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AAMC Submits Comment Letter on IPPS FY 2019 Proposed Rule

June 29, 2018—The AAMC June 25 submitted a comment letter on the Centers for Medicare and Medicaid Services (CMS) Inpatient Prospective Payment System (IPPS) fiscal year (FY) 2019 proposed rule. In addition to the standard payment update proposals, the proposed rule detailed changes to the Medicare cost report submission requirements, public listing of hospital standard charges, and payment for chimeric antigen receptor T-cell (CAR-T) therapies. Moreover, the proposed rule addressed several quality measurement issues, including removing quality measures, Value-Based Purchasing (VBP) Program scoring, Hospital-Acquired Condition Reduction Program (HACRP) scoring, and the Medicare and Medicaid Promoting Interoperability Programs.

Below are highlights of the AAMC comments:

Medicare Cost Report Submission Requirements: CMS proposed adding several new requirements to the cost report submission process. CMS would require hospitals not only to maintain financial records and statistical data to support their cost report but to also submit supporting data that identically match the submitted cost report numbers.  The AAMC is concerned that the proposal that certain information must be identical to the numbers on the cost report or be rejected will create significant administrative burden for hospitals. 

Public Listing of Hospital Standard Charges: CMS proposed to require hospitals to report publicly a listing of its standard charges via the internet in a machine-readable format. The AAMC recommended that CMS not finalize the requirement and instead work with hospitals, insurers, consumers, and other stakeholders to identify information that patients need to  understand better the costs they will incur for hospital care.

CAR-T Therapy:  AAMC submitted comments of mixed support for CMS’ payment proposal for CAR-T therapies. It would assign these therapies to MS-DRG 016 and pair payment for them with the new technology add-on payment and outlier payments. In response, AAMC voiced significant concern about insufficient payment to hospitals for these treatments that frequently include extensive hospitalizations. The AAMC supports CMS’ decision to assign these therapies to MS-DRG 016, and to utilize the new technology add-on payment but urged CMS to monitor its impact on outlier payments and hospital reimbursement, as well as consider creating a separate DRG for CAR-T drugs.

Quality Measure Removals: CMS proposed removing 19 quality measures from the five-hospital quality reporting and performance programs. It also proposed to “de-duplicate” an additional 21 measures. The AAMC strongly recommended that CMS finalize the proposals to remove measures that are duplicative, burdensome, or otherwise do not meet the goals of CMS’ Meaningful Measures framework.

VBP Program Scoring: CMS proposed to change the scoring methodology related to proposed measure removals from the program by removing the Safety Domain and re-weighting the remaining domains by doubling the weight of the Clinical Outcomes Domain. The AAMC supported the proposed policy, because it most fairly weights the individual measures within the program.  It also responds to a Government Accountability Office (GAO) report that observed the prior weighting scheme allowed hospitals with performance below the national average on the clinical quality measures yet performed well on the cost measure to receive an incentive payment under the VBP program.

HACRP Scoring: CMS proposed to modify the weighting of the measures by removing the domains and instead weighting the measures equally. The AAMC does not support CMS’s proposed scoring policy and instead recommended that CMS modify the scoring by comparing cohorts of hospitals based upon the measures for which they have scores. This would better ensure that the scoring does not disproportionately penalize teaching hospitals.

Medicare and Medicaid Promoting Interoperability Programs(formerly the EHR Incentive Program): CMS proposed to eliminate the threshold-based scoring methodology and replace it with a points-based scoring methodology. CMS also proposed requiring 2015 Edition of Certified EHR Technology (CEHRT) for calendar year (CY) 2019 reporting and  extending its 2018 policy that hospitals must report on a minimum of four self-selected measures for a self-selected calendar year quarter. The AAMC asked CMS to replace the scoring methodology with a modified version of a points-based approach that would require fewer measures but allow hospitals to receive bonus points for additional measures. If CMS’s proposal to change the scoring is not finalized, the AAMC recommended that CMS should retain the Stage 2 methodology for meaningful use. The AAMC asked CMS to allow hospitals to use both 2014 and 2015 editions of CEHRT for 2019 reporting and encouraged CMS to finalize the continued policy for the reporting period and requirements.

Contact:

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

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

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

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