HAP Resource Center

Advocacy Correspondence: HAP Comment Letter, CMS-1808-P

June 10, 2024

The Honorable Chiquita Brooks-LaSure
Centers for Medicare & Medicaid Services
Hubert H. Humphrey Building
200 Independence Avenue, SW, Room 445-G
Washington, DC 20201

RE: CMS-1808-P, 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, (Vol. 89, No. 86), May 2, 2024.

Dear Administrator Brooks-LaSure:

On behalf of The Hospital and Healthsystem Association of Pennsylvania (HAP), representing more than 230 hospitals and health systems statewide, we appreciate the opportunity to comment on the Centers for Medicare & Medicaid Services’ (CMS) hospital inpatient prospective payment system proposed rule for fiscal year (FY) 2025.

For FY 2025, CMS proposes a market basket increase of a net update of 2.6 percent. This is simply not enough. HAP has grave concerns about this inadequate update, especially when taken together with the underwhelming market basket increases from FY 2022, 2023, and 2024. It does not capture either the unprecedented inflationary environment or the other persistent financial headwinds hospitals and health systems are experiencing. It also fails to account for the fact that labor composition and costs have remained extraordinarily high and that, as a result, the hospital field continues to face sustained financial pressures and workforce shortages. Given all the above, HAP strongly urges CMS to find ways to account for these increased costs to ensure that beneficiaries continue to have access to quality inpatient care.

In addition, we incorporate, by reference, all of the comments provided in the AHA’s response to the proposed rule.

Thank you for your consideration of HAP’s comments about this proposed rule regarding inpatient payment and other provisions related to hospitals and the patients they serve in Pennsylvania.

If you have any questions, contact Brooke Bowers, HAP’s director, financial reimbursement and analysis.


Jolene H. Calla, Esq.
Vice President, Finance and Legal Affairs



Topics: Federal Advocacy, Medicare

Revision Date: 6/10/2024

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