Michigan Health & Hospital Association Issues Public Comment on Centers for Medicare & Medicaid Services Proposed Rule

WASHINGTON, July 23 -- Vickie R. Kunz, senior director for health finance at the Michigan Health and Hospital Association, Lansing, has issued a public comment on the Centers for Medicare and Medicaid Services' proposed rule entitled "Medicare Program; Hospital Inpatient Prospective Payment Systems for Acute Care Hospitals and the Long-Term Care Hospital Prospective Payment System and Proposed Policy Changes and Fiscal Year 2021 Rates; Quality Reporting and Medicare and Medicaid Promoting Interoperability Programs Requirements for Eligible Hospitals and Critical Access Hospitals ". The comment was written on July 9, 2020, and posted on July 17, 2020:

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On behalf of its member hospitals, the Michigan Health & Hospital Association (MHA) appreciates this opportunity to provide comments to the Centers for Medicare & Medicaid Services (CMS) regarding the proposed rule to update the Medicare fee-for-service (FFS) hospital Inpatient Prospective Payment System (IPPS) for fiscal year (FY) 2021. The proposed rule is estimated to provide a $105 million, or 2.5%, increase to Michigan hospitals in FY 2021, which is less than the projected 5% increase in healthcare inflation projected for 2021.

The absence of adequate Medicare payments challenges the financial viability of Michigan hospitals and their ability to provide care to Medicare and other patients. The latest Medicare margins data reflects that statewide Medicare fee-for-service (FFS) pays Michigan PPS hospitals approximately 4% less than the cost of providing care to Medicare beneficiaries, resulting in a shortfall of $275 million.

Our comments regarding the IPPS proposed rule focus specifically on:

* Requiring hospitals to report median charges and negotiated payment rates for Medicare Advantage (MA) plans and third-party payors by Medicare-Severity Diagnosis Related Group (MS-DRG)

* Requesting additional funding to reduce disparities in the Medicare wage index

* Extending the deadline for wage data reviews and the 2019 occupational mix survey

* Codifying several provisions for Medicare allowable bad debt

* Urging the CMS implement an annual review of Worksheet S-10 data for all DSH-eligible hospitals and clarify reporting instructions

* Restoring the American Taxpayer Relief Act (ATRA) Documentation and Coding Offset

* Recommending the CMS continue new technology add-on payments for Chimeric Antigen Receptor T-cell (CAR-T) Therapy services

* Objecting to the proposal to require more than two quarters of electronic clinical quality (eCQM) measure data submission

* Adopting the Hybrid Hospital-Wide Readmission Measure

* Releasing the final program factors for the three Medicare quality-based programs prior to Oct. 1

PRICING TRANSPARENCY

The MHA is disappointed that the CMS is proposing to require hospitals to disclose privately negotiated contractual terms particularly since this will not further the CMS' goal of paying market rates that reflect the cost of providing care. Negotiated payment rates take many factors into account and often represent unique circumstances between a hospital and private payor and are not relevant for use in the Medicare FFS system.

Specifically, the CMS proposes to collect, through the Medicare cost report, the median payor-specific negotiated charge by MS-DRG that a hospital has negotiated with all:

(1) Medicare Advantage (MA) plans and

(2) third-party payers

The CMS proposes to use data collected on payer-specific negotiated payment rates, among MA organizations to calculate new relative weights in the MS-DRG system, beginning in FY 2024.

This requirement would be effective for cost reporting periods ending on or after Jan. 1, 2021, which means many hospitals such as those with fiscal years ending March 31 or June 30 will be required to report this data on their next filed cost report. Hospitals are not prepared to report this data in such a short timeframe particularly given the intense challenges resulting from the COVID-19 pandemic. If the CMS opts to move forward with this proposal, the MHA urges the CMS to adopt the requirement for cost report periods beginning on and after a specific date to give hospitals additional time to comply. This would also result in all hospitals reporting data for a full year rather than a partial year based on their FYE.

Since hospitals do not bill services at the MS-DRG level, this requirement will create a significant burden on hospitals that are being asked to compile the data by MS-DRG. Hospitals often negotiate other methods of payment in their contracts including per diem rates, percent of charge arrangements, All Patient Refined DRGs, etc. The CMS has indicated that payment under these systems would need to be cross-walked to MS-DRGs. It is unclear specifically how hospitals will do this. The CMS has estimated the total annual burden for this proposal to be equal to 15 hours per hospital based on 10 hours of reporting and 5 hours of record keeping per hospital to update the Worksheet S-12. The MHA urges the CMS to abandon this proposal. The administrative burden on hospitals will be considerably greater than the 15 hours estimated.

