The AHA today submitted comments on the Centers for Medicare & Medicaid Services’ hospital inpatient prospective payment system proposed rule for fiscal year 2021.

“We support a number of the inpatient PPS proposed rule’s provisions, including utilizing FY 2017 Worksheet S-10 data to determine FY 2021 Medicare Disproportionate Share Hospital payments and modifying the definition of displaced resident for the purposes of graduate medical education slot transfers after hospital or residency program closures,” AHA wrote. “At the same time, we have serious concerns with other proposals. In particular, we do not believe CMS’s proposals to collect and apply payer-specific charge data are lawful and urge CMS not to finalize them.”

The association also urged the agency to withdraw its proposals to retroactively apply certain policies related to Medicare bad debt. AHA also reiterated its recommendation that CMS take certain actions related to COVID-19 alongside the FY 2021 inpatient PPS final rule.

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