Wednesday, June 08, 2011

Need Action From:

Hospital leaders

Attention Needed:

Voice concerns with proposed IPPS rule


By June 20


Rule cuts hospital payments by nearly $500 million


Submit comments to CMS

Submit Comments on Proposed IPPS Rule by Monday, June 20

AHA comments can serve as a model

The AHA today urged the Centers for Medicare & Medicaid Services (CMS) to revise its proposed rule for the inpatient prospective payment system (PPS) for fiscal year (FY) 2012, which continues the agency's flawed documentation and coding adjustment policy. For FY 2012, the policy would cut hospital payments by 6.05 percent, or $6.3 billion, and will create in substantial volatility in inpatient PPS rates for the next two years. Together with other policy changes, this cut would cause FY 2012 payments to decrease by 0.55 percent on average, or $498 million total, compared to FY 2011 payments.

The AHA is deeply disappointed with this level of payment for FY 2012 and believes there is a fundamental flaw in CMS' methodology for determining the effect of documentation and coding changes on the case-mix index (CMI). The AHA conducted analyses that indicate that much of the change CMS found is actually the continuation of historical increases in the CMI, not the effect of documentation and coding changes due to the implementation of the Medicare severity diagnosis-related groups (MS-DRGs). Thus, the agency should use a more appropriate methodology to estimate documentation and coding, one that takes real case-mix changes into account. Its proposed cut is excessive in light of these historical trends in CMI change and should not be implemented.

In its comment letter, the AHA also expresses its concerns about the measures proposed for the Hospital Readmission Reduction Program, which begins in FY 2013. CMS proposes to use the three currently reported 30-day readmission measures for heart attack, heart failure and pneumonia. The statute directs CMS to exclude from the measures readmissions that are unrelated to the prior discharge or that are planned; however, the current measures exclude only a very limited set of planned readmissions and, thus, do not meet the statutory requirement. The AHA strongly disagrees with CMS' proposal and believes the agency has ignored Congress' intent that the measures be modified to explicitly exclude unrelated and planned readmissions. The AHA urges the agency to instead conduct a study to thoroughly determine the common reasons for planned readmissions, as well as determine a subset of readmissions that are unrelated to the initial admission for the relevant conditions. In the interim, CMS should take steps to improve the existing measures, such as adjusting for patient characteristics beyond age, gender and medical diagnosis.

To read the letter in its entirety, click here.

Please consider using the AHA's letter as a model as you draft and submit your own comments to CMS. Comments on the proposed rule are due June 20 and can be submitted at Enter ID: "CMS-1518-P" then click on "submit a comment" in the CMS entry with posting date of May 5, 2011. For assistance, contact AHA Member Relations at (800) 424-4301.

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