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AAMC Submits Comment Letter on IPPS FY 2020 Proposed Rule

June 28, 2019—The AAMC June 24 submitted a comment letter on the Centers for Medicare and Medicaid Services (CMS) Inpatient Prospective Payment System (IPPS) fiscal year (FY) 2020 proposed rule.  In addition to the standard payment update proposals, the rule proposed changes to payments for chimeric antigen receptor T cell therapies, the Medicare wage index, and the data source for calculating uncompensated care payments. Moreover, the proposed rule addressed several quality issues, including adopting quality measures, electronic clinical quality measure (eCQM) reporting, and the collection of race data in the Long-Term Care Hospital Quality Reporting Program (LTCH QRP).

Below are highlights of AAMC comments on proposals in the IPPS proposed rule:

Chimeric Antigen Receptor (CAR) T Cell Therapy: CMS proposed to continue assigning CAR-T cell therapy to Medicare Severity Diagnosis Related Group (MS-DRG) 016 in FY 2020 and continue new technology add-on payments (NTAPs) for CAR-T cell therapy. CMS also solicited feedback on a potential new MS-DRG for CAR-T cell therapy that would not include indirect medical education (IME) and disproportionate share hospital (DSH) payment adjustments. The AAMC supports CMS’s decision to keep CAR-T cell therapy in MS-DRG 016 and continue NTAP payments. However, the AAMC insists that if a separate MS-DRG is created in the future, it must include IME and DSH payment adjustments. 

Hospital Wage Index: CMS proposed to raise and reduce the wage index for targeted quartiles of hospitals. The AAMC also believes that CMS does not have the authority to implement the proposed changes to the wage index. The AAMC encourages CMS to explore more comprehensive reform to ensure that the data for the wage index is accurate and that hospitals at the low end of the wage index are paid appropriately.

Disproportionate Share and Uncompensated Care Payments (UCPs) (Factor 3): CMS proposed to use a single year of audited FY 2015 Worksheet S-10 data to calculate uncompensated care payments. Alternatively, CMS requested comments on whether unaudited FY 2017 Worksheet S-10 data would be more appropriate. The AAMC supports CMS’s proposal to use audited FY 2015 Worksheet S-10 data, but requests that CMS begin auditing FY 2017 Worksheet S-10 data in preparation for FY 2021 to ensure the data is as accurate and consistent as possible.

New Technology Add-On Payments (NTAP): CMS has proposed to increase the NTAP from 50% to 65% of the additional cost of the new service or technology or 65% of the amount by which costs exceed the standard DRG. The AAMC supports raising the NTAP, which contributes modestly to ensuring adequate payment for new high-cost services and technologies.

Peripheral Extracorporeal Membrane Oxygenation (ECMO): CMS proposed to reassign peripheral ECMO to Pre-MDC MS-DRG 003. The AAMC supports CMS’s decision to reassign peripheral ECMO to a DRG that more appropriately reflects the cost of peripheral ECMO procedures.

Critical Access Hospitals (CAHs) as Nonprovider Sites for Purposes of Direct Graduate Medical Education (DGME) and Indirect Medical Education (IME):CMS proposed to include CAHs as nonprovider sites for purposes of DMGE and IME. Currently, the time residents spend rotating to CAHs cannot be counted for DGME and IME for IPPS hospitals. The AAMC supports CMS’s decision to allow IPPS hospitals to claim the time residents spend training at CAHs. However, the AAMC also requested that CMS allow IPPS teaching hospitals that are currently within their cap-building period to count the time residents previously spent training at CAHs at any point during their cap-building period.    

Urban-to-Rural Reclassification Applications and Cancellations: CMS proposed to allow hospitals to apply for 42 C.F.R. 412.103 reclassifications using electronic means or fax, and modify reclassification cancellation requirements, which would no longer require a hospital to be paid as rural for one 12-month cost reporting period before cancelling. The AAMC supports CMS’s proposals to add flexibility to the application and cancellation of 42 C.F.R. 412.103 rural reclassifications.

Quality Measure Adoption: CMS has proposed to adopt three new measures for the Inpatient Quality Reporting (IQR) Program and solicited feedback on three potential future measures. The AAMC emphasized that these proposed and future measures must be National Quality Forum (NQF)-endorsed and approved by the Measure Applications Partnership (MAP) before they are proposed for adoption in the IQR program.

Electronic Clinical Quality Measure (eCQM) Reporting: CMS has proposed to retain the current eCQM reporting requirements beyond calendar year (CY) 2021 reporting for both the IQR and the Promoting Interoperability Program and make the Safe Use of Opioids measure mandatory for CY 2022. The AAMC supports CMS’s decision to maintain the current reporting requirements, but urges CMS to not finalize its proposal to make the Safe Use of Opioids measure mandatory to report in CY 2022, as it would leave inadequate time to test the measure before it is made mandatory.

Long-Term Care Hospital Quality Reporting Program: CMS has proposed to adopt a new race data element for LTCH continuity assessment record and evaluation data set (LCDS) data collection. The AAMC requests that CMS not finalize this proposal due to serious flaws in its question framing.

Contact:

Mary Mullaney
Director, Hospital Payment Policies
Telephone: 202-909-2084
Email: mmullaney@aamc.org

Phoebe Ramsey, J.D.
Sr. Regulatory Analyst - Quality & Payment Policy
Telephone: 202-448-6636
Email: pramsey@aamc.org

Andrew Amari
Hospital Policy and Regulatory Specialist
Telephone: 202-828-0554
Email: aamari@aamc.org

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Washington Highlights, a weekly electronic newsletter, features brief updates on the latest legislative and regulatory activities affecting medical schools and teaching hospitals.


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Jason Kleinman
Senior Legislative Analyst, Govt. Relations
Telephone: 202-903-0806
Email: jkleinman@aamc.org