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Statement on FY 2022 Inpatient Prospective Payment System Rule

By Blair Childs, Senior Vice President, Public Affairs

Premier appreciates that the Centers for Medicare & Medicaid Services (CMS) is providing an option for Medicare Shared Savings Program (MSSP) ACOs to opt-out of advancing to the next level of risk for Payment Year (PY) 2022 due to the ongoing COVID-19 public health emergency. However, we are disappointed that ACOs will advance to the level of risk it would have participated in for PY 2023 absent deferral elections. The risk pathways established under MSSP provide for a gradual transition to risk. Skipping steps does not allow ACOs to gain experience with a lower level of risk first. To truly recognize the continued need to focus on COVID-19 care, ACOs should be able to pause their risk advancement and then continue on the pathway.

We are pleased that CMS has recognized hospitals’ continued need to adapt their care processes to respond to the pandemic by mitigating the impact of COVID-19 on quality measures. This will prevent a hospital’s quality score from telling a false story and being unfairly penalized.

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