The American Hospital Association submitted to CMS Tuesday a letter detailing comments on behalf of its 5,000 member hospitals on the hospital inpatient prospective payment system proposed rule for fiscal year 2016.
While the AHA said it supports a number of provisions included in the proposed rule, it expressed the following five concerns.
1. Data transparency
The AHA expressed concern regarding the lack of disclosure of calculations and estimates from the Office of the Actuary used to support the proposed inpatient PPS rule. The lack of access is detrimental to meaningful commentary, the AHA said.
2. Two-midnight policy
The AHA suggests CMS extends the partial enforcement delay of the two-midnight policy to March 30, 2016. Without this extension, if CMS makes changes to the two-midnight policy in the outpatient PPS rule, the changes will take place beginning Jan. 1, 2016.
3. Inpatient Quality Reporting program changes
In the proposed rule, CMS suggested hospitals submit 16 of 28 available electronic clinical quality measures by FY 2018. The AHA said it is in favor of using EHRs to streamline the quality reporting process. However, it suggests CMS wait to set a deadline for hospitals to use eCQMs because eCQMs have not been thoroughly tested for feasibility and accuracy. The AHA also urged CMS to adopt recommendations from the Institute of Medicine on how to streamline national quality measurements.
4. Hospital Readmissions Reduction Program changes
CMS proposed a 65 percent increase in the patient population of its pneumonia readmission measure, which would affect the readmission rate of every hospital, AHA said. The AHA believes this change should not be finalized unless it is reviewed and endorsed by the National Quality Forum. The AHA also expressed concern about sociodemographic factors that may be affecting the measure. The organization recommended CMS include a sociodemographic adjustment to the HRRP to account for hospitals that treat a disproportionate number of poor and vulnerable patients.
5. Bundled Payments for Care Improvement Initiative
The AHA wrote in favor of continued expansion of the BPCI Initiative, including more testing and evaluation, as well as increased monitoring of the financial arrangements created as part of the initiative.
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