In the letter, CHA raised concerns about the inadequate proposed market basket update and asked CMS to use alternative sources of data that better reflect input price inflation experienced by providers to calculate the FFY 2023 market basket update. CHA also asked CMS to use its existing authority to eliminate the productivity adjustment from the market basket update calculation for any year impacted by the COVID-19 public health emergency (PHE).
Additionally, CHA asked the agency to calculate the outlier threshold using data that better reflects the lower anticipated COVID-19 caseload hospitals will experience in FFY 2023, as CHA believes that CMS has overestimated the fixed-loss outlier threshold.
As stated in previous comments, CHA continues to oppose the continuation of the low wage index policy that increases the wage index for hospitals with wage index values in the bottom quartile of the national distribution at the expense of all IPPS hospitals.
In the letter, CHA encouraged CMS to recalculate Factors 1 and 2 of uncompensated care (UCC) disproportionate share hospital (DSH) calculation. CHA is concerned that CMS has significantly underestimated the growth in utilization and acuity in the Medicare fee-for-service population, which has negatively impacted Factor 1. CHA is also concerned that the uninsured rate used to calculate Factor 2 does not account for the loss of coverage projected to occur when Medicaid redeterminations resume after the COVID-19 PHE ends, and enhanced exchange subsidies expire at the end of 2022. CHA asked CMS to increase the UCC DSH pool.
CHA also provided detailed comments on CMS’ proposals on the:
- Use of Z codes to capture social determinants of health
- Calculation of Factor 3 of the UCC DSH calculation using multiple years of audited data from Worksheet S-10 of the Medicare Cost Report
- Creation of an add-on payment to encourage hospitals to use domestically produced N95 respirators
- Quality programs, including the Hospital Inpatient Quality Reporting Program and addressing the impact of the COVID-19 PHE on the Hospital Readmissions Reduction Program, Hospital Value-Based Purchasing Program, and the Hospital Acquired-Conditions Reduction Program
- Requests for information on measuring health care quality disparities across CMS quality programs, assessing climate change impacts on outcomes, care and health equity, and advancing maternal health equity
- Changes to the Promoting Interoperability Program