The AHA said it was particularly “deeply concerned about the inadequacy of the proposed net payment update of 2.6% given the unrelenting financial challenges faced by hospitals and health systems.” The group is asking CMS to use its authority to make a one-time retrospective adjustment to account for what it missed in the 2022 market basket forecast.
The group is also concerned about CMS’ “lack of transparency in the underlying calculations for disproportionate share hospital payments” and disagrees with the agency’s uninsured estimates for 2025. The AHA is urging the agency to consider additional data by researchers and policy stakeholders to “reach a more reasonable estimate of the percent of uninsured.”
Other concerns involve CMS’ quality-related proposals. The AHA is asking CMS not to adopt its two proposed new structural measures and not to increase the number of required electronic clinical quality measures.
“CMS’ proposal to use conditions of participation (CoPs) to compel hospitals to share data with the federal government is both needlessly heavy-handed and inconsistent with the intent of CoPs,” the AHA said in the letter.
The AHA also said it supported several of the proposed rule’s provisions, including certain policies supporting low-volume and Medicare-dependent hospitals. It added that it appreciates CMS revising its previous drug buffer stock proposal. The group also supports several aspects of CMS’ quality-related proposals, most of the updates to the Hospital Consumer Assessment of Healthcare Providers and Systems and removing five redundant quality measures from the Inpatient Quality Reporting program.
Read the full letter here.
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