The letter details comments on the payment and quality updates proposed by the Centers for Medicare & Medicaid Services (CMS).
- Strongly supports CMS’ efforts to mitigate the impact of COVID-19 on IPPS rate setting by using FFY 2019 Medicare Provider Analysis and Review data and FFY 2018 Hospital Cost Report Information System data to establish the relative weights and calculate the fixed loss outlier threshold
- Strongly opposes CMS’ proposal to continue its low-wage index policy, increasing the wage index for hospitals with wage index values in the bottom quartile of the nation at the expense of all IPPS hospitals. CHA continues to believe this policy is inappropriately redistributive and penalizes all IPPS hospitals in an effort that is mis-targeted and ineffective for achieving the agency’s stated goal.
- Is concerned the methodology CMS uses to rebase and revise the labor-related share of Medicare inpatient payments for hospitals with a wage index of 1 or greater is premised on the flawed assumption that some categories of labor costs are not subject to geographic variation. The significant reduction in the labor-related share is driven by this assumption. CHA asks that CMS revise its methodology for rebasing the labor-related share to account for the geography wage variation inherent in all home office and non-clinical professional services costs.
- Asks CMS to mitigate the impact of the COVID-19 public health emergency (PHE) on the calculation of Factor 1 of the uncompensated care disproportionate share hospital formula by using the CMS Office of the Actuary’s estimate of FFY 2021 Medicare discharges from the FFY 2021 IPPS final rule, which we believe reflects the more normalized inpatient utilization hospitals will experience during the remainder of FFY 2021. CHA also asks the agency to provide additional transparency into the changes in the “Other” component of Factor 1 between the FFY 2021 final rule and the FFY 2022 proposed rule.
- Strongly supports CMS’ proposal to withdraw the market-based relative weight policies finalized in the FFY 2021 IPPS proposed rule. CHA agrees with the agency’s concerns about the utility of the data and the accuracy of MS-DRG weights this process would yield.
- Urges CMS to withdraw its proposed change to the definition of a “Medicare organ” for purposes of calculating Medicare allowable organ acquisition costs. CHA is concerned the proposed policy will reduce the number of available organs for transplantation. This unintended consequence is not contemplated in the preamble. Further, CHA does not believe it is currently possible for an excising transplant hospital to obtain the organ recipient’s insurance information, as required by the proposal, in instances where an excised organ is sent to an organ procurement organization.
- Supports CMS’ proposed measure suppression policies in the value-based quality programs to address the impact of the COVID-19 PHE on hospital performance. However, CHA urges CMS to continue to evaluate the data for its FFY 2023 programs to avoid unfairly penalizing hospitals that were severely impacted by the COVID-19 PHE beyond 2020.
- Urges CMS to reconsider several proposals under the Promoting Interoperability Program, including an increased reporting period for 2024.
- Applauds the administration for its commitment to addressing racial disparities and improving health equity. CHA urges CMS to focus its efforts on improving, standardizing, and incentivizing the collection of demographic data.
CHA thanks members for their feedback, which helped inform comments.