In the letter, CHA:
- Opposes CMS’ existing and proposed payment methodology for 340B-purchased drugs and respectfully requests that CMS restore payment for separately payable drugs acquired through the 340B program at average sales price plus 6%.
- Urges CMS not to finalize its proposal to eliminate the inpatient only (IPO) list over three years.
- Continues to oppose CMS’ unnecessarily redistributive policy that decreases payments to all hospitals to offset an increase in the area wage index for the hospitals in the lowest area wage index quartile.
- Strongly opposes CMS’ ongoing policy to reduce payment for clinic visits furnished in excepted provider-based departments at 40% of outpatient payment rates.
- Opposes CMS’ proposal to expand its prior authorization program to include two additional service categories.
- Generally supports CMS’ proposed changes to the hospital overall star ratings methodology to simplify and improve stability in the star ratings.
Comments were due to CMS on Oct. 5.