The AHA today submitted comments on the Centers for Medicare & Medicaid Services’ inpatient prospective payment system proposed rule for fiscal year 2019, offering key recommendations with respect to Medicare Disproportionate Share Hospital payment, CAR T-cell therapy, rural hospitals, the wage index, hospital quality reporting and value programs, and electronic health information exchange. Specifically, AHA recommends:  

Medicare DSH Payment:

  • Put in place a full audit process for the S-10 data to ensure the data are sufficiently accurate and consistent.
  • Implement a stop-loss policy to protect hospitals that lose more than 10 percent in DSH payments in any given year as a result of transitioning to the Worksheet S-10.

CAR T-cell Therapy:

  • Use an alternative method of determining the cost of the CAR T therapy that ensures the agency captures that cost accurately, such as using a cost-to-charge ratio of 1.0 (as mentioned in the rule), or using the therapy’s average sales price as a proxy for its cost.
  • Approve CAR T for new technology add-on payments and increase the NTAP marginal reimbursement to 100 percent for CAR T.
  • Consider longer-term solutions for these costly new technologies, such as making payment on a pass-through basis. 

Rural Hospitals:

  • Review and ensure accuracy of the Sole Community Hospital and Medicare-dependent Hospital-specific rate calculations for FY 2019.

Wage Index:

  •  Extend the “imputed” rural floor policy absent other wage index policies that would address the original need for the imputed rural floor. 

Hospital Quality Reporting and Value Programs:

  • Adopt CMS’s proposal to remove 18 measures from hospital programs altogether and “de-duplicate” an additional 21 measures. The AHA applauds CMS for beginning to use its “Meaningful Measures” framework to reduce unnecessary data collection burden and to prioritize the measures in hospital programs around the issues that matter the most to improving care.
  • Adopt CMS’s alternative proposal to weight measure domains of the hospital value-based purchasing program equally in calculating the VBP total performance score.
  • Require that any measures newly added to the Hospital-Acquired Condition and Readmissions Reduction Programs be publicly reported without a tie to payment for at least one year to ensure there are no adverse unintended consequences of their use.

RFI on Interoperability:

  • Do not create Condition of Participation/Condition for Coverage requirements to promote interoperability.
  • Establish a framework for interoperability such that the technology and governance of health information exchange are universally and consistently implemented and demonstrable. 

Promoting Interoperability Program:

  • Finalize the proposed 90-day reporting period in 2019 and 2020 and removal of requirements that hold hospitals and critical access hospitals responsible for the actions of others.
  • Finalize a scoring approach that permits hospitals to get credit for building performance in some areas while earning additional points in areas of strong performance.
  • Offer access to at least one application, rather than any application, configured to meet the technical specifications of the application program interface in the hospital’s or CAH’s electronic health record.

Also today, AHA submitted separate comments on the agency’s proposed changes to the long-term care hospital PPS, and proposals and request for information related to price transparency.