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  • Proposed CMS Hospital Payment Rule Includes Payment Increases, Reductions in Reporting and EHR Requirements

    In its proposed rule for hospital payment in 2019, the US Centers for Medicare and Medicaid Services (CMS) is continuing its shift toward fewer reporting requirements and reduced burdens associated with electronic health records (EHRs), while recommending payment increases that could mean a 3.4% boost for some acute care hospitals (ACHs).

    The inpatient prospective payment system (IPPS) proposed rule released last week (CMS fact sheet here) covers a range of areas related to how ACHs and long-term care hospitals (LTCHs) would operate in relation to Medicare and Medicaid beneficiaries. Here are a few highlights of the proposed rule:

    • ACHs could see a $4 billion payment increase. That's the CMS estimate of what the proposed 3.4% increase could mean (last year's final rule included a $2.4 billion increase). The increase will apply only to hospitals that successfully participate in the CMS Hospital Inpatient Quality Reporting Program.
    • Technically, LTCHs also would see a payment increase…but, practically speaking, probably not. The rule proposes a 1.5% increase for LTCHs, but other provisions in the proposed rule offset the increase, leaving LTCHs to face a 0.1% decrease in 2019. In 2018 LTCH payment was reduced by 2.4%.The proposed rule also would end a policy that pays LTCHs at a rate comparable to an ACH if an LTCH admits more than 25% of its patients from a single ACH. That program was suspended in 2018—the proposed rule would make the change permanent.
    • CMS continues to back off on quality-measure reporting requirements. For hospitals involved in Medicare and Medicaid EHR incentive programs, the proposed rule would eliminate 40 quality-reporting measures CMS has identified as duplicative, excessively burdensome, or "topped out"—measures on which the "overwhelming majority of providers" are performing highly. Measures proposed to be eliminated include stroke education and assessment for rehabilitation, both of which CMS describes as measures whose costs outweigh the benefits of continued use.
    • EHR incentive programs are getting retooled. Incentive programs related to EHR use would receive what CMS is calling an "overhaul" in 2019. The aim of the rule, according to CMS, is to increase interoperability and decrease burdens on hospitals and providers. Changes include shortened reporting periods for 1 self-selected quarter and fewer required measures to be reported. CMS also hopes to change the name of the program from "Meaningful Use " to "Promoting Interoperability" and add 2 new measures: Query of the [Prescription Drug Monitoring Program] and Verify Opioid Treatment Agreement.
    • CMS is asking for public input on price transparency. Specifically, CMS wants to hear from the public about "barriers preventing providers from informing patients of their out-of-pocket costs." To underscore its intention to increase price transparency, CMS also proposes upping the ante when it comes to hospitals sharing lists of standard charges: in addition to requiring hospitals to "make public a list of their standard charges," (something they already do), CMS wants to mandate that those charges be made available on the Internet.

    The proposed rule also includes information on how the Rural Community Hospital Demonstration has been carried out. That project, designed to evaluate the possibility of applying cost-based reimbursement for rural hospitals that are too large to be crucial-access hospitals, must remain budget neutral.

    APTA regulatory affairs staff are reviewing the rule and will draft comments for submission to CMS before the deadline of June 25, 2018.

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