The AAMC submitted June 8 comments to the Centers for Medicare & Medicaid Services (CMS) in response to the Fiscal Year (FY) 2027 Inpatient Prospective Payment System (IPPS) proposed rule [refer to Washington Highlights, April 17].
The AAMC urged the CMS to increase the market basket update to incorporate expected growth in hospital input costs and reevaluate the accuracy of the total factor productivity adjustment. The AAMC also asked the CMS to withdraw its proposed changes to cost reporting allocation principles related to organ acquisition costs, as these changes would result in transplant hospitals not being accurately reimbursed for their overhead costs. Comments also touched on disproportionate share hospital and uncompensated care payments, the low wage index policy, Z-code severity changes, high-cost outlier payments, and provider-based criteria.
The AAMC commented on policies related to graduate medical education, including a request not to finalize proposed regulatory changes to approved programs, while also supporting the adoption of policies to make determinations for a new residency training program based on a letter of initial accreditation from the program accreditation. The AAMC appreciated clarifications for hospital merger calculations and made a request for information regarding CAA, 2021 Section 131 PRA, and FTE resets.
The letter also suggests significant refinements to the mandatory episode-based payment models, including the need to work with stakeholders to develop a sustainable target pricing model. The AAMC asked the CMS to ensure that the alignment of quality measurement policies with the hospital quality reporting programs is appropriate for performance-based measurement, in addition to comments on specific policies proposed for the hospital quality programs in the rule.