AHA Statement on IPPS Proposed Rule

Tom Nickels
AHA Executive Vice President

Today’s rule outlines some promising proposals intended to reduce regulatory barriers for hospitals, health systems and the patients they serve. Specifically, we are extremely pleased with the proposed regulatory moratorium on the implementation of the 25% Rule for long-term care hospitals that will allow CMS time to determine if the policy is still necessary. Likewise, we appreciate the agency’s proposal to implement a 90-day meaningful use reporting period in fiscal year 2018. In addition, CMS’s proposal to use a more complete data source to determine the overall payment amount for hospitals that care for a disproportionate share of uninsured patients is a good step.

Yet we are concerned about some troubling elements within the proposed rule, including CMS’s intent to not restore last year’s excess cut to reimbursement rates for hospital services. While a reduction to the hospital update factor was mandated by law in 2012, CMS ignored Congress’ intent by imposing a cut that was nearly two times what was specified. We will continue to urge the agency to restore the excess cut and help ensure that hospitals have sufficient resources to be able to care for their communities.

In addition, we are concerned that CMS has proposed to use the “Worksheet S-10” data to determine the cost of treating uninsured patients without taking sufficient action to ensure the accuracy, consistency and completeness of these data prior to their use. We have communicated with the agency on the steps that should be taken to improve the quality of these data and thereby help ensure fair payment for hospitals treating vulnerable communities. We will continue to advocate that the agency adopt these changes, as well as a broad definition of uncompensated care that includes Medicaid shortfalls and discounts to the uninsured.

About the AHA

The AHA is a not-for-profit association of health care provider organizations and individuals that are committed to the health improvement of their communities. The AHA is the national advocate for its members, which include nearly 5,000 hospitals, health care systems, networks, other providers of care and 43,000 individual members. Founded in 1898, the AHA provides education for health care leaders and is a source of information on health care issues and trends. For more information, visit the AHA website at www.aha.org.