The AHA yesterday urged the Medicare Payment Advisory Commission to consider certain changes to its draft recommendations for the Recovery Audit Contractor program. The association supports the draft recommendation for the Centers for Medicare & Medicaid Services to base each RAC’s contingency fees in part on its denial overturn rate, but does not believe the other draft recommendations for the RAC program would achieve the stated goal of relieving hospital administrative burden, wrote Linda Fishman, AHA senior vice president for public policy analysis and development. AHA continued to urge the commission to support five other changes to the program. In addition, AHA urged the commission to consider alternative designs before making a short-stay payment policy recommendation; to analyze the justification for CMS’s 0.2% reduction to the standardized amount in the fiscal year 2014 final rule related to the two-midnight policy; and to better define the parameters around its draft recommendation for notice of observation status; among other recommendations. “We also appreciate the commission’s reluctance to make recommendations about the 340B program,” the letter states, calling the program “critical to the financial viability of its participants. It creates savings on outpatient drug expenditures to reinvest in patient care and health activities to benefit communities, and saves money for state and federal governments.” The commission is expected to vote on recommendations for its June report when it meets Thursday and Friday.

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