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AAMC Submits Comments on 2012 Medicare Hospital Outpatient Proposed Rule

September 2, 2011—The AAMC sent an Aug. 30 comment letter on the Medicare calendar year (CY) 2012 hospital outpatient proposed rule, urging the Centers for Medicare and Medicaid Services (CMS) to delay the implementation of the Medicare Spending Per Beneficiary (MSPB), Hospital Acquired Condition (HAC), and AHRQ Patient Safety Composite measures in the Value Based Purchasing (VBP) program starting in FY 2014. CMS had previously attempted to finalize these measures for VBP in the FY 2012 IPPS final rule [see Washington Highlights, Aug. 5].

In the OPPS CY 2012 proposed rule, the agency recommends a domain weighting scheme and performance periods for these measures. Because these measures have not been publicly reported on the Hospital Compare website for one year, as required by the Affordable Care Act (P.L.111-148 and P.L.111-152), the AAMC states that they are ineligible for inclusion in the VBP program at this time. The AAMC letter maintains that all measures must meet this statutory requirement to allow consumers, stakeholders, and CMS the opportunity to monitor for any unintended consequences prior to implementation. 

In other areas, the AAMC urges CMS to amend the agency’s proposal to pay for separately payable drugs and biologicals at the average sales price (ASP) plus 6 percent, rather than the proposed ASP plus 4 percent, until CMS establishes a more precise methodology for determining the acquisition and overhead costs of these products.

The letter also supports an adjustment for cancer hospitals but expresses concern regarding the increases in copayments that will accompany the proposed adjustment.  In the letter, AAMC encourages CMS to adopt an approach to this adjustment that does not impede beneficiary access to care.

Quality Issues

Jennifer Faerberg, MHSA
Director, Clinical Transformation Unit
Telephone: 202-862-6221


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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
Sr. Legislative Analyst, Govt. Relations
Telephone: 202-903-0806