As stated in our Jan. 29, 2020 comments regarding the transparency proposed rule requiring health plans to report certain data, the MHA strongly supports healthcare transparency inclusive of both price and quality and ensuring that patients and their families have timely information to make informed healthcare decisions. Charge transparency from hospitals is important for some patients such as the uninsured population while patient-specific cost-sharing liability is key for patients covered by Medicare, MA, Medicaid and commercial health plans.

Regulatory changes to increase healthcare transparency should result in outcomes that meet the needs of patients to make informed healthcare purchasing decisions while not adding unnecessary burden and cost to healthcare providers. We must continue to work collectively to educate patients about how to use price and quality information together to make better informed healthcare decisions. The MHA recommends the CMS also take action to promote the use of information about healthcare quality and patient safety. The CMS provides this information to the public on its "provider compare" websites. This and similar sites such as the MHA's transparency site, www.verifymicare.org, should also be promoted.

Finally, patients should also have information regarding the total cost of care across the full continuum, professional, acute, and post-acute, to allow for a greater understanding of healthcare cost beyond an individual service.

WAGE INDEX CHANGES

The area wage index (AWI) is used to adjust Medicare operating and capital payments for geographic variations in labor costs. For FY 2020 and at least three additional years, the CMS proposes to reduce disparities in the Medicare AWI among hospitals that have a low AWI value by increasing the AWI for hospitals in the bottom quartile funded by a decrease in the national standardized operating rate for all hospitals. The MHA appreciates the CMS' recognition of hospitals with low wage rates. In the past this was recognized for the frontier states with an increase to 1.0 and funded by new funds. We believe that the CMS could implement a similar solution for low wage hospitals with new funding as it has done to date.

While the MHA ardently supports improving the wage index for hospitals with low wage rates, especially in our rural areas, the MHA opposes the CMS' proposed improvement of AWI values for some hospitals funded by a reduction to the standardized operating rate for all hospitals, especially when Medicare pays less than the cost of providing care. We believe that the CMS can locate additional funds to increase the AWI for hospitals in low-wage areas.

WAGE DATA REVIEW & OCCUPATIONAL MIX SURVEY DEADLINE

In May the CMS released preliminary data that will be used to develop the FY 2022 area wage index, with hospitals having until Sept. 3 to request data revisions and provide supporting documentation. Given the COVID pandemic that hospitals have been dealing with since March, we urge the CMS to extend the deadline for hospital data reviews from Sept. 3 to Oct. 31, 2020.

The CMS is required to collect data on the occupational mix of employees every three years for each short-term acute care hospital participating in the Medicare program with this data used to adjust the Medicare area wage index. The 2019 survey is due to the Medicare Administrative Contractor (MAC) on Aug. 3, 2020. We recognize that the CMS extended the deadline for survey submission from July 1 to Aug. 3 and indicated that hospitals should communicate concerns meeting the deadline to the CMS via their MAC. However, given the hospital resources dedicated to the public health emergency since March, we urge the CMS to automatically extend the submission deadline for all hospitals until Sept. 3 or after. This is especially vital since survey results will be used to adjust the wage index for three years--FY 2022, 2023 and 2024.

MEDICARE REIMBURSABLE BAD DEBT

The CMS proposes to codify several policies that have been in existence in the Provider Reimbursement Manual, many of which have been applied for several years in cost report audits. The MHA opposes retroactive rulemaking and disagrees with the CMS' position that retroactive implementation of bad debt policy proposals would advance the public interest. Instead retroactive implementation would have the opposite effect--providers would likely request re-opening and re-submitting cost reports out of an abundance of caution to ensure compliance with retroactive rules. Providers would feel compelled to reassess all previous cost reports if policies were made retroactive, leading to an increased burden for both providers and government resources. Our other specific concerns are identified below.

Required Documentation

The CMS is specifically identifying documentation required for Medicare bad debts, proposing to require copies of billing statements sent to patients. This requirement is unnecessary and has not been a required document in past audits. The use of electronic health records (EHR) allows notes to be automatically generated in the patient account upon issuance of statements. These EHR notes sufficiently support the collection efforts of the hospital and have satisfied the requirements of cost report auditors. The MHA opposes the requirement for a patient statement and urge the CMS to abandon this requirement.

