Every year, the Centers for Medicare & Medicare Services (CMS) publishes in the Federal Register a draft regulation describing how it proposes paying hospitals for the inpatient care they provide to their Medicare patients in the coming fiscal year. The proposed inpatient prospective payment system regulation for FY 2015 was published on May 15, and as always, CMS invited interested parties to submit written comments.
The National Association of Urban Hospitals has always found CMS to be receptive and even responsive to its comments and therefore takes the opportunity to submit detailed comments and suggestions about the agency’s annual proposal.
NAUH is presenting excerpts from its comment letter to CMS. The subjects and the dates they will be published are:
June 26 – The size of the Medicare DSH pool
June 27 – The manner in which CMS uses CBO estimates of changes in insurance status
June 30 – The methodology for distributing Medicare DSH funds
July 1 – The need for appropriate risk adjustment in the hospital readmissions reduction program
July 2 – a much-needed adjustment to the methodology employed by the hospital readmissions reduction program
Today – hospital inpatient rates
July 7 – short hospital stays (two-midnight rule)
NAUH’s complete comment letter to CMS can be found here.
Hospital Inpatient Rates
NAUH recognizes that some of the proposed adjustments of the annual Medicare inpatient rate update are statutory requirements. Last year, however, CMS applied a budget neutrality factor in anticipation of increased inpatient spending associated with the implementation of Medicare’s two-midnight rule. In light of the challenges the agency encountered in implementing this rule, NAUH urges CMS to evaluate whether experience in the current fiscal year demonstrates that this adjustment was justified. If, as we suspect, it is not, we urge CMS to reverse this adjustment in FY 2015.
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Monday – Short Hospital Stays (Two-Midnight Rule)
NAUH’s complete comment letter to CMS can be found here.
