AHA Response to “Make Your Voice Heard” RFI – Promoting Equity and Efficiency in CMS Programs

November 4, 2022

The AHA appreciates the opportunity to comment on the Centers for Medicare & Medicaid Services’ (CMS) “Make Your Voice Heard” Request for Information (RFI) on promoting equity and efficiency in CMS programs. As requested in the RFI, we submitted our key recommendations using CMS’s electronic commenting tool; this letter provides the agency with additional context and information in support of our recommendations.

Hospitals and health systems face an unprecedented array of challenges as they work to sustain access to high-quality, equitable care in their communities. Among other issues, hospitals are grappling with staffing shortages, unsustainable rises in labor, supply and drug costs, supply chain disruptions, the rampant inflation affecting our entire economy, and continued disruptions from the COVID-19 pandemic. It is no surprise that hospitals are projected to face their most difficult year financially since the COVID-19 pandemic began. Hospitals are working hard to adapt to these extraordinary circumstances. However, they need CMS’ help in fostering supportive policies that fund hospitals and health systems adequately, protect patient access to equitable health care coverage, provide flexibility for more innovative and efficient care delivery approaches and relieve unnecessary administrative burden.

That is why the AHA appreciates that CMS has focused this RFI on policy areas that could meaningfully support hospitals and health systems as they navigate a profoundly challenging environment. These areas include access to health care coverage, sustaining the health care workforce and the potential continuation of COVID-19 Public Health Emergency (PHE) regulatory flexibilities. Hospitals and health systems also share CMS’ deep commitment to advancing health equity in their organizations and communities. We greatly appreciate CMS seeking input on approaches to advancing health equity generally, and the equity implications of health care coverage, workforce and COVID-19 PHE policies specifically.

Among other recommendations, the AHA urges CMS to:

  • Enhance its oversight of managed care plans and Medicare Advantage Organizations (MAOs) to ensure equitable access to medically necessary care and consumer protections, and ensure those in managed care plans do not face more restrictive coverage practices;
  • Adopt workforce-related policy changes that could provide short-term relief to the health care workforce and enable the health care field to adapt and innovate to meet the workforce challenges and care needs of the future, such as rethinking clinical documentation and licensure requirements;
  • Advance health equity using policy approaches that strike a balance of advancing broadly applicable, evidence-based practices across the hospital field while also not being overly restrictive or prescriptive; and
  • Making permanent certain COVID-19 PHE waivers, including those related to telehealth and Hospital at Home.

Our detailed comments follow.