AHA Comments on CMS’ Inpatient Payment Proposal for FY 2025

June 5, 2024

The Honorable Chiquita Brooks-LaSure
Centers for Medicare & Medicaid Services
Hubert H. Humphrey Building
200 Independence Avenue, S.W.
Room 445-G
Washington, DC 20201

RE: CMS-1808-P, Medicare and Medicaid Programs and the Children’s Health Insurance Program; Hospital Inpatient Prospective Payment Systems for Acute Care Hospitals and the Long-Term Care Hospital Prospective Payment System and Policy Changes and Fiscal Year 2025 Rates; Quality Programs Requirements; and Other Policy Changes, (Vol. 89, No. 86), May 2, 2024.

Dear Administrator Brooks-LaSure:

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 comment on the Centers for Medicare & Medicaid Services’ (CMS) hospital inpatient prospective payment system (PPS) proposed rule for fiscal year (FY) 2025. We are submitting separate comments on the agency’s proposed changes to the long-term care hospital PPS and Transforming Episode Accountability Model.

We support several of the inpatient PPS proposed rule provisions, including certain policies supporting low-volume and Medicare-dependent hospitals. We also appreciate that the agency revised its previous drug buffer stock proposal in response to several matters the AHA raised in last year’s request for information (RFI). We also support several aspects of CMS’ quality-related proposals, including most of the updates to the Hospital Consumer Assessment of Healthcare Providers and Systems (HCAHPS) survey and the removal of five redundant quality measures from the Inpatient Quality Reporting (IQR) program.

At the same time, we continue to have strong concerns about the proposed payment updates. In particular, we are deeply concerned about the inadequacy of the proposed net payment update of 2.6% given the unrelenting financial challenges faced by hospitals and health systems. As such, we strongly urge CMS to utilize its authority to make a one-time retrospective adjustment to account for what the agency missed in the FY 2022 market basket forecast. We also are concerned about the agency’s lack of transparency in the underlying calculations for disproportionate share hospital (DSH) payments and disagree with the agency’s estimates of the number of uninsured for FY 2025. We urge CMS to consider additional data by researchers and policy stakeholders to reach a more reasonable estimate of the percent of uninsured. Additionally, we are concerned with the agency’s graduate medical education (GME) proposals and RFI related to modifications of the “newness” criteria to establish new residency training programs.

Finally, we have concerns about several of the agency’s quality-related proposals. We urge CMS not to adopt its two proposed new structural measures and not to increase the number of required electronic clinical quality measures. CMS' proposal to use conditions of participation (CoPs) to compel hospitals to share data with the federal government is both needlessly heavy-handed and inconsistent with the intent of CoPs. Rather than jeopardizing hospitals’ Medicare participation status, the AHA urges CMS to take a more collaborative approach and to invest in the infrastructure needed to make the voluntary sharing of important data on infectious diseases less burdensome and more meaningful.

We appreciate your consideration of these issues. Our detailed comments are attached. Please contact me if you have questions or feel free to have a member of your team contact Shannon Wu, AHA’s director for payment policy, at (202) 626-2963 or swu@aha.org.



Ashley Thompson
Senior Vice President
Public Policy Analysis and Development

View the details below.