Hospital Association of Pennsylvania > Advocacy > Federal Advocacy > Comment Letter to House Comm on Hosp Improvements for Payment Act of 2014 Discussion Draft


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HAP Comments to U.S. House Committee on Ways and Means, Subcommittee on Health

January 21, 2015

The Honorable Kevin Brady
U.S. House Committee on Ways and Means, Subcommittee on Health
1135 Longworth House Office Building
Washington, DC 20515

Re: Hospital Improvements for Payment Act of 2014 Discussion Draft

Dear Chairman Brady:

On behalf of The Hospital & Healthsystem Association of Pennsylvania (HAP), which represents nearly 240 member institutions, including 68 stand-alone hospitals and another 138 hospitals that are part of 29 health systems across the state, we appreciate the opportunity to provide feedback about the Hospital Improvements for Payment Act of 2014 discussion draft.

We recognize the earnest work by the Committee to seek to address many issues of importance to hospitals and the Medicare program through the policies outlined in this discussion draft. The Pennsylvania hospital community looks forward to working with you to advance elements of the discussion draft that we strongly support and address significant concerns raised by certain policies contemplated in the proposal.

Specifically, HAP is supportive of particular elements of the proposal pertaining to:

  • The two-midnight policy and short-stay payment
  • Provisions that provide relief for critical access hospitals and small rural hospitals
  • Policy to apply an adjustment for socio-demographic factors in the Hospital Readmissions Reduction Program

HAP is concerned regarding the complexity of the short-stay payment solution. We object to any reduction in hospital payments to pay for any of the provisions in the discussion draft, and urge continued support for payments that reflect unique services provided by hospitals in serving their communities. Finally, we believe more robust and fundamental reforms are necessary to address the Recovery Audit Contractor program. 

In reviewing the discussion draft, the following principles guided our consideration:

  • Ensure adequate payments that reflect the intensity and resources of care provided
  • Provide stability and certainty to provide a foundation that allows hospitals to make investments in delivery system transformation while maintaining the delivery of high-quality care today
  • Reduce administrative burdens that divert time and resources from the focus on patient care

HAP appreciates the Committee’s recognition of the problems inherent in the two-midnight inpatient admissions and medical review criteria policy, and the work you engaged in during the 113th Congress on Congressman Jim Gerlach’s legislation—H.R. 3698, the Two-Midnight Rule Delay Act of 2013. We look forward to working with you during the 114th Congress. 

Thank you for consideration of HAP’s comments about the discussion draft, and the impact on hospitals and health systems and the patients they serve in Pennsylvania. If you have any questions, please feel free to contact me or Laura Stevens Kent, vice president, federal advocacy, at (202) 863-9287.


Andy Carter
President and Chief Executive Officer


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