The two-midnight policy changes proposed by the Centers for Medicare & Medicaid Services "are a good first step towards resolving some of the problems created by this policy,” wrote AHA Executive Vice President Rick Pollack in an Aug. 27 letter to the agency.

 On July 1, Medicare proposed allowing for case-by-case exceptions to the policy in the outpatient payment rule. Based on the admitting physician’s judgment, certain short stays could be classified as inpatient so that they would be paid under Medicare Part A. Physicians who admit patients for what are expected to be short stays must document factors that support the decision, such as severity of symptoms and the risk of an adverse medical event occurring during the hospitalization.

 Pollack expressed the AHA’s support for the changes in comments on the proposed outpatient prospective payment system (PPS) rule for 2016.

 He said the AHA remains concerned, however, that CMS continues to apply its 0.2% reduction to the standardized amount that was implemented in fiscal year 2014 and asked the agency to “repeal this unlawful reduction.”

 The 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 on the proposed outpatient PPS rule, the 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.” The association 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, the AHA urged the agency to focus outpatient quality reporting measures “on national priority areas for improvement applicable to the entire health care system.”