AAMC Comments on Proposed IPPS Rule for FY2023

The AAMC comments submitted in response to the Centers for Medicare & Medicaid Services (CMS) Fiscal Year (FY) 2023 Inpatient Prospective Payment System (IPPS) proposed rule. Below are highlights of the AAMC’s June 16 comment letter.

Proposals for Graduate Medical Education (GME)

Payment of direct costs of higher medical education: On May 17, in the case Milton S. Hershey Medical Center, et al. c.Becerra, the United States District Court for the District of Columbia has struck down the CMS-adjusted weighted full-time equivalent (FTE) count method for Direct Payment for Graduate Medical Education (DGME). The CMS did not appeal and said it would deal with the decision through rulemaking. In the proposed rule, the agency proposed a new calculation method in which, when a hospital’s weighted FTE count is above its 1996 cap, the hospital would adjust the weighted FTE count to the 1996 cap. 1996. A hospital whose number of weighted FTEs does not exceed its 1996 cap would use the number of weighted FTEs. CMS also proposed to make the change retroactive to October 1, 2001. AAMC supported CMS’s proposed changes to the calculation of the adjusted number of weighted DGMEs.

Proposal to allow Medicare GME affiliation agreements within certain rural track FTE limits: For the first time, CMS has proposed to allow hospitals that establish a separately accredited Accreditation Council for Higher Medical Education (ACGME), 1-2 family medicine programs before October 1 to create accreditation agreements. Rural Track Medicare GME membership. The AAMC supported this proposal and encouraged the agency to engage in future regulations that would allow feeder roads programs established under the Consolidated Appropriations Act of 2021 to also engage in feeder agreements. membership after the five-year cap construction window.

Payment proposals

Update of the consumption basket and pricing: The letter from the AAMC said the association does not believe the data used to calculate the update represents significantly higher growth in labor and supply costs that hospitals have experienced at the time. following the COVID-19 public health emergency. The association asked the CMS to increase the market basket update under the power of “exceptions and adjustments” to account for increased labor and supply costs. The AAMC supported the agency’s proposal to mix COVID-19 and non-COVID-19 cases for fiscal year 2023 rate setting.

Aberrant fixed loss threshold: CMS’s calculation of the proposed outlier fixed loss threshold for FY2023 is significantly increased from previous years. The AAMC advised that the fixed loss threshold for fiscal year 2023 is significantly higher due to a concentration of high-cost COVID-19 cases used in the base calculation. The letter asked the CMS to consider removing COVID-19 cases from the outlier fixed loss threshold calculation.

Disproportionate share of hospital payments and unpaid care: The AAMC letter asked CMS to consider the potential for high rates of uninsurance due to new Medicaid determinations and the expiration of market-enhanced subsidies when the public health emergency ends with the factor 2.

Medicaid Portion: CMS has proposed a new definition of Medicaid beneficiaries who can be included in the Medicaid portion. The AAMC letter asked the agency to include all Medicaid beneficiaries covered by an 1115 demonstration waiver in the Medicaid fraction.

Salary index: The AAMC supported the proposal of the CMS to continue the policy of indexation of the low wages. The letter also asked the agency to consider the impact of the COVID-19 public health emergency on the wage index.

Declaration of COVID-19 and seasonal influenza: The AAMC letter asked the CMS not to finalize the proposal to require continued reporting of COVID-19 and seasonal influenza as a hospital condition of participation.

Payment adjustment for N95 masks: The AAMC expressed support for CMS’s goal of maintaining a strong global supply chain for hospital supplies, including N95 masks. However, the AAMC questioned whether the Medicare program was the best way to address supply chain issues. The letter called on the agency to continue stakeholder engagement to ensure that Medicare is the appropriate program to incentivize the purchase of 100% domestically manufactured N95 masks.

Quality proposals

Social Determinants of Health Diagnostic Codes (Z codes): The AAMC’s comments encouraged the CMS to further explore the link between the Z59.0 (homelessness) code and payment by reclassifying it as a complication or comorbidity code for the purposes of Medicare severity diagnostic grouping. and encourage stakeholder participation to determine the best way to proceed. .

Impacts of climate change on health equity: In response to a request for information regarding climate change, the AAMC comment letter suggested that CMS engage broadly in a collaborative approach to developing innovative solutions to address the role of the healthcare sector in the climate change.

Measuring disparities: AAMC’s comments in response to several inquiries regarding Medicare’s measurement of health disparities through quality measures encouraged the agency to (1) focus on developing the intra- to measure inequities, (2) prioritize process and access measures, (3) carefully assess specific health-related social needs and social risk factors to assess inequities, and (4) focus primarily on how to use the measurement of inequalities to inform providers and interventions.

Measuring technical cuts and changes to address COVID-19 impacts in quality pay-for-performance programs: The AAMC letter supported proposals to remove certain quality measures in the Hospital Value-Based Purchase Program and the Hospital-Associated Ailment Reduction Program in response to the COVID-19 public health emergency. Additionally, the association’s comments suggested that the CMS consider additional changes to the proposed risk adjustment changes for certain measures when assessing the history of COVID-19.

Adoption of new measures for the Inpatient Quality Reporting (IQR) program: The AAMC’s comments urged the CMS to consider the burden of adopting ten new metrics in the IQR program in a single year and prioritize the metrics most meaningful to hospitals and patients.

Interoperability Promotion Program (IP): The AAMC letter suggested that in proposing significant changes to the PI program scoring, the CMS balances the increased emphasis on public health reporting through the proposed scoring changes with the need to invest more in public health departments to better support electronic health record data and reporting enhancements. swap.

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