Premier Responds to Proposed FY 2022 Inpatient Payment Rule

In comments on the proposed FY 2022 inpatient prospective payment system rule, Premier supported CMS’ proposals to mitigate the impacts of COVID-19 across its value-based quality programs, but made several recommendations for how CMS could further strengthen these policies to ensure hospitals are not penalized for factors outside of their control, including:

• Broadening its suppression policy to address impacts on care for all patients
• Not publicly displaying rates that are impacted by COVID-19
• Excluding COVID-19 patients from additional measure calculations
• Monitoring data to address impacts of COVID-19 on future payment years

Additionally, Premier encouraged CMS to explore alternative avenues for analyzing and sharing information on COVID-19 related data, such as healthcare personnel vaccination rates or COVID-19 mortality rates. There is an opportunity for shared learnings to improve the nation’s response to the pandemic. However, we strongly discourage CMS from publicly reporting individual hospital data, as many factors are outside of their control and the data are not easily interpreted by consumers.

Premier also strongly recommended that CMS establish a glide path to risk for Medicare Shared Savings Program (MSSP) ACOs that opt to freeze their risk tracks and that CMS adopt additional policies to mitigate the impacts of COVID-19 on ACOs.

Finally, CMS is proposing several changes to its Medicare Promoting Interoperability program. Premier continues to recommend that CMS adopt policies that minimize regulatory and administrative burden for providers and that they harmonize rules and timelines with the Office of National Coordinator for Health Information Technology (ONC).