Advocacy Correspondence: CMS Comment Letter, Long-Term Care Hospital Prospective Payment System and Policy Changes and Fiscal Year 2025

 

June 10, 2024

The Honorable Chiquita Brooks-LaSure
Administrator
Centers for Medicare & Medicaid Services
Attention: CMS-1808-P
P.O. Box 8013
Baltimore, MD 21244-8013

Submitted Electronically

Re: Medicare and Medicaid Programs and the Children's Health Insurance Program; Hospital Inpatient Prospective Payment Systems for Acute Care Hospitals and the Long-Term Care Hospital Prospective Payment System and Policy Changes and Fiscal Year 2025 Rates; Quality Programs Requirements; and Other Policy Changes; 89 Fed. Reg. 35,934 (May 2, 2024).

Dear Administrator Brooks-LaSure:

On behalf of our more than 230 Pennsylvania member hospitals and health systems, including long-term care hospitals (LTCH), The Hospital and Healthsystem Association of Pennsylvania (HAP) appreciates the opportunity to comment on the Centers for Medicare & Medicaid Services’ (CMS) fiscal year (FY) 2025 LTCH prospective payment system (PPS) proposed rule.

HAP, along with the American Hospital Association (AHA), has serious concerns about this year’s proposed payment updates for LTCHs. First, we would note that market basket updates have lagged real inflation for numerous consecutive years. In addition, the sharp rise in the fixed-loss amount (FLA) for outlier payments has forced LTCHs to absorb hundreds of millions in losses for treating high-acuity patients. The combination of these factors, and the difficult inflationary environment facing hospitals, is seriously jeopardizing access for severely ill patients. HAP strongly urges CMS to take action to address these issues by adopting specific recommendations detailed in this letter.

 

Download HAP's full Comment Letter below.

 

Download

Topics: Access to Care, Federal Advocacy, Medicaid, Medicare

Revision Date: 6/10/2024

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