The association voiced support for the agency’s decision to end its cuts to 340B hospitals. It urged the agency to promptly restore 340B hospital payments for calendar years 2018-2022 without penalizing other hospitals.
The association also articulated support for the agency’s proposal to use Medicare claims data to calculate the monthly facility rate for Rural Emergency Hospitals. It also urged the agency to detail the payment methodology and monitor its adequacy.
In contrast, the organization strongly urged the agency to increase the rule’s proposed market basket update of 3.1 percent, noting that it is woefully inadequate and does not capture the inflationary environment in which hospitals and health systems engage.
Finally, the association voiced opposition to the CMS proposal of adding a facet joint interventions service category to its prior authorization process. The letter noted that the utilization of these services has other justifications and the current data reveal that utilization levels of these services have already recessed.
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