CHA News Article

CHA Submits Comments on FFY 2019 Inpatient Prospective Payment System Proposed Rule

CHA has submitted the attached comment letter on the Centers for Medicare & Medicaid Services’ (CMS) federal fiscal year (FFY) 2019 inpatient prospective payment system proposed rule. CHA thanks members for their feedback on the draft comment letter.

In the letter, CHA opposes CMS’ proposal to proceed in weighting Worksheet S-10 at two-thirds for FFY 2019 and believes significant issues remain with the data. CHA suggests that CMS use one year of S-10 data (FFY 2015), weighted at the current one-third, and low-income patient days, weighted at two-thirds, for FFY 2019 and 2020.

CHA applauds CMS for its efforts to reduce the quality measure reporting burden on hospitals, but urges clarification on how the proposed measure removals will impact public reporting, including Hospital Overall Star Ratings, in the final rule. While CHA appreciates the de-duplication of measures across quality programs, the letter expresses concern that continued volatility in pay-for-performance programs does not allow for meaningful conclusions about hospital performance improvement. In addition, CHA supports CMS’ proposal to extend current requirements that hospitals report on four self-selected electronic clinical quality measures (eCQMs) for one calendar year quarter of data for the 2019 reporting year.

CHA supports the proposed 90-day reporting period for 2019 and 2020 for the Medicare and Medicaid Promoting Interoperability programs, but urges CMS to make additional changes, including more evenly distributing weights across the objectives as hospitals transition to new editions of electronic health record technology and adjust to the new scoring methodology. In response to the request for information on promoting electronic interoperability, CHA encourages the agency to take a broad, rather than piecemeal, approach to updating the Conditions of Participation and consider implications across the delivery system while engaging in a robust stakeholder engagement process.

CHA also supports the proposal to reduce documentation requirements for inpatient admission orders and welcomes additional dialogue with the agency on additional burdensome regulatory issues that could be further addressed under the Patients Over Paperwork Initiative.