AHA comments on inpatient payment proposals for FY 2017

The AHA today voiced support for a number of provisions in the Centers for Medicare & Medicaid Services’ inpatient prospective payment system proposed rule for fiscal year 2017, but concern with the rule’s proposed documentation and coding reduction, changes to disproportionate share hospital payments and quality proposals. The association appreciates the agency’s decision to reverse the 0.2% payment reduction implemented in conjunction with its two-midnight policy and supports proposals to “restore the resources that hospitals are lawfully due,” wrote AHA Executive Vice President Tom Nickels. However, he said the agency’s proposed documentation and coding cut of 1.5 percentage points “is inconsistent with Congress’ intent,” and urged the agency to remove any amount over 0.8 percentage points or return it to the standardized amount in FY 2018. With respect to CMS’s DSH payment proposals, AHA urged the agency to take additional steps to ensure the accuracy, consistency and completeness of Worksheet S-10 data before using it to determine uncompensated care payments, and to consider a potentially longer phase-in approach and/or a stop-loss policy. The association also recommended additional changes to the hospital-acquired conditions and readmissions programs and electronic clinical quality measures. It submitted separate comments on the rule’s long-term care hospital proposals.