On behalf of our nearly 5,000 member hospitals, health systems and other health care organizations, including 240 long-term care hospitals (LTCHs), and our clinician partners – including more than 270,000 affiliated physicians, 2 million nurses and other caregivers – and the 43,000 health care leaders who belong to our professional membership groups, the American Hospital Association appreciates the opportunity to comment on the LTCH provisions in the Centers for Medicare & Medicaid Services’ fiscal year 2022 proposed rule for the inpatient and LTCH prospective payment systems. We are separately submitting comments on the rule’s inpatient PPS proposals.
This letter focuses on the LTCH provisions in the rule and provides an update on the LTCH role in the COVID-19 pandemic response. The AHA supports many of the provisions in the rule, including the proposed use of FY 2019 claims as a basis for calculating the FY 2022 payment update, the proposal to require state Medicaid programs to enroll all eligible Medicare providers, and the overall objectives of the requests for information on health equity and digital quality reporting. However, we have concerns with other issues, such as the FY 2023 implementation of the proposed COVID-19 vaccination quality measure.
See the complete letter in the PDF below.