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CHA has submitted comments on the federal fiscal year 2024 inpatient rehabilitation facility (IRF) prospective payment system (PPS), skilled-nursing facility (SNF) PPS, and inpatient psychiatric facility (IPF) PPS proposed rules. CHA encourages members to use the drafts as a template to submit their own comment letters.
In each letter, CHA raises concerns about the proposed market basket update and urges the Centers for Medicare & Medicaid Services (CMS) to provide an adequate payment update in the final rule. Additional proposals commented on are outlined below.
IRF PPS: CHA provided specific comments on proposals related to the methodology used to calculate the labor-related share and a cross-setting discharge function score measure.
SNF PPS: CHA offered specific comments on proposals related to the productivity adjustment, forecast error adjustment, a cross-setting discharge function score measure, and a SNF value-based purchasing program health equity adjustment. Comments are due to CMS by 2 p.m. (PT) on June 5 and can be submitted online. Members should cite “CMS-1779-P” in the subject line of the letter.
IPF PPS: CHA commented on proposals related to the methodology used to calculate the labor-related share, an updated risk adjustment model, public reporting of patients that screen positive for social drivers of health, and COVID-19 vaccination reporting requirements. Comments are due to CMS by 2 p.m. (PT) on June 5 and can be submitted online. Members should cite “CMS-1783-P” in the subject line of the letter.
CHA thanks members for their input, which helped inform the comments.
