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AAMC Urges CMS Not to Implement Full "Documentation and Coding" Cut in Inpatient Comment Letter

June 25, 2010

In its June 18 comment letter on the Medicare fiscal year 2011 hospital inpatient proposed rule and supplemental proposed rule, the AAMC urges the Centers for Medicare and Medicaid Services (CMS) to reduce a proposed "documentation and coding" reduction of 2.9 percentage points. The proposed cut was mandated by the TMA, Abstinence Education, and QI Programs Extension Act of 2007 (P.L. 110-90) and CMS analyses showing increased payments due to coding changes that occurred when CMS moved from diagnosis-related groups (DRGs) to Medicare-severity DRGs in 2009. The AAMC's comment letter identifies flaws in the CMS methodology and notes that while some documentation changes occurred, the result should be only a 0.45 percent reduction.

In other areas, the AAMC commends CMS on the development of a three-year plan for quality reporting; however, the Association recommends that any long term plans should not be finalized until after the national priorities and strategic plan for quality improvement have been developed as required by the health reform law. The AAMC supports the public reporting of hospital-acquired infections but urges a delay in public reporting through the National Healthcare Safety Network (NHSN) until significant operational issues have been addressed. The AAMC also expresses concern regarding the use of registries in the quality reporting program and suggests that a base set of criteria should be met before any registry is used for public reporting purposes.

On the graduate medical education (GME) front, the AAMC asks CMS to confirm the use of the cost report for residents whose time may not be claimed and who also may not bill for their services. The AAMC also encourages CMS to adopt as final the agency's proposal to allow hospitals to submit GME affiliation agreements to the CMS Central Office electronically.


Karen Fisher, JD
Chief Public Policy Officer
Telephone: 202-828-0412

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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