HAP Comment Letter to CMS About Request for information on Concepts for Regional Multi-Payer Prospective Budgets
May 13, 2016
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: Request for information on Concepts for Regional Multi-Payer Prospective Budgets
Dear Mr. Slavitt:
On behalf of The Hospital & Healthsystem Association of Pennsylvania (HAP), which represents approximately 240 member institutions, we appreciate the opportunity to provide comments regarding the Request for Information on concepts for regional multi-payer prospective budgets. This promising program model could serve to support better management of cost and quality for a community’s population by providing clear revenue expectations and connecting care across outpatient and inpatient services.
This topic is especially timely in Pennsylvania, as the Commonwealth, under the leadership of Secretary of Health Dr. Karen Murphy, is proposing to develop and implement a multi-payer global budget initiative in rural Pennsylvania. HAP member hospitals are interested in exploring the state’s proposal, as well as providing guidance to the Centers for Medicare & Medicaid Services (CMS) as these program designs move forward.
As CMS explores these models, it is important to note that Pennsylvania hospitalslike many rural hospitals across the nationare struggling financially. Thirty-four percent of rural Pennsylvania hospitals are currently operating with negative total margins and many more have dangerously narrow margins. Any changes to the reimbursement system must take into account the tenuous nature of these providers’ operating models to protect access to health care in rural parts of the state.
HAP commends CMS for requesting input into the design and implementation of a multi-payer prospective budget approach. The attached document provides comments for CMS to consider while developing the details of these programs.
Thank you for your consideration of HAP’s comments. If you have any questions, please contact me at (717) 561-5325, or Kate Slatt, senior director, health care finance policy, at (717) 561-5317.
Jeffrey W. Bechtel, JD
Senior Vice President, Health Economics and Policy