NCHA Submits Comment Letter Addressing IPPS Proposed Rule for Fiscal Year 2020

The Centers for Medicare & Medicaid Services issued its Hospital Inpatient Prospective Payment System (IPPS) proposed rule for fiscal year 2020 in April 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, documentation and coding adjustments, disproportionate share hospital payment adjustments and uncompensated care payment, and changes to the Hospital-Acquired Conditions Reduction Program, Hospital Readmissions Reduction Program, 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 24, 2019. We focused our comments on calculation of the new technology add-on payment, wage index disparities, rural floor, transition to S-10, changes to Hospital Payment Reductions for excessive readmissions, and promoting interoperability programs.

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