Commenting today on the proposed Outpatient Prospective Payment System rule for FY 2016, AHA said it supports the Centers for Medicare & Medicaid Services’ proposed two-midnight policy changes. “Specifically, we believe that CMS’s proposed changes are a good first step towards resolving some of the problems created by this policy,” wrote AHA Executive Vice President Rick Pollack.” The AHA remains concerned, however, that CMS continues to apply its 0.2% reduction to the standardized amount that was implemented in FY 2014 and asks the agency to “repeal this unlawful reduction.” AHA also urged the agency to extend the two-midnight partial enforcement delay through March 2016 to allow sufficient time for hospitals and the agency to implement the proposed changes. Among other comments, AHA said it strongly opposes CMS’s proposal to apply a 2 percentage point reduction to the OPPS conversion factor, which is “founded on questionable assumptions, a poorly described methodology and data that are not publically available.” AHA also urged the agency not to finalize certain other proposed outpatient payment reforms, which the association said are not adequately explained, difficult to validate and burdensome for hospitals to implement. In addition, AHA urged the agency to focus outpatient quality reporting measures “on national priority areas for improvement applicable to the entire health care system.”