MHA Releases Draft Comments on Medicare FY 2019 IPPS Proposed Rule

Posted on June 15, 2018

The MHA has drafted comments in response to the proposed rule that the Centers for Medicare & Medicaid Services (CMS) recently released to update the fiscal year (FY) 2019 inpatient prospective payment system (IPPS) effective Oct. 1. The MHA comments on the proposal address numerous topics, including:

  • Price transparency considerations.
  • Requesting CMS payment for Chimeric Antigen Receptor T-cell therapy services through a new technology add-on payment, which would not be subject to budget-neutrality requirements and would not reduce IPPS payments for other core services.
  • Recommending that the full 3.9 percent cut from IPPS payments resulting from the American Taxpayer Relief Act of 2012 be returned to hospitals.
  • Phasing-in substantial reductions in Medicare-severity diagnosis-related group (MS-DRG) relative weights for the four MS-DRGs proposed to have weight decreases between 20 and 30 percent.
  • Correcting the low-volume payment adjustment formula, which was incorrectly reflected in the proposed rule, and provide instructions to the Medicare Administrative Contractor for making this adjustment to hospitals for FY 2018, which is retroactive to Oct. 1, 2017.
  • Delaying year two of the transition to using Worksheet S-10 data for distributing the $8.25 billion uncompensated care pool among approximately 2,500 hospitals nationally, due to potential data inconsistencies.
  • Objecting to the CMS requiring interoperability as a Medicare condition of participation.
  • Supporting the proposed removal of 39 measures from the hospital inpatient quality reporting program and eliminating similar measures from multiple Medicare quality-based programs.
  • Supporting the proposed removal of 10 measures from the hospital value-based purchasing program and the proposed domain weighting.
  • Requesting that the CMS examine the impact of using data for the hospital readmissions reduction program that includes both ICD-9 and ICD-10 data to ensure there are no unintended negative consequences due to using data from two unique systems.
  • Objecting to the use of the patient safety indicator-90 measure in the hospital-acquired conditions reduction program; the MHA believes this measure lacks reliability.
  • Requesting that hospitals be allowed to provide an updated listing of Medicaid-eligible patient days prior to the Medicare desk review or audit. The CMS proposes to require hospitals to provide this listing with their filed cost report, when the most accurate data is not available.

The MHA encourages hospitals to submit comments to the CMS by June 25. The MHA distributed hospital-specific impact analyses May 25 and will provide an updated analysis following release of the FY 2019 IPPS final rule, which is expected in early August. Members with questions should contact Vickie Kunz at the MHA.

Tags: Medicare, proposed rule, comments, 2019 IPPS

Posted in: Member News

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