Premier Reacts to Final IPPS Rule

The Premier healthcare alliance is deeply disappointed in the way that CMS chose to change policy for how Medicare contractors review inpatient hospital admissions for payment purposes. While CMS’s quest for clarity is admirable, these new medical review and admissions criteria do not provide any protections from burdensome audits and appeals, and require providers to have a sixth sense and predict the future treatment needs for patients. Moreover, these changes add insult to injury, imposing an associated 0.2% payment reduction to offset what CMS believes will be an increase in inpatient volume. We expect that this will result in even more confusion around what constitutes an appropriate inpatient hospital admission, all while cutting payments for following CMS’ rules.

While we appreciate that CMS has made an effort to remove planned readmissions from the Hospital Readmissions Reduction Program, we are concerned about the addition of chronic obstructive pulmonary disease (COPD) in FY 2015. COPD is an environmentally sensitive condition that will result in more readmissions in certain areas as compared to others. Further, we are concerned that this addition will exacerbate the disproportionately negative effect on hospitals that serve low-income populations.

Moreover, just because overlapping hospital-acquired condition (HAC) measures included in both the HAC Reduction Policy and Value-Based Purchasing (VBP) programs have different scoring methodologies does not erase the facts CMS has tried to ignore: these programs are duplicative, with overlapping measures that penalize hospitals multiple times for the same HACs. For instance, under CMS’ new policies, a single blood stream infection could count in two VBP measures, two HAC reduction program measures and in the existing HAC policy. Penalizing providers five times for the same event is certainly not what Congress envisioned.

Source: Premier Inc