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CHA Issues Comment Letter on FFY 2020 IPPS Proposed Rule

For CEOs, CFOs, Reimbursement Staff, Government Relations Staff, Quality Reporting Staff

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CHA has submitted a comment letter on the federal fiscal year (FFY) 2020 inpatient prospective payment system (IPPS) proposed rule issued by the Centers for Medicare & Medicaid Services (CMS).

In the letter, CHA strongly opposes the wage compression proposal that would increase the area wage index in low-wage states by lowering the area wage index in high-wage states. This would decrease Medicare hospital inpatient payments in California by more than $100 million in FFY 2020 (nearly 60% of total costs).

CHA encourages CMS to strongly consider FFY 2017 Worksheet S-10 data as a viable option to meet its current policy objectives in distributing the Medicare disproportionate share hospital (DSH) uncompensated care dollars in FFY 2020. CHA also urges CMS to honor its commitment to mitigating the volatility of these payments to providers by considering blending FFY 2019 uncompensated care payments with FFY 2017 payments.

CHA’s letter includes detailed comments on proposed changes to CAR T-cell therapy, Medicare Severity-Diagnosis Related Group classifications, payment for ambulance services and changes to quality reporting programs.

In addition to the extensive IPPS comments, CHA also prepared a letter template that members can use to share with CMS their opposition specifically to its proposed changes to the Medicare area wage index.

Members are encouraged to use both letters to draft their own comments to CMS, which are due by 2 p.m. (PT) on June 24. To submit comments, go to and search “CMS-1716-P.”