Accounting Practices

The CMS is proposing to require that patient accounts must be written off the hospital's accounting system as a bad debt expense rather than a contractual allowance. Specifically, the accounts must be written off with a bad debt transaction code. While this is acceptable for traditional Medicare bad debt patients, it is inappropriate to require this for Medicare-Medicaid dual-eligible patients since it is contrary to the accounting practice of many hospitals throughout the country. When Medicaid denies coverage on a Medicare coinsurance or deductible, the amount is typically transacted with a contractual allowance transaction code. Since the hospital is precluded from attempting to collect these deductibles and coinsurance amounts from Medicaid beneficiaries, it is inappropriate to classify these amounts as bad debt and believe that a contractual allowance transaction code is more appropriate.

The CMS Medicare bad debt regulations also allow reimbursement of Medicare coinsurance and deductible accounts written off as charity care, subject to various requirements. When a beneficiary meets the requirements of the hospital's financial assistance policy, these amounts are written off the accounting system to charity care. The CMS proposal to require hospitals to write off these accounts as bad debt in order to be reimbursed by Medicare is contrary to usual accounting practices. Further, the requirement to use a bad debt transaction code for these patients will impact the calculation of the Medicare Disproportionate Share Hospital (DSH) uncompensated care (UCC) pool.

The MHA opposes the CMS dictating hospitals' internal accounting policies for reimbursing Medicare beneficiaries' uncollectible deductible and coinsurance amounts, assuming the hospital meets all other requirements. We request the CMS remove these requirements that specify how hospitals transact patient accounts within the general ledger since this is not a determining factor reflecting collection efforts and should not preclude hospitals from being reimbursed for these otherwise allowable accounts under the Medicare bad debt regulations.

Presumptive Eligibility

The CMS should allow hospitals to use presumptive eligibility tools to determine indigence for Medicare bad debt purposes. The CMS proposes a list of factors that a hospital must review to determine whether a non-dual eligible beneficiary is indigent, including assets, liabilities, income, and expenses. When a beneficiary is determined to be indigent, the provider can write off any amounts owed without having to go through the collection process. Many hospitals already use these processes, which are efficient and reliable, for determining if patients qualify for financial assistance. The MHA recommends that the CMS allow presumptive eligibility determinations for determining patient indigence for Medicare bad debt purposes.

ALLOCATION OF UNCOMPENSATED CARE (UCC) POOL PAYMENTS

Calculation of FY 2021 UCC Factor 1

The CMS Office of the Actuary (OACT) estimates the UCC Factor 1 annually based on the most recently available data and adjusts this estimate to account for inflation and changes in utilization and case mix. Since release of the FY 2020 IPPS Final Rule, the CMS has updated several of its assumptions, which have led to a nearly $1 billion or 7.4% decrease in the FY 2021 Factor 1 compared to FY 2020.

The main driver of this decrease is changes in the CMS' assumptions around the "Other Factor," which includes various adjustments to payment rates not accounted for by the update, case mix, or discharge factors. The "Other Factor" also includes a factor for Medicaid expansion due to the Affordable Care Act (ACA). To date, the CMS has provided limited transparency of how the "Other Factor" is calculated. Given the significant change in Factor 1 since FY 2020, the MHA encourages the CMS to provide additional information on the calculation of Factor 1, including the parameters around any assumptions made by the CMS in this calculation.

Calculation of FY 2021 UCC Factor 2

Factor 2 is used to adjust Factor 1 based on the change in uninsured since implementation of the ACA. Since FY 2018, the CMS uses the uninsured estimate from the National Health Expenditures Accounts. With the ongoing COVID-19 pandemic, there has been an unexpected spike in unemployment, which has led to a significant increase in the uninsured. The MHA encourages the CMS OACT to account for the effects of the COVID-19 public health emergency in its model to estimate the percent of uninsured and underinsured for FY 2021.

Calculation of FY 2021 UCC Factor 3

The CMS proposes to use audited S-10 UCC costs from FY 2017, which were audited for roughly 65% of hospitals nationally and reflect the most recently audited data. The FY 2017 data also reflects revisions to worksheet S-10 cost report instructions that were effective as of Oct. 1, 2017 and should result in increased consistency in data reporting by hospitals compared to earlier years. The CMS proposes to use the most recent single year of data that have been audited for a significant number of hospitals receiving substantial Medicare UCP for FY 2022 and subsequent years.

