AHA Feb. 26 submitted comments on the Centers for Medicare & Medicaid Services’ proposed rule establishing appeals rights for Medicare beneficiaries admitted for an inpatient hospital stay subsequently reclassified to an outpatient stay with observation services. The rule, which establishes both retrospective and prospective appeal rights for beneficiaries, is a result of a court decision in the case of Alexander v. Azar. In comments, AHA said it supports the agency’s general approach and offered recommendations to ensure beneficiaries better understand CMS policies and to help clarify and reduce the burden of these appeals on all parties involved. AHA also asked CMS to temporarily use its enforcement discretion regarding the proposal that hospitals timely deliver a new notice called a Medicare Change of Status Notice, in order to determine whether changes or additional requirements are warranted.

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