CMS Releases Inpatient Payment Proposed Rule
On April 24, 2018, the Centers for Medicare & Medicaid Services (CMS) issued a proposed rule that makes updates to Medicare payment policies and rates under the Inpatient Prospective Payment System (IPPS) and the Long-Term Care Hospital (LTCH) Prospective Payment System (PPS). According to CMS, these changes and other policy proposals will “empower patients through better access to hospital price information, improve the use of electronic health records, and make it easier for providers to spend time with their patients.”
In addition to payment rates and quality measure changes, CMS is requesting comments on a proposal to require hospitals to publish online a list of their standard charges and to update the information at least once a year. CMS is also overhauling the Medicare and Medicaid EHR Incentive Programs, including proposing to change the name of the meaningful use program to “Promoting Interoperability.” The rule would keep in place the program’s 90-day reporting period, which CMS shortened last year, and requires all eligible hospitals and Critical Access Hospitals (CAHs) to use the 2015 Edition of CHERT.
Additionally, CMS is asking for responses to a request for information on interoperability, or the sharing of healthcare information between providers. Specifically, CMS is requesting stakeholder feedback through a Request for Information on the possibility of revising Conditions of Participation related to interoperability as a way to increase electronic sharing of data by hospitals. According to CMS, this will inform next steps to advance this critical initiative. The agency is also asking for responses to a request for information related to price transparency, “including patients being surprised by out-of-network bills for physicians, such as anesthesiologists and radiologists, who provide services at in-network hospitals, and patients being surprised by facility fees and physician fees for emergency room visits.”
“We are seeking information from the public regarding barriers preventing providers from informing patients of their out of pocket costs; what changes are needed to support greater transparency around patient obligations for their out of pocket costs; what can be done to better inform patients of these obligations; and what role providers should play in this initiative,” the agency stated. “CMS is also considering making information regarding hospital non-compliance with the requirements public and also intends to consider additional enforcement mechanisms in future rulemaking.”
AAOS has urged CMS to address the regulatory burden and improve interoperability. Additionally, while AAOS supports the removal of burdensome and duplicative measures, we are reviewing the list of the proposed measures for removal so that orthopaedic surgeons can continue to participate in the quality reporting programs without additional barriers. Further, AAOS recently submitted a statement for the record to Congress that addressed price transparency.
“AAOS recognizes that the growth in healthcare costs represents a challenge for the long-term sustainability of the system overall and for the federal healthcare programs Congress and the agencies oversee,” the letter states. “AAOS welcomes any tool that would allow physicians to make better informed decisions about what care is most suitable and cost-effective for their patients. While all payer claims databases (APCDs) are one solution, obstacles remain to effectively implement these databases, including accurate identification of providers, and ensuring that an APCD’s pricing and quality data are always timely and complete. Nevertheless, AAOS believes that APCD data can be combined with other sources of clinical data (such as that contained within registries) to expedite movement toward value-based care assessment.”
AAOS will be submitting comments by the deadline of June 25, 2018. The proposed rule and the RFI (CMS-1694-P) can be downloaded from the Federal Register at: https://s3.amazonaws.com/public-inspection.federalregister.gov/2018-08705.pdf.