May 20, 2021
At a Glance
The Centers for Medicare & Medicaid Services (CMS) April 27 issued its hospital inpatient prospective payment system (PPS) and long-term care hospital (LTCH) PPS proposed rule for fiscal year (FY) 2022. The rule affects inpatient PPS hospitals, critical access hospitals (CAHs), LTCHs and PPS-exempt cancer hospitals. A summary of the proposals related to inpatient PPS hospitals, CAHs and PPS-exempt cancer hospitals is attached. Look for a separate AHA advisory on the LTCH PPS-related proposals soon. Comments on the proposed rule are due to CMS by June 28. The final rule will be published on or around Aug. 1 and take effect Oct. 1.
We applaud CMS’ proposal to repeal the requirement that hospitals and health systems disclose privately negotiated contract terms with payers on the Medicare cost report. We have long said that privately negotiated rates take into account any number of unique circumstances between a private payer and a hospital and their disclosure will not further CMS' goal of paying market rates that reflect the cost of delivering care. We once again urge the agency to focus on transparency efforts that help patients access their specific financial information based on their coverage and care.
What You Can Do
- Participate in an AHA members-only webinar May 24 at 1:30 ET to share your questions about and feedback on this regulation for AHA’s comment letter to CMS. To register for this 60-minute webinar, visit here.
- Share this advisory with your senior management team and ask your chief financial officer to examine the impact of the proposed payment changes on your Medicare revenue for FY 2022. Hospitals may assess the impact of these provisions on their organizations by using AHA’s calculators on readmissions, value-based purchasing and Medicare DSH: https://www.aha.org/inpatient-pps.
- Verify CMS’ table listing the factor used to calculate uncompensated care payments for Medicare Disproportionate Share Hospitals (DSH). Hospitals have until June 28 to review this table and notify CMS in writing of any inaccuracies.
- Verify that you have attested to meaningful use. Attestation status can be determined through CMS’ website.
- If applicable, apply for low-volume hospital status by written request to your Medicare Administrative Contractor (MAC) by Sept. 1 in order to receive the low-volume adjustment beginning Oct. 1.
- Share this advisory with your billing, medical records, quality improvement and compliance departments, as well as your clinical leadership team – including the quality improvement committee and infection control officer – to apprise them of the proposals around the diagnosis-related groups and quality measurement requirements.
- Submit comments to CMS with your specific concerns by June 28 at www.regulations.gov. The final rule will be published on or around Aug.1 and take effect Oct. 1.
Hospital Inpatient PPS Proposed Rule for FY 2022
Table of Contents
Click on the PDF link below to read the full Regulatory Advisory.