The AHA supports  a number of provisions in the inpatient prospective payment system proposed rule for fiscal year 2018, but has concerns about certain proposed changes related to disproportionate share hospital payments, the documentation and coding reduction, and quality programs, AHA Executive Vice President Tom Nickels told the Centers for Medicare & Medicaid Services in comments submitted yesterday.

On DSH payments, the AHA urged CMS to delay by one year only the use of Worksheet S-10 to calculate DSH payments, and continue to use Medicaid and Medicare Supplemental Security Income days from FY 2011-2013 to calculate uncompensated care payments in FY 2018.

The AHA also urged the agency to phase in the transition to Worksheet S-10 data over at least three years, and implement a stop-loss policy to help hospitals adjust to new payment levels.

Proposed rule for long-term care hospitals. The association commented separately on proposed changes to the long-term care hospital PPS. In those comments, the AHA welcomed CMS’s proposed 12-month regulatory pause on full implementation of the 25% Rule for long-term care hospitals and urged the agency to permanently rescind the rule.

Commenting on the proposed LTCH prospective payment system rule for fiscal year 2018, the AHA also voiced support for CMS's proposal to change the existing short-stay outlier policy by replacing the various payment options with a single graduated per diem adjustment, but urged the agency not to apply the related budget neutrality factor in FY 2018.

In addition, the AHA expressed concern that CMS continues to apply a duplicative budget neutral adjustment to site-neutral payments.

“As Medicare approaches the end of the transition from the single-rate LTCH PPS to the dual-rate version of the payment system, we ask CMS to examine access to care for those site-neutral cases that require specialized high-resource LTCH services,” wrote the AHA’s Nickels.

The AHA also recommended CMS reconsider the adoption of newly proposed and revised measures for the FY 2020 LTCH Quality Reporting Program. 

Reduce regulatory burden. In another comment letter, the AHA laid out actions CMS could take to immediately reduce the regulatory burden on hospitals, health systems and the patients they serve. The actions range from cancelling Stage 3 meaningful use requirements for electronic health records to prohibiting the enforcement of direction supervision requirements in critical access and small or rural hospitals.

"Reducing administrative complexity in health care would save billions of dollars annually and allow providers to spend more time on patients, not paperwork," wrote Nickels.

The letter responds to a request for information on CMS flexibilities and efficiencies included in the proposed rule for the inpatient and long-term care hospital prospective payment systems for FY 2018.


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