News: AHA comments on inpatient payment proposals for FY 2017
The American Hospital Association (AHA) is concerned about the documentation and coding reduction, changes to disproportionate share hospital (DSH) payments, and the implementation of many of CMS’s quality programs detailed in the CMS IPPS Proposed Rule for Fiscal Year (FY) 2017, according to a response published by the AHA on June 17, 2016.
The AHA believes the proposed documentation and coding cut of 1.5 percentage points is “inconsistent with Congress’ intent” of the American Taxpayer Relief Act of 2012 (ATRA) and, as well as the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) where Congress reiterated its belief that the reduction should be 0.8 percentage points. The AHA urged CMS to remove any amount over 0.8 percentage points or return it to the standardized amount in FY 2018.
To better track and measure the cost of care for treating uninsured patients, CMS is suggesting a three-year phase-in of incorporating hospital’s Worksheet S-10 data—total facility bad debt expenses and total facility Medicare reimbursable bad debts—to determine uncompensated care payments. The AHA remained concerned, asking CMS to take additional steps to ensure accuracy, consistency, and completeness of Worksheet S-10 data before using it to determine uncompensated care payments, and to consider a potentially longer phase-in approach and/or a stop-loss policy.
CMS proposed a number of changes to the Hospital Inpatient Quality Reporting (IQR) Program, including removing two registry participation measures, 13 electronic clinical quality measures (eCQMs), and two chart-abstracted measures. In general, the AHA felt that the existing IQR falls short when it comes to improving quality in the most important areas. The organization started by suggesting CMS streamline and focus the IQR program by identifying concrete and actionable goals for quality improvement.
Additionally, CMS proposed four new quality measures for FY 2019. The AHA does not support any of the proposed measures. For the three clinical episode-based payment measures, the AHA suggested CMS consider provider data and information about the episodes of care to hospitals using a mechanism other than the IQR program. The fourth measure, excess acute care days after pneumonia hospitalization, the AHA urged CMS not to adopt measures for pneumonia, stating they do not believe there is clear or consistent evidence to suggest hospitals are substituting observation stays and ED visits in place of readmissions.
The association also recommended additional changes to the hospital-acquired conditions and readmissions programs and electronic clinical quality measures. It submitted separate comments on the rule’s long-term care hospital proposals.
Editor’s note: ACDIS and its Advisory Board also sent comments to CMS on June 16. Its principal concerns included the DCA cut, ICD-10-PCS and CMS grouping logic, changes in quality measures, and changes to the value-based purchasing program, among other matters. ACDIS members can read their complete comments in the forthcoming July/August edition of the CDI Journal.