Medicare Inpatient/LTCH Rule Comments Due June 28; MHA Drafts Available

The MHA has prepared draft comment letters to the Centers for Medicare & Medicaid Services (CMS) regarding the proposed rules to update the Medicare fee-for-service prospective payment systems (PPSs) for fiscal year (FY) 2022 for inpatient and long-term care hospitals (LTCHs). The letters are now available for member review prior to the 5 p.m. June 28 submission deadline.

Comments on the FY 2022 inpatient PPS proposed rule focus specifically on:

  • Expressing appreciation of the CMS’ proposal to repeal the requirement for hospitals to report median charges and negotiated payment rates for Medicare Advantage (MA) plans by Medicare-severity diagnosis-related group.
  • Requesting an extension of the Medicare wage index stop-loss transition policy.
  • Supporting improvement of the area wage index for hospitals in the bottom quartile and encouraging the CMS to locate additional funds rather than reducing the standard operating rate for all hospitals.
  • Opposing the $600 million decrease in the uncompensated care pool.
  • Improving the allocation of additional medical residency slots included in the Consolidated Appropriations Act.
  • Objecting to the proposed changes for organ acquisitions.
  • Restoring the American Taxpayer Relief Act documentation and coding offset.
  • Releasing the final program factors for the three Medicare quality-based programs prior to Oct. 1.

Comments on the following topics are included in the letters for both the inpatient and LTCH PPS rules:

  • Opposing the addition of the COVID-19 Healthcare Personnel vaccine in the quality reporting programs.
  • Closing the health equity gap.
  • Using fast healthcare interoperative resources. 

Members are encouraged to review these draft letters and submit comments electronically to the CMS by using the website’s search feature to find file code “1752-P.”  Members may direct questions on the proposed rules to Vickie Kunz at the MHA.