Premier Files Comments on FY 2015 IPPS Proposed Rule

Charlotte, N.C.-based Premier has submitted comments to CMS on the FY 2015 Inpatient Prospective Payment System proposed rule.

The FY 2015 IPPS rule discusses payment change and requirements for acute-care and long-term hospitals. As it stands, the rule would decrease total payments to acute-care hospitals by $241 million.

Premier agreed with a handful of CMS' proposed IPPS rules, such as phasing in the documentation and coding adjustment and excluding patients with total hip and total knee arthroplasty from the 30-day readmission measure.

However, the group purchasing organization also offered its comments and recommendations on a handful of other proposed topics. The following are a handful of insights on the proposed rule from Premier.

  • Two-midnight rule: Premier urges CMS to delay enforcing the "two-midnight" policy as "this policy has had the exact opposite effect as was intended," according to the filed comments. Premier suggests developing a new policy that is less confusing and more clearly outlines the policy.
  • Readmissions penalties: As the maximum penalty of readmissions increases to 3 percent, Premier suggests CMS address the issue of readmissions penalties totaling more than four times the case cost of an excess readmission and instead improve the measures before adding additional conditions. Premier also urges CMS to adjust payment penalties to match socioeconomic status, as it may negatively affect some providers who serve certain populations in attempts to reduce healthcare disparities.
  • Electronic reporting: Premier suggests CMS does not implement mandatory electronic reporting of the Inpatient Quality Reporting program until the majority of hospitals can do so and a system for validating data for e-measures is established.

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