Premier Responds to FY 2025 Medicare Inpatient Hospital Proposed Rule

Premier submitted comments to CMS’ FY 2025 Inpatient Prospective Payment System (IPPS)/Long-Term Care Hospital (LTCH) PPS proposed rule. Premier responds to several key areas, urging CMS to:

• Adopt new or supplemental data sources, such as PINC AI™ data, to ensure labor costs are adequately reflected in the Medicare hospital payment update in the final rule. Premier also strongly urges CMS to apply a one-time adjustment to course correct for its significantly lower estimates of the hospital market basket for FYs 2021-2024. At a minimum, CMS must address the gross underpayment that occurred in FY 2022 via a one-time adjustment of at least 3 percent.
• Solicit input from the hospital community on reforms to the wage index and efforts to improve the sustainability of workforce, especially in rural and underserved communities.
• Finalize its reclassification of the Z-codes representing housing insecurity/instability and consider ways to address persistent issues that may limit how accurately these and other Z-codes are capturing the significant resource use involved in providing care to underserved populations.
• Modify its buffer stock of essential medicines proposal to instead focus on establishing a differential reimbursement for domestically manufactured essential medications.
• Not finalize an increase to mandatory electronic clinical quality measure (eCQM) reporting requirements under the Hospital Inpatient Quality Reporting (IQR) and Medicare Promoting Interoperability Programs and instead continue to work with stakeholders to address persistent challenges with eCQM reporting and develop a strategy around advancing digital quality measurement.
• Modify its proposal to require hospitals to continue reporting certain data related to acute respiratory illnesses, including not tying the policy to a condition of participation (CoP) and providing hospitals with additional time before the policy goes into effect.
• Work with stakeholders to develop policies focused on improving maternal healthcare outcomes while ensuring CMS does not exacerbate access to care issues. As a result, Premier does not support the creation of a new CoP around obstetrics care, but rather offers feedback to help inform CMS’ thinking of how it can improve data collection, standards, and other elements of obstetrical care in the United States.