AHA Comments Re: MedPAC’s Final Payment Update Recommendations

January 3, 2023

Michael Chernew, Ph.D.
Medicare Payment Advisory Commission
425 I Street, NW, Suite 701
Washington, D.C. 20001

Dear Dr. Chernew:

On behalf of our nearly 5,000 member hospitals, health systems and other health care organizations; 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 (AHA) appreciates the opportunity to share our comments and asks that commissioners consider the following issues before making their final payment update recommendations.

The decisions you reach on hospital payment updates will not only greatly affect America’s hospitals and health systems, but also other providers and the patients and communities we serve. In response to the discussions during the December meeting and the commission’s draft recommendations, we:

  • Appreciate your draft recommendation to provide a current law market-basket update plus an additional 1% for the hospital inpatient and outpatient prospective payment systems (PPS), but urge the commission to recommend a higher update for hospitals in light of the sustained and substantial financial pressures and negative Medicare margins they face;
  • Urge the commission to recommend current law updates for inpatient rehabilitation facilities (IRFs) and hospital-based skilled nursing facilities (SNFs) given the pivotal role they play for the entire health care continuum; and
  • Support the recommendation to increase physician reimbursement, as well as the proposal for add-on payments, but encourage the commission to consider a higher update that more fully accounts for the impact of inflation, as well as the release of additional analysis on the distribution and amount of add-on payments for safety net clinicians.

View detailed comments on these issues below.