HAP Resource Center

Advocacy Correspondence: HAP Comment Letter to CMS, Medicare Hospital IPPS Proposed Rule FFY 2022

June 28, 2021

Chiquita Brooks-LaSure Administrator
Centers for Medicare & Medicaid Services
U.S. Department of Health and Human Services
P.O. Box 8013
Baltimore, MD 21244-1850

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 (FY) 2022 Rates; Quality Programs and Medicare Promoting Interoperability Program Requirements for Eligible Hospitals and Critical Access Hospitals; Proposed Changes to Medicaid Provider Enrollment; and Proposed Changes to the Medicare Shared Savings Program; Proposed Rule, May 10, 2021

Dear Administrator Brooks-LaSure:

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) 2022.

HAP recognizes many places where CMS has taken the COVID-19 public health emergency (PHE) into account in the formation and calibration of policy. The Pennsylvania hospital community has appreciated CMS’ flexibility and stands ready to support CMS in using the learnings of COVID-19 to achieve shared goals.

HAP supports CMS’ retraction of the problematic requirement for hospitals to report median payor- specific negotiated charges by MS-DRG and the use of FY 2019 data in rate-setting. At the same time, we have significant concerns about the proposals for dramatic changes to the long-standing organ procurement payment and reporting systems and its potential negative impact on this critical lifesaving service. We also urge CMS to modify its proposals in distributing residency slots as part of the graduate medical education program.

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.


Jeffrey W. Bechtel
Senior Vice President, Health Economics and Policy




Topics: Federal Advocacy

Revision Date: 6/28/2021

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