Advocacy Correspondence: Comment Letter, CMS, 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 2021 Rates

July 10, 2020

Seema Verma Administrator
Centers for Medicare & Medicaid Services
U.S. Department of Health and Human Services Hubert H. Humphrey Building
200 Independence Avenue, S.W. Washington, DC 20201

SUBJECT: CMS-1735-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 2021 Rates; Quality Reporting and Medicare and Medicaid Promoting Interoperability Programs Requirements for Eligible Hospitals and Critical Access Hospitals; Proposed Rule, May 29 , 2020

Dear Administrator Verma:

On behalf of The Hospital and 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 (FFY) 2021.

This year’s proposed rule comes during a time in a state of uncertainty unlike we have seen before. While we are pleased to see CMS continue its efforts to reduce the administrative burdens often associated with its quality programs, HAP remains very disappointed that CMS continues down the unlawful path of requiring hospitals to disclose privately negotiated contract terms.

The following comments provide areas of emphasis. HAP otherwise incorporates by reference all comprehensive comments by the American Hospital Association.

Thank you for your consideration of HAP’s following comments regarding this proposed rule. If you have any questions, contact Kate Slatt, vice president, innovative payment and care delivery, at (717) 561-5317.

Sincerely,

 

Jeffrey Bechtel
Senior Vice President, Health Economics and Policy

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Topics: Federal Advocacy

Revision Date: 7/10/2020

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