Comment Letter

HFMA Comments on CMS’ FY2016 Hospital OPPS Proposed Rule

HFMA highlights concerns and provides recommendations on key payment policy issues in the FY16 Medicare outpatient PPS proposed rule.

HFMA September 2, 2015

HFMA Comments on the FASB’s Proposal on NFP Financial Statement Presentation

HFMA comments on the FASB’s proposed Accounting Standards Update Not-for-Profit Entities (Topic 958) & Health Care Entities (Topic 954): Presentation of Financial Statements of Not-for-Profit Entities.

HFMA August 18, 2015

HFMA Comment Letter: CMS’ FY2016 Hospital IPPS Proposed Rule

HFMA comments on the CMS analysis and discussion of the myriad Medicare hospital reimbursement decisions addressed in the 2016 IPPS Proposed Rule.

HFMA July 1, 2015

HFMA comments on the Senate Finance Committee Chairmen’s Audit & Appeal Bill

HFMA comments on the Senate Finance Committee Chairman's Mark of the AFFRIM Act to put forth solutions to the challenges faced by hospitals and beneficiaries from overlapping recovery audit programs.  

HFMA June 22, 2015

HFMA Comments on CMS Bundled Payments for Care Improvement (BPCI) Initiative

HFMA proactively comments on issues related to CMS’s BPCI initiative to provide recommendations to address design issues with the episodes and other operational and administrative barriers.

HFMA May 22, 2015

HFMA Comments on Medicare Short Stay Payment Policy

HFMA comments on issues related to Medicare’s current payment policy for short stays, the Recovery Audit Contractor (RAC) program, and the impact of both on Medicare beneficiaries.

HFMA April 20, 2015

HFMA Comments on Transition to HIPAA Eligibility Transaction System

HFMA is concerned that a 12-month limitation will not allow providers the time to research facts and, if mistakes are discovered, reopen claims with Medicare under CMS' reopening regulations.

HFMA March 20, 2015

HFMA Comments on Hospital Improvements for Payment Act of 2014 Discussion Draft

HFMA comments to the U.S. House Committee on Ways and Means on the challenges of the Medicare Recovery Audit Contractor program and other policies that have had negative unintended consequences.

HFMA March 11, 2015

HFMA Comments on the Proposed Rule on the Medicare Shared Savings Program

HFMA commended CMS for its efforts to modify the Medicare Shared Savings Program (MSSP) to ensure its sustainability. However, HFMA had specific recommendations for improvement.

HFMA February 11, 2015

HFMA comments to CMS on the 2015 Medicare OPPS Proposed Rule

HFMA comments the 2015 Medicare and Medicaid Programs: Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems and Quality Reporting Programs; Physician-Owned Hospitals: Data Sources for Expansion Exception; Physician Certification of Inpatient Hospital Services; Medicare Advantage Organizations and Part D Sponsors: Appeals Process for Overpayments Associated With Submitted Data; Proposed Rule (hereafter referred to as the 2015 OPPS Proposed Rule) published in the July 14, 2014, Federal Register. 

HFMA September 5, 2014
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