The American Hospital Association has raised a variety of concerns with the Centers for Medicare & Medicaid Services regarding the proposed Inpatient Prospective Payment System (IPPS) rule for fiscal 2016, AHA News Now has reported.
The nation's largest hospital trade group is most concerned with payment cuts to facilities participating in the Disproportionate Share Hospital program (DSH) and proposed changes to the Quality Reporting Program and Hospital Readmissions Reductions Program (QRP).
Cuts in DSH payments were mandated under the Affordable Care Act, a law which has helped hospitals save billions in uncompensated care costs. But how the cuts are specifically calculated by the Office of the Actuary are not fully revealed, according to AHA Executive Vice President Pollack in a letter to CMS Adminstrator Andrew Slavitt. The letter also included 41 pages of comments on the proposed changes. Pollack noted that the CMS has never shared the calculations that it used, and this lack of access "severely hampers our ability to replicate the analysis and provide meaningful comment on these issues of great importance to the hospital field."
Regarding the changes in QRP, Pollack wrote that the relatively high reliance on electronic transmissions (for 16 of 28 reporting categories by fiscal 2018, with another eight quality measures to be implemented in that fiscal year) is "premature given the serious questions about (electronic clinical quality measures)." Instead, it suggested CMS rely on the recommendations of an Institute of Medicine report released in April that recommended 15 "streamlined" quality reporting guidelines.
The AHA also asked for a delay of enforcement of the revised two-midnight rule from the start of 2016 to March 30 of next year. "This will not only provide additional time for CMS to issue guidance related to any new policies or admission criteria for hospitals and review contractors; it will allow hospitals time to implement changes put forth by the agency."
The two-midnight rule has been a sticking point with hospitals, which have appealed payment clawbacks in large numbers, prompting CMS to offer settlements of disputed claims for 68 cents on the dollar.