June 27—HFMA issued a comment letter to the Centers for Medicare & Medicaid Services (CMS) in response to the FY14 Inpatient Prospective Payment System (IPPS) Proposed Rule, which addresses a wide variety of issues related to Medicare hospital reimbursement. 

One area the letter speaks to is Medicare disproportionate share hospitals (DSH) payment. HFMA is concerned about the potential for CMS to underestimate DSH payments, which would ultimately result in an underfunded pool of uncompensated care payments for distribution to providers. 

In the letter, HFMA strongly recommends that CMS annually reconcile estimated DSH payments to actual DSH payments. HFMA further suggests that any necessary adjustments be made to the uncompensated pool in the next available federal fiscal year. 

Another area on which the letter focuses is hospital readmissions. HFMA strongly recommends that CMS conduct a thorough analysis of the role that economic factors play in Medicare readmissions. HFMA believes the analysis should be conducted at the claims level for readmitted Medicare patients, matching their zip codes to existing poverty data. The thought is that this would provide an accurate understanding of the role that economic conditions, which are beyond a hospital’s control, play in hospital readmissions.

Further programs and policies covered in the letter include:  

  • Implementation of the Hospital-Acquired Conditions Reduction Program for FY15
  • Hospital Value-Based Purchasing Program  
  • Hospital Inpatient Quality Reporting Program  
  • Policy on Admission and Medical Review Criteria for Hospital Inpatient Services under Medicare Part A and Related Cost Offset Adjustments

Publication Date: Thursday, June 27, 2013