HAP Comment Letter to CMS on FFY 2016 Hospital IPPS Proposed Rule
June 16, 2015
Centers for Medicare & Medicaid Services
U.S. Department of Health and Human Services
Hubert H. Humphrey Building
200 Independence Avenue, S.W., Room 445-G
Washington, DC 20201
SUBJECT: CMS-1632-P. Medicare Program; Hospital Inpatient Prospective Payment System for Acute Care Hospitals and the Long-Term Care Hospital Prospective Payment System Policy Changes and Fiscal Year 2016 Rates; Revisions of Quality Reporting Requirements for Specific Providers, Including Changes Related to the Electronic Health Records Incentive Program; Proposed Rule, April 30, 2015
Dear Acting Administrator Slavitt:
On behalf of The Hospital & 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) 2016.
HAP supports many of the payment and policy proposals contained within the proposed rule and looks forward to working with CMS to continue to promote payment accuracy and drive quality improvement.
Key areas of concern include mandatory reporting of electronic clinical quality measures for FFY 2018 Inpatient Quality Reporting program requirements, ongoing issues surrounding the two-midnight policy, and the modification of pneumonia-related claims-based measures.
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 Jamie Buchenauer, vice president, regulatory advocacy, at (717) 561-5308 or Laura Stevens Kent, vice president, federal advocacy, at (202) 863-9287.
President and Chief Executive Officer