We have concerns about the proposed use of FY 2017 data for allocating the FY 2021 UCP pool, since it was not audited or reviewed for roughly 35% of hospitals nationally. The MHA encourages the CMS to review the data for all hospitals using a desk review process similar to that used annually for reviewing wage index data. We also urge the CMS to ensure consistent procedures are in place across all MACs for reviewing the data. We believe this would help improve consistency in data across all hospitals which is vital since the data is used to allocate the $7.8 billion UCC pool.

Consistent with our comments on the FY 2020 IPPS proposed rule, the MHA remains concerned about the volatility of using a single year of UCC data to allocate the UCC pool and again encourage the CMS to use an average of three years of data when calculating Factor 3.

Insured Charity - Medicare Beneficiaries

As we noted in the Medicare bad debt comments above, we have concerns with the CMS' proposal to require hospitals to write off Medicare beneficiary accounts for patients that meet a hospital's financial assistance policy to bad debt, rather than charity care. Specifically, insured patients' coinsurance and deductibles written off as charity are fully included in the UCC calculation. By requiring the hospitals to write off these accounts with a bad debt trans code, the UCC calculation is reduced by multiplying these amounts by the hospital's cost-to-charge ratio (CCR). This policy change will impact UCC payments for many hospitals, which we believe is inconsistent with general accounting practices. The CMS should not mandate hospitals' accounting practices when determining Medicare payments.

Bad Debt Clarification - Insured Bad Debt

The CMS should clarify the instructions on line 29 regarding non-Medicare bad debt for insured patients. The CMS should allow hospitals to include coinsurance and deductibles on worksheet S-10 without multiplying these amounts by the hospital's CCR. The CMS' revised cost report instructions and guidance state that hospitals do not have to multiply non-reimbursed Medicare bad debt by the CCR, because coinsurance and deductibles are actual amounts expected from the patient (as opposed to charges, which are not the actual amounts a patient is expected to pay). However, the CMS' September 2017 transmittal states that hospitals should multiply their non-Medicare bad debt by the CCR.

The treatment of non-reimbursed Medicare bad debt and non-Medicare bad debt is inconsistent, and the CMS provides no justification for the inconsistency. Coinsurance and deductible amounts for patients other than Medicare FFS patients, such as those with Medicare Advantage, are actual amounts the hospital expects the patients to pay. Hospitals, therefore, should list unpaid coinsurance and deductible amounts as bad debt in their entirety and the CMS should not reduce those amounts by the CCR. Making this change would be consistent with the way the CMS treats charity care amounts for insured patients.

The CMS has clarified that charity care amounts for insured patients--that is, coinsurance and deductible amounts that patients do not have the ability to pay--do not have to be reduced by the CCR. We request that the CMS clarify the instructions for bad debt expenses to treat all coinsurance and deductibles for non-Medicare bad debt the same--not multiplying them by the hospital CCR.

Bad Debt Clarification - Implicit Price Concessions

In 2014, the Financial Accounting Standards Board issued its Accounting Standards Codification Topic 606, which directs hospitals and other organizations to report their revenue in external financial statements in accordance with Generally Accepted Accounting Principles (GAAP). Specifically, Topic 606 characterizes most bad debts and uncollectible amounts as "implicit price concessions" rather than bad debt. The CMS proposes to modify regulation to incorporation this update, referring to bad debt as "bad debt, also known as "implicit price concessions".

The bad debt proposals included in this rule could result in eliminating implicit price concessions from bad debt reporting on worksheet S-10. Whether labeled as bad debt or implicit price concessions, the result is that both terms mean uncompensated costs. We are concerned that without clear reporting instructions from the CMS, implicit price concessions may no longer be reported on worksheet S-10, which will reduce a hospital's reported bad debt. Not including implicit price concessions as bad debt on worksheet S-10 would mean that some hospitals may report no bad debt, which would not accurately reflect the uncompensated care and bad debt they incur and would negatively impact a hospital's UCC. We urge the CMS to clearly state that implicit price concessions are to be included as bad debt on worksheet S-10 for calculating Factor 3 and the hospital's UCC payment.

Create an Appeals Process for Disallowed Uncompensated Care

The CMS should provide hospitals with a mechanism to appeal adjustments made to data reported on worksheet S-10. Currently, hospitals are only allowed to appeal adjustments that have a material settlement impact on the cost report. While the data used to calculate the UCC payment may have a material payment impact on hospitals, it is not a settlement item on the Medicare cost report. The MHA believes that the CMS should create a process by which disallowed UCC cost could be appealed to the Provider Reimbursement Review Board, consistent with other items on the Medicare cost report.

