The AHA supports a number of provisions in the inpatient prospective payment system (PPS) proposed rule for fiscal year 2016, but is concerned about the rule’s cuts to disproportionate share hospital payments, lack of data transparency and certain proposed changes to the Inpatient Quality Reporting Program and Hospital Readmissions Reductions Program, AHA Executive Vice President Rick Pollack told the Centers for Medicare & Medicaid Services in comments submitted today.

Among other comments, the AHA expressed concern that the rule does not propose any changes to the two-midnight policy.

“In light of the fact that CMS will be addressing issues related to the two-midnight policy in the outpatient PPS rule, with any changes likely to take effect Jan. 1, 2016, we urge the agency to extend the partial enforcement delay of the two-midnight policy until March 30, 2016,” the AHA said. As noted yesterday in its June report to Congress, the Medicare Payment Advisory Commission recently recommended that CMS withdraw its two-midnight policy and target Recovery Audit Contractor (RAC) reviews to hospitals with the highest number of short inpatient stays.

The AHA told CMS it is gathering feedback from members related to these and other MedPAC recommendations, but is concerned that the RAC recommendations “do not fully address the RAC program’s systemic problems.”