CHA News

CHA Comments on IPPS Proposed Rule

This post has been archived and contains information that may be out of date.

CHA has submitted comments on the federal fiscal year (FFY) 2024 inpatient prospective payment system (IPPS) proposed rule.

In the letter, CHA raised concerns about the proposed market basket update and urged CMS to provide an adequate payment update in the final rule. Additional proposals commented on are outlined below. 

  • Provide an Adequate Market Basket Update: CHA expressed concern that CMS’ proposed market basket update does not match hospital input price inflation and offers a number of recommendations to improve the market basket update.  
  • End the Bottom Quartile Policy: CHA strongly opposed CMS’ proposal to continue its 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.  
  • Revise Uncompensated Care (UCC) Disproportionate Share Hospital (DSH) Factors: CHA encouraged CMS to recalculate Factors 1 and 2 of UCC DSH calculation. 
  • Revise Long-Term Care Hospital Fixed-Loss Outlier Threshold: CHA asked CMS to re-evaluate the calculation to ensure that it accurately reflects the anticipated caseloads hospitals will experience in FFY 2024. 
  • Limit COVID-19 Vaccination Reporting Requirements: CHA strongly supported ongoing efforts to maintain high levels of up-to-date vaccination for COVID-19 among both health care providers and the communities they serve but urged CMS to consider limiting the COVID-19 health care personnel vaccination reporting requirements.  
  • Focus Agency Resources on Development of a Sepsis Outcome Measure: CHA opposed the inclusion of the Severe Sepsis and Septic Shock: Management Bundle in the hospital Value-Based Purchasing (VBP) program and urges the agency to work with stakeholders to develop a sepsis outcome measure that would be more appropriate for the program.
  • Hospital VBP Program Health Equity Adjustment: CHA supported the proposed health equity adjustment and urged CMS to explore additional approaches to identify hospitals that care for high proportions of underserved patients. CHA cautioned the agency against using area-level indexes such as the area deprivation index or other similar indexes that rely on national benchmarks in value-based payment programs. 
  • Maintain 180-Day EHR Reporting Period: CHA supported the proposal to establish a 180-day electronic health records (EHR) reporting period for 2025 and urged CMS to maintain this reporting period in the future to account for upgrades and other changes to hospital EHR technology.