reporting

On Nov. 2, the association submitted comments on the interim final rule with a comment period regarding additional policy and regulatory revisions, including new hospital conditions of participation (CoPs) for reporting of COVID-19 utilization and patient data.

The association strongly opposed the new hospital CoPs related to reporting COVID-19 data and urged the Centers for Medicare & Medicaid Services (CMS) to withdraw these requirements. Noting the uncertain financial future and many other challenges facing essential hospitals as they continue to respond to and recover from the COVID-19 public health emergency, the association urged CMS to ensure the collection of COVID-19 data does not add complexity and burden to a workforce already under immense pressure.

Additional comments from the association urged CMS to:

  • provide adequate time for meaningful responses from stakeholders on policies, before implementation, and prioritize the development of interpretive guidance;
  • provide further guidance to hospitals and laboratories about the agency’s measure of compliance, data completeness, and future data requests;
  • consider the unintended consequences of placing limits on COVID-19 and related diagnostic testing, including the effect of such a policies on access to care; and
  • make updates to the extraordinary circumstances exception granted for value-based purchasing programs and be transparent about data and analyses relied upon to make assessments about future updates across the quality reporting programs.

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

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

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