Statement on Proposed CY 2016 OPPS Rule
Executive Vice President
American Hospital Association
July 1, 2015
The Centers for Medicare & Medicaid Services’ (CMS) proposed revision to the two-midnight policy is a good first step. The nation’s hospitals appreciate today’s proposal to maintain the certainty that patient stays of two midnights or longer are appropriate as inpatient cases. We also agree with CMS’s proposal that stays of less than two midnights should be paid on an inpatient basis based on the medical judgment of a physician. However, it is unfortunate that CMS maintains the misguided 0.2 percent cut to payments for inpatient hospital services as part of the two-midnight policy.
We are pleased CMS proposed to make Quality Improvement Organizations (QIOs) the first line of medical review instead of the Recovery Audit Contractors (RACs), in order to prevent RACs from making inappropriate denials of patient status determinations. At the same time, we await further clarification on how changes to the RAC program interface with these proposed changes. Significant fundamental RAC reform is still needed. CMS also must extend the partial enforcement delay of the two-midnight policy beyond September 30.
At the same time, we are deeply disappointed CMS has proposed a negative update for hospital outpatient services. We are dismayed that miscalculations by the actuaries are resulting in penalties to hospitals and the patients they care for. CMS must reevaluate the actuaries’ estimates.
About the AHA
The AHA is a not-for-profit association of health care provider organizations and individuals that are committed to the health improvement of their communities. The AHA is the national advocate for its members, which include nearly 5,000 hospitals, health care systems, networks, other providers of care and 43,000 individual members. Founded in 1898, the AHA provides education for health care leaders and is a source of information on health care issues and trends. For more information, visit the AHA website at www.aha.org.
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