Stacey HughesExecutive Vice President American Hospital Association
April 18, 2022
We are extremely concerned with CMS’ proposed payment update of only 3.2%, given the extraordinary inflationary environment and continued labor and supply cost pressures hospitals and health systems face. Even worse, hospitals would actually see a net decrease in payments from 2022 to 2023 under this proposal because of proposed cuts to DSH and other payments. This is simply unacceptable for hospitals and health systems, and their caregivers, that have been on the front lines of the COVID-19 pandemic for over two years now. While we have made great progress in the fight against this virus, our members continue to face a range of challenges that threaten their ability to continue caring for patients and providing essential services for their communities.
Separately, we are pleased to see that the agency has proposed a 5% cap on any decrease to a hospital’s wage index, though we urge that this be applied in a non-budget neutral way. CMS also proposes to use more than one year of data to determine uncompensated care costs. We have long stated that utilizing a single year of S-10 data may increase the potential for anomalies and undue fluctuations in uncompensated care payments especially when hospitals experience unforeseen circumstances such as a pandemic.
Finally, we thank CMS for recognizing that the COVID-19 pandemic continues to affect hospital performance in its quality measurement and value programs, and appreciate its proposal not to penalize hospitals for non-representative performance under the Hospital-Acquired Condition Reduction and Value-Based Purchasing Programs for FY 2023. Hospitals and health systems share CMS’ deep commitment to advancing health equity. We look forward to reviewing the details of CMS’ proposed health equity-related quality measures and further engaging the agency on how to advance this vital work.