Comments to CMS on its FY 2023 Proposed Long-term Care Hospital Prospective Payment System

On behalf of our nearly 5,000 member hospitals, health systems and other health care organizations, including approximately 300 long-term care hospitals (LTCH), and our clinician partners — 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 (AHA) appreciates the opportunity to comment on the fiscal year (FY) 2023 LTCH prospective payment system (PPS) proposed rule. We are submitting separate comments on the rule’s inpatient PPS proposals.

We are concerned that CMS is proposing policies and payment adjustment that do not take into account the current the COVID-19 public health emergency (PHE) and its atypical market forces and pandemic-driven aberrations affecting the utilization and cost of providing LTCH services. Specifically, we are concerned by proposals for an inadequate market basket update and an untenable spike in the high-cost outlier threshold.

Please read the entire letter. See the pdf below.