Premier Comments on FY 2023 Inpatient Payment Proposed Rule

Premier submitted comments to the Centers for Medicare & Medicaid Services on the FY 2023 inpatient prospective payment (IPPS) proposed rule. In its response, Premier:

• Strongly recommends that CMS use its exceptions and adjustments authority to adjust the IPPS payment update to accurately reflect rising labor costs. A Premier PINC AI™ analysis found that labor costs have increased by > 16% since the start of FY 2021, which is significantly higher than what CMS used to set FY 2022 rates and is proposing for FY2023 rates.
• Supports adoption of an inpatient and outpatient payment adjustment using new dollars for domestically produced N95s and other critical medical supplies and pharmaceuticals.
• Urges CMS to advance standards for collection of social determinants of health (SDOH) and socio-demographic data using existing tools. As part of this, Premier urges CMS to consider all use cases for SDOH data to ensure data is collected and reported in a standardized manner that does not create undue provider burden.
• Supports establishment of a maternal care designation but encourages CMS to continue to explore other measures that move towards measuring outcomes.
• Applauds CMS’ proactive approach to addressing the COVID’s impact on quality measurement and encourages CMS to continue to work with stakeholders to ensure sufficient adjustments to capture COVID’s long-term impacts.
• Comments on how hospitals and other providers can better prepare for the impact of climate change on their patients.