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Association Gives Feedback on IPPS Proposed Rule

In response to the fiscal year (FY) 2017 Medicare Inpatient Prospective Payment System (IPPS) proposed rule, America’s Essential Hospitals urged the Centers for Medicare & Medicaid Services (CMS) to ensure its inpatient payment policies do not unfairly disadvantage essential hospitals for serving the most vulnerable.

In comments to CMS, the association applauded the agency for reversing the 0.2 percent payment cut to inpatient payment rates associated with the two-midnight policy, which has been in effect since FY 2014.

The association also gave CMS detailed feedback on accurately capturing hospital uncompensated care data when distributing Medicare disproportionate share hospital (DSH) payments. CMS proposes to begin using uncompensated care costs from worksheet S-10 of the Medicare cost report to target Medicare DSH payments in FY 2018. America’s Essential Hospitals urged CMS to account for both uncompensated care costs and low-income insured days in calculating Medicare DSH payments. The association also asked CMS to make necessary revisions to its proposed use of worksheet S-10, such as including teaching costs in the calculation of uncompensated care costs.

CMS also proposed updates to quality reporting programs, including a change in scoring methodology for the Hospital-Acquired Condition Reduction Program and other updates to the Hospital Readmissions Reduction Program, Hospital Value-Based Purchasing Program, and Inpatient Quality Reporting Program. The association urged CMS to ensure measures and methodologies in these programs are adjusted for sociodemographic status to accurately reflect quality of care and improved patient outcomes and avoid creating bias against any particular type of hospital.

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


About the Author

Shahid Zaman is a senior policy analyst at America's Essential Hospitals.

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