The Alliance of Safety-Net Hospitals has submitted formal comments in response to the Centers for Medicare & Medicaid Services’ proposed Medicare inpatient prospective payment system regulation for FY 2027.
Highlights of ASH’s comments include:
The assertion that the proposed Medicare inpatient payment increase is not sufficient to account for the sustained cost growth and fiscal pressures affecting hospitals and a request that CMS reconsider the assumptions underlying its proposed net payment increase of 2.4 percent.- A request that CMS reconsider its proposal to reduce Medicare disproportionate share (Medicare DSH) uncompensated care payments by more than a half-billion dollars because such payments remain a vital source of support for maintaining access to services and advancing care delivery to the low-income and underserved populations typically served by community safety-net hospitals – especially at a time when CMS projects growth in the national uninsured rate.
- An argument against CMS’s plan to expand its list of MS-DRGs subject to Medicare’s post-acute transfer policy because doing so would place additional financial strain on community safety-net hospitals that treat large numbers of lower-income short-stay patients who have complex and costly needs.
The assertion that the proposed Medicare inpatient payment increase is not sufficient to account for the sustained cost growth and fiscal pressures affecting hospitals and a request that CMS reconsider the assumptions underlying its proposed net payment increase of 2.4 percent.ASH also argued against making participation in a revived and expanded Comprehensive Care for Joint Replacement Model mandatory. In addition, ASH expressed its opposition to the inclusion of data from ambulatory surgical centers and physician-owned hospital cases in the calculation of benchmarks and target prices for the Transforming Episode Accountability Model (TEAM) because those types of providers generally serve patients with lower acuity and better overall health, including by specifically choosing healthier patients, making their costs inherently lower than the patients served by community safety-net hospitals; that, in turn, would artificially lower the program’s target prices – to the great disadvantage of mission-driven community safety-net hospitals.
Learn more about ASH’s response to CMS’s proposed Medicare inpatient prospective payment system rule for FY 2027 from ASH’s comment letter to CMS.
