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Comment Letter to CMS on Hospital Outpatient Prospective Payment System (OPPS) Proposed Rule for Calendar Year (CY) 2013
Regulatory Advocacy
Last Updated: 8/30/2012
August 30, 2012 Marilyn Tavenner
Acting Administrator
Centers for Medicare & Medicaid Services
Department of Health and Human Services
Attention: CMS-1589-P
P.O. Box 8013
Baltimore, MD 21244-1850
RE: CMS–1589–P, Hospital Outpatient Prospective and Ambulatory Surgical Center Payment Systems and Quality Reporting Programs; Electronic Reporting Pilot; Inpatient Rehabilitation Facilities Quality Reporting Program; Quality Improvement Organization Regulations; (Vol. 77, No.146), July 30, 2012.
Dear Ms. Tavenner: On behalf of The Hospital & Healthsystem Association of Pennsylvania (HAP), which represents approximately 250 member institutions, including 125 stand-alone hospitals and another 120 hospitals that comprise 32 health systems across the Commonwealth of Pennsylvania, HAP appreciates the opportunity to comment about the Centers for Medicare & Medicaid Services’ (CMS) hospital outpatient prospective payment system (OPPS) proposed rule for calendar year (CY) 2013. While HAP supports a number of the proposed rule’s provisions, we have serious concerns about the independent rehabilitation facilities (IRF) quality provisions, independent review process for reassessing the appropriate level of supervision, the proposal to remove the code for total knee arthroplasty from the inpatient list, and the pilot program to field test the measures used in the electronic health record (EHR) incentive program. We also are commenting about the geometric mean-based payment weights, a new payment policy for separately payable outpatient drugs, coding and payment for critical care services, a new transitional care management code, a payment adjustment for radioisotopes derived from non-highly enriched uranium sources, requirements for outpatient quality data reporting, changes to the Quality Improvement Organization (QIO) regulations, and quality reporting through an EHR. Additionally, HAP is pleased that CMS has engaged stakeholders in a discussion of the complexities that surround determinations of whether a patient is appropriately an inpatient or outpatient and is seeking ways to improve its instructions and policies regarding patient status. Because proper consideration of these issues will require more time and effort than a 60-day comment period will allow, we encourage CMS to consider this the first of several important discussions of a more formal ongoing dialogue with hospitals, physicians, beneficiaries, skilled nursing facilities (SNF), and other stakeholders. Attached are more detailed comments for your consideration. Again, HAP appreciates the opportunity to submit these comments and recommendations about this important proposed rule on behalf of Pennsylvania hospitals and health systems. If you have questions about HAP’s comments, please contact Michael Lane, director, health care finance policy, at (717) 561-5317; or Lynn Leighton, vice president, health services, at (717) 561-5308. Sincerely, CAROLYN F. SCANLAN
President and Chief Executive Officer
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