Hospital Association of Pennsylvania > Advocacy > Federal Advocacy > IPPS Proposed Rule FFY 2017 Comment Letter


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HAP Comment Letter to CMS About IPPS Proposed Rule for FFY 2017

June 17, 2016

Andy Slavitt
Acting Administrator
Centers for Medicare & Medicaid Services
U.S. Department of Health and Human Services
Hubert H. Humphrey Building
200 Independence Avenue, S.W., Room 445-G
Washington, DC 20201

SUBJECT: CMS-1655-P. Medicare Program; Hospital Inpatient Prospective Payment Systems for Acute Care Hospitals and the Long Term Care Hospital Prospective Payment System and Proposed Policy Changes and Fiscal Year 2017 Rates; Quality Reporting Requirements for Specific Providers; Graduate Medical Education; Hospital Notification Procedures Applicable to Beneficiaries Receiving Observation Services; and Technical Changes Relating to Costs to Organizations and Medicare Cost Reports; Proposed Rule, April 18, 2016

Dear Acting Administrator Slavitt:

On behalf of The Hospital & Healthsystem Association of Pennsylvania (HAP), which represents approximately 240 member institutions, we appreciate the opportunity to comment about the Centers for Medicare & Medicaid Services’ (CMS) hospital inpatient prospective payment system proposed rule for federal fiscal year 2017.

HAP supports many of the payment and policy proposals contained within the proposed rule and looks forward to working with CMS to continue to promote payment accuracy and drive quality improvement.

Key areas included in the attached comments are:

  • Two-midnight policy payment adjustment
  • Medicare Disproportionate Share Hospital Payment Reductions
  • Documentation and Coding Adjustment
  • Notification Procedures for Outpatients Receiving Observation Services
  • Inpatient Quality Reporting Program
  • Hospital Readmissions Reduction Program
  • Inpatient Psychiatric Facility Quality Reporting Program

Thank you for your consideration of HAP’s comments regarding this proposed rule. If you have any questions, contact Kate Slatt, senior director, health care finance policy, at (717) 561-5317.


Jeffrey Bechtel
Senior Vice President, Health Economics and Policy


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