MHA Draft Comments Available for FY 2020 Medicare IPPS Proposed Rule

Posted on June 14, 2019

The MHA has drafted comments to the Centers for Medicare & Medicaid Services (CMS) regarding the proposed rule to update the Medicare fee-for-service (FFS) inpatient prospective payment system (IPPS) for fiscal year (FY) 2020. While the impact varies by individual hospital, Michigan hospitals statewide are estimated to realize a $79 million, or 1.9%, payment increase, which is lower than the expected increase in medical cost inflation that generally ranges from 5.5% to 7% annually. In its comments, the MHA requested:

  • Additional funding to reduce disparities in the Medicare wage index. The MHA objects to the CMS proposal to increase the wage index values for hospital in the bottom quartile at the expense of those in the top quartile. 
  • That the CMS use multiple years of data to allocate the nearly $8.5 billion uncompensated care payment pool among the 2,400 hospitals nationally that are eligible for disproportionate share hospital payments.
  • Annual review of Worksheet S-10 data for all hospitals, similar to the existing AWI review process.
  • A delay in the proposed change in severity level for approximately 1,500 ICD-10-CM procedure codes, since the CMS has not provided sufficient data to determine whether the changes are appropriate. The proposed changes would result in a decrease in severity level for almost 1,000 codes that are currently designated as Major Complication or Comorbidities (MCC) or CC. 
  • Full restoration of the documentation and coding offset that decreased payment rates for FYs 2014-2017.
  • An increase for new technology add-on payment to 100% rather than the proposed 65%.
  • Payment for chimeric antigen receptor (CAR) T-cell therapeutic agent on a reasonable cost basis, similar to payment policy for solid organ transplants.
  • The annual release of final program factors for the three Medicare quality-based programs prior to Oct. 1.
  • That the CMS not use the same measure or a variation of it in multiple quality-based programs. The CMS proposes to use the same healthcare-associated infection measure administrative requirements across the value-based purchasing and hospital-acquired conditions reduction program.
  • That the CMS not adopt the proposed new electronic clinical quality measure Hospital Harm — opioid-related adverse events, since it is not endorsed by the National Quality Forum.

Unless otherwise noted, provisions of the proposed rule take effect Oct. 1, 2019. The MHA encourages members to submit comments to the CMS by June 24. Following release of the IPPS final rule, expected in early August, the MHA will provide hospitals with an updated impact analysis. Members with questions should contact Vickie Kunz at the MHA.

Tags: Medicare, proposed rule, comments, 2020 IPPS

Posted in: Member News

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