FULL RESTORATION OF ATRA DOCUMENTATION AND CODING OFFSET

The CMS implemented a 0.8% cut to the annual market-basket update in FYs 2014-2016 to recoup the effect of documentation and coding changes that it believed do not reflect real changes in patient acuity.

For FY 2017, the CMS increased this cut from 0.8 percentage points to 1.5 percentage points to achieve the $11 billion targeted by the American Taxpayer Relief Act (ATRA). In total, these cuts reduced hospital inpatient payments by 3.9%. The CMS mandated a positive 0.5% adjustment for each year from FY 2018 through FY 2023 to offset the previous recoupment. The 21st Century Cures Act subsequently reduced the FY 2018 "add-back" from 0.5% to 0.4588%. Cumulatively after all negative and positive adjustments, hospitals will have a permanent payment reduction of approximately 1%.

The MHA believes that the CMS should restore the full 3.9% that was withheld from hospitals. We recommend that the CMS use its authority and adjust hospital payment amounts to return the payments previously withheld from hospitals.

PAYMENT for CAR-T THERAPY SERVICES

The CMS proposes to create a new MS-DRG for Chimeric Antigen Receptor T-cell (CAR-T) therapy services. Based on information provided by the American Society for Transplantation and Cellular Therapy (ASTCT) and the American Society of Hematology (ASH), the MHA requests that the CMS maintain the new technology add-on payment (NTAP) for these services in FY 2021 to ensure that when a new MS-DRG is created it is based on the best data available. These organizations see cellular and gene therapies as a new branch of medicine that the current Medicare IPPS could never have anticipated. They recognize that CAR-T therapy is the first from this class requiring the CMS to balance protecting patient access to these costly lifesaving services with responsible stewardship of the Medicare trust fund. We urge the CMS to take time necessary to ensure the appropriate balance is struck in rate setting for CAR-T therapy rather than risk establishing a rate that stifles innovation of future cellular and gene therapy services.

It is vital that payments for these expensive lifesaving services cover the cost. Inadequate reimbursement would quickly stifle growth of this field, reduce treatments for a patient population that has few alternatives and create barriers for patient access since hospitals and other institutions throughout the country cannot invest in setting up treatment programs without adequate reimbursement. Poor reimbursement will also discourage pushing discoveries for new treatments including the role of pharmaceutical companies in research and development in these areas of cancer where we still do not have a cure.

The MHA respectfully requests that the CMS maintain the NTAP for the FDA-approved CAR-T products for FY 2021 and delay creating a new MS-DRG until adequate data is available in future years. We believe this is the only policy that will maintain patient access to this therapy in the short term while allowing the CMS to carefully consider how to develop an equitable MS-DRG for CAR-T that will set a precedent for future cellular therapies.

INCREASING THE NUMBER OF QUARTERS OF ELECTRONIC CLINICAL QUALITY MEASURE DATA

The CMS proposes to retain the current inpatient quality reporting (IQR) program measure set but proposes significant changes to the measure validation process used for certain measures. For electronic clinical quality measure (eCQM) reporting, the CMS proposes to retain its current requirement that hospitals report data on four self-selected eCQMs using the 2015 Edition of certified EHR technology. For calendar years (CYs) 2020 and 2021 reporting period (tied to FYs 2022 and 2023 payment), hospitals can choose any four eCQMs in the IQR program. Beginning with the CY 2022 reporting period, hospitals must report the Safe Use of Opioids eCQM, along with any three other eCQMs in the IQR program. However, the CMS proposes two key changes:

Number of Quarters of Data. Currently hospitals must submit one self-selected quarter of data for the four eCQMs that it reports. The CMS proposes to increase the number of quarters for which hospitals are required to report eCQM data by requiring hospitals to report two self-selected quarters for the CY 2021 reporting period which would impact FY 2023 payment, three self-selected quarters for CY 2022 (FY 2024 payment) and four quarters for CY 2023 (FY 2025 payment). The data submission deadline which is generally two months after the end of the reporting period would remain unchanged. The requirement that hospitals must use EHR technology certified to the 2015 Edition and that EHRs be certified to all available eCQMs would also continue.

Public Reporting of eCQM Data - The CMS proposes to begin publicly reporting eCQM measure results on Hospital Compare in late 2022, starting with CY 2021 data. The CMS suggests that the increased number of quarters of data required in CY 2021 would make publicly-released data more comprehensive and reliable since a single quarter is not adequate for capturing trends in performance over time.

