Comment Letter

With weeks remaining in the open enrollment period it appears highly unlikely that the CBO's May 2013 estimate of a reduction in the uninsured by 14 million individuals in 2014 will be achieved. 

Read HFMA's comments to Centers for Medicare & Medicaid Services regarding its FY2014 proposed rule for Hospital Inpatient Prospective Payment Systems.

HFMA believes a workable approach is to delay enforcement of the two-midnight rule until October 1, 2014. During this delay, CMS will work with stakeholders to develop alternate policy solutions.

HFMA urges support for the Stark Administrative Simplification Act (H.R. 3776) introduced by Rep. Charles Boustany, MD, and Rep. Ron Kind.

HFMA urges CMS to undertake a comprehensive approach to testing the readiness of the Medicare contractors and state Medicaid agencies for the October 1, 2014, ICD-10 implementation.

HFMA addresses the Centers for Medicare & Medicaid Services (CMS) in a proactive comment on issues related to the Medicare Recovery Audit Contractor (RAC) program.

HFMA prepared a comment letter on key issues contained in CMS's 2014 Hospital Outpatient Prospective Payment Systems for Acute Care Hospitals.

HFMA is concerned with aspects of the RAC program that violate many of HFMA’s principles of a reformed payment system. Comments focused on rebilling for medically necessary services and the timeframe.

Read HFMA's comments to the chairs of the House of Representatives' Ways and Means and Energy and Commerce Committees and their respective Health Subcommittees on their drafted framework for legislation to replace the SGR.

HFMA comments to CMS on its efforts to simplify requirements for physician quality reporting. HFMA supports efforts to better align CMS policy with HFMA's core payment reform principles.