AHA to CMS: Proposed inpatient, LTCH payment updates ‘woefully inadequate’

Commenting today on the proposed rule for the inpatient prospective payment system for fiscal year 2023, AHA today urged the Centers for Medicare & Medicaid Services to adjust the market basket update to account for the unprecedented inflationary environment hospitals and health systems are experiencing, and eliminate the productivity cut.  
 
“When historical data vastly underestimate future inflation, the market basket becomes inadequate,” AHA wrote (LINK). “Similarly, when data incorrectly predict gains in productivity, the productivity adjustment is substantially overstated. This is essentially what occurred in the forecasting of the FY 2022 and 2023 market basket and productivity adjustments.” 
 
AHA also urged the agency to update its estimates of the Medicare Disproportionate Share Hospital amount to more accurately reflect discharge volume and the uninsured rate; and consider additional temporary changes to help mitigate the dramatic increase in the high-cost outlier threshold.  

The association voiced support for provisions related to the full-time equivalent cap calculation in the graduate medical education program and the cap on area wage index decreases, as well as proposals to recognize the ongoing impact of the COVID-19 pandemic on quality programs and advance health equity.