Hospitals have indicated that it is unclear how the data must be submitted and whether they will be required to submit numerator and denominator data for the numbers. If this is the case, they will not have a problem with data submission. However, hospitals have expressed concern that if they are required to submit combined files this would be a major issue for any hospital that converts to a different electronic health record (EHR) system.

For example: patient John Doe comes to the hospital in January when the hospital is using EHR System A and returns to the hospital in April after the hospital has moved to EHR System B. In this scenario, can the hospital combine the numbers from EHR Systems A and B which would inflate the number of patients since it would count patient John Doe twice? If this approach is acceptable to the CMS, hospitals would not see this as an issue. However, if hospitals are required to combine them and submit a combined report, it becomes very expensive for hospitals and the software expense far exceeds than the penalty the hospital would receive. In the current environment which requires hospitals to report data for one self-selected quarter or even the proposed two quarters for 2021, hospitals could select either EHR System A or B but once they're required to report for three or four quarters, they would not be able to select a single EHR. We request that the CMS provide clarification in the final rule and grant reporting flexibility for the year when hospitals change EHR systems.

HYBRID HOSPITAL-WIDE ALL CONDITION READMISSION MEASURE REPORTING

Against industry recommendations, in the FY 2020 IPPS final rule, the CMS adopted its proposal to require hospitals to report the hybrid hospital-wide readmission measure starting with the FY 2026 IQR program. The hybrid readmission measure combines Medicare FFS claims data with certain data hospitals must report from EHRs to calculate performance. The measure was adopted for voluntary reporting in the FY 2018 IPPS final rule. The CMS will simultaneously remove the existing claims-only version of the measure from the FY 2026 IQR program. In this rule, the CMS proposes that future hybrid measures would use the same reporting requirements as the hybrid hospital-wide readmission measure. That is, hospitals must use the 2015 edition of certified EHR technology and submit data using the quality reporting document architecture currently used for eCQMs.

The CMS proposes to require the Hybrid Hospital-Wide Readmission Measure beginning with FY 2026 payment determination which is solely dependent upon the hospital's EHR vendor. Although this measure was voluntary for two years prior to the required FY 2026 reporting, some EHR vendors have not yet begun measure mapping to prepare for hospital data submission. In the current state, hospitals are unable to volunteer to submit data nor validate and improve upon current measure performance. Any changes to workflow and EHR documentation to improve documentation and capturing of the data points will also be dependent upon the readiness and commitment of the EHR vendor to support the type of material change imposed by this requirement. An EHR vendor's readiness can impede hospital progress toward achieving data submission and its impact should not be underestimated. There remain far too many unanswered questions about the accuracy and validity of the measure, and the ability of the CMS' QualityNet website to accept measure data. The MHA encourages the CMS to further delay adopting this measure until EHR vendors are compelled and certified to prepare for data submission and allow hospitals the opportunity to review and improve upon documentation to meet the measure requirements. Instead we urge the CMS to retain this measure for voluntary reporting, allowing the experience of the industry to inform any requirement to report the measure in the future.

TIMING FOR RELEASE OF QUALITY-PROGRAM FACTORS

Historically, the CMS has finalized factors for the value-based purchasing, readmissions reduction and hospital-acquired conditions reduction programs several months after the beginning of the fiscal year, which has meant that hospitals do not know their actual payment adjustment for these programs until several months into the new fiscal year. For the FY 2020 programs, the CMS did not release final factors until February. This delay is problematic for hospitals since these factors impact Medicare payments back to Oct. 1. Hospitals are subject to CMS deadlines for data submission related to the quality-based programs. If the deadlines are too close to the beginning of the fiscal, we recommend that the CMS revise these deadlines or the timeframes for the quality program data elements to ensure the final factors can be released prior to Oct. 1. Late release of this data by the CMS creates unnecessary administrative burden for the MACs and hospitals related to the reprocessing of claims. In addition, hospitals are left in limbo, not knowing their final Medicare payment rate until months after the start of the federal fiscal year. This is further compounded by the Medicare Advantage plans using those factors. The MHA recommends that the CMS release final program factors before Oct. 1, prior to the beginning of the fiscal year consistent with our comments on the FY 2020 IPPS proposed rule.

SUMMARY

The MHA appreciates this opportunity to provide comments to the CMS regarding this proposed inpatient rule. If you have questions regarding this comment letter, please contact Vickie Kunz at (517) 703-8608 or [email protected].

Sincerely,

Vickie R. Kunz

Senior Director, Health Finance

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The proposed rule can be viewed at: https://www.regulations.gov/document?D=CMS-2020-0052-0002

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