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CHA submitted comment letters on the federal fiscal year (FFY) 2023 inpatient rehabilitation facility (IRF) prospective payment system (PPS) and FFY 2023 inpatient psychiatric facility (IPF) PPS proposed rules.
Comments were due to the Centers for Medicare & Medicaid Services (CMS) by 2 p.m. (PT) on May 31.
In both letters, CHA expressed disappointment in the proposed market basket update as it is wholly inadequate relative to the input cost inflation experienced by IRFs and IPFs. CHA believes the assumptions underpinning the productivity adjustment are fundamentally flawed and strongly disagrees with the continuation of the policy. CHA asked CMS to work with Congress to permanently eliminate this unjustified reduction to hospital payments and for CMS to use its section 1135 waiver authority to remove the productivity adjustment for any fiscal year that was covered under public health emergency determination from the calculation of market basket for FFY 2023 and any year thereafter.
CHA’s additional comments on each rule are outlined below.
FFY 2023 IRF PPS Proposed Rule Comments
In the letter on the IRF PPS proposed rule, CHA urged CMS to reject consideration of adding home health to the IRF transfer policy in order to ensure that Medicare beneficiaries continue to have access to the continuum of care that best meets their needs throughout their recovery.
CHA also raised concerns about the proposed timeline for implementation of an all-payer IRF quality program reporting requirement and urges CMS to delay the requirement for the implementation of the updated IRF patient assessment instrument (PAI) for all payers until at least Oct. 1, 2024. This would allow for the opportunity to review the first year of IRF-PAI 4.0 use and develop a clearer understanding of the necessary time commitment and operational considerations.
CHA asked CMS to provide a significant transition period, training, and education if the agency moves forward with the adoption of the digital version of a quality measure for the IRF Quality Reporting Program that would use data from the electronic health record to assess rates of IRF-onset Clostridiodes difficile infection.
FFY 2023 IPF PPS Proposed Rule Comments
In comments on the IPF PPS proposed rule, CHA shared concerns that CMS has overestimated the impact of COVID-19 on the IPF PPS outlier threshold and asked CMS to use an approach similar to that used to normalize the impact of COVID-19 on the fixed-loss outlier threshold in the inpatient PPS.
Additionally, CHA provided feedback on a variety of issues related to the facility and patient-level payment adjustments that CMS will consider when the agency elects to update the payment adjusters.
