AHA Urges CMS to Allow All Hospitals to Elect Alternate Payment Options

Dear Ms. Verma:

We greatly appreciate the hard work that the Centers for Medicare & Medicaid Services (CMS) and others have been doing to provide support and flexibilities to hospitals and health systems during this unprecedented crisis related to the novel coronavirus (COVID-19). As you are aware, hospitals and health systems are under enormous pressure to manage surge capacity due to the virus.

Hospitals are preparing for this influx of patients by canceling non-essential procedures and services, and discharging those patients who can be safely sent home or to other locations. However, this had led to open and empty beds at their facilities, and is creating a massive financial burden. Many of our member hospitals, especially those in rural areas, have shared serious concerns about a lack of cash flow, and thus the ability to keep their doors open. A steady flow of dollars to these providers is crucial to provide a buffer for the large incoming costs they will face in the near future.

To that end, I am writing to urge CMS to allow all hospitals to elect to receive periodic interim payments (PIP) or accelerated payments immediately, and with minimal administrative barriers. These payments would provide ongoing revenues to providers to keep cash flow moving and compensate for procedures that are currently delayed, but will take place after the medical surge has subsided. While approval for these payments is typically at the discretion of the Medicare Administrative Contractors (MACs), we request that CMS advise its contractors to offer maximum flexibility in approving requests for these unique payment timeframes and flexibility in administrative requirements.

Specifically, we urge:

• broad and immediate approvals of PIP and accelerated payment requests;
• delayed reconciliation and cost settlement for PIP and accelerated payments for hospitals until after the public health emergency has subsided; and
• leniency in meeting reporting criteria and other administrative requirements.

Further detail on our requests may be found in the attached document. Please contact me if you have questions or feel free to have a member of your team contact Erika Rogan, AHA senior associate director for policy, at <a href="tel:1-202-626-2963">(202) 626-2963</a> or <a href="mailto:erogan@aha.org?subject="Allow All Hospitals to Elect Alternate Payment Options">erogan@aha.org</a>.

By taking this additional step to provide steady Medicare payments, CMS will help ensure that critical inpatient care remains available to address the pandemic that the U.S. is currently facing. Again, on behalf of our members, we thank you for your efforts to support providers during this unprecedented time.

Sincerely,

/s/

Richard J. Pollack
President and CEO
American Hospital Association