KHA Submits Comments to CMS

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Yesterday, KHA submitted two comment letters to the Centers for Medicare and Medicaid Services (CMS). The first letter related to the CMS proposed rule for the hospital inpatient prospective payment system (PPS) for fiscal year 2025 and started by expressing KHA’s agreement with the AHA’s comments regarding the inadequacy of the proposed net payment update of 2.6% given the unrelenting financial challenges faced by hospitals and urged CMS to focus on appropriately accounting for recent and future trends in inflationary pressures and cost increases. KHA also shared support for the extended low-volume adjustment.

The letter continued with a request for CMS to address factors like the area wage index, clarity on the agency’s calculations for disproportionate share hospital (DSH) payments, regulatory flexibilities to help providers effectively act on social determinants of health and gaps in access to care for the populations they serve.

KHA’s submitted a separate letter to address the CMS proposed rule for Transforming Episode Accountability Model (TEAM) that was included in the inpatient PPS proposed rule. The proposed new mandatory TEAM payment model would bundle payment to acute care hospitals for five types of surgical episode categories: coronary artery bypass graft, lower extremity joint replacement, major bowel procedure, surgical hip/femur fracture treatment, and spinal fusion. It would make acute care hospitals responsible for the quality and cost of all services provided during select surgical episodes, from the date of inpatient admission or outpatient procedure through 30-days post-discharge. This includes services covered under both Medicare Part A and Part B, including physician, post-acute care, therapy, clinical laboratory, Part B drugs and biologicals, and other medical services and supports. It would run for five years and require participation for inpatient prospective payment system (PPS) hospitals in certain core-based statistical areas that would be selected at a later date.

KHA’s letter expressed deep concern regarding the proposed TEAM and specifically recommended CMS make TEAM voluntary, lower the 3% discount factor, and make several changes to the problematic design elements.

If you have any questions, please contact Donna Little at KHA (dlittle@kyha.com).

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