NCHA submits comment letter addressing IPPS proposed rule for FY 2019

On April 24, 2018, the Centers for Medicare & Medicaid Services (CMS) issued its hospital inpatient prospective payment system (IPPS) proposed rule for fiscal year 2019. The proposed rule affects inpatient PPS hospitals, critical access hospitals (CAHs), long-term care hospitals (LTCHs) and PPS-exempt cancer hospitals. Major provisions of the proposed rule related to inpatient PPS, CAHs, and PPS-exempt cancer hospitals include operating payment rate updates, public reporting of standard changes, documentation and coding adjustments, disproportionate share hospital (DSH) payment adjustments and uncompensated care payment, and changes to the hospital-acquired Conditions (HAC) Reduction Program, Hospital Readmissions Reduction Program (HRRP), Hospital Value-Based Purchasing Program, Inpatient Quality Reporting Program and Electronic Health Records Incentive Program (Promoting Interoperability). NCHA prepared the attached comment letter that was submitted on Monday, June 25, 2018.  We focused our comments on transparency, reducing regulatory barriers, the nationwide rural floor budget neutrality adjustment, and the transition to Worksheet S-10 for determining the amount of uncompensated care provided by hospitals.

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