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Statement on the CY 2025 Hospital Outpatient Prospective Payment System Proposed Rule

By Soumi Saha, Senior Vice President, Government Affairs

Premier is deeply disappointed that the Centers for Medicare & Medicaid Services (CMS) is once again proposing an update for hospital outpatient services that will continue to widen the chasm between Medicare reimbursement and hospitals’ actual operational costs. It is no secret that the financial pressures hospitals are facing are being compounded by inflation, stubborn labor shortages and an aging demographic. Payment policies should empower hospitals to deliver exceptional, patient-centric care, but the proposed update falls short on this objective. CMS can course correct by implementing more robust methodologies and incorporating new data sources to accurately gauge hospitals' true costs, including comprehensive labor expenses.

Furthermore, Premier is disappointed in CMS’ proposal to move forward with the creation of a new Conditions of Participation (CoP) around obstetrics care. Premier supports the standardization of data collection and measurement and agrees with CMS that obstetrical care delivery standards can help address the maternal morbidity, mortality and maternity care access issues in the United States. However, any policy change to improve maternal outcomes must ensure that it does not reduce access to care. An obstetric services CoP that results in the loss of Medicare certification for compliance failure is far too harsh a penalty, resulting in further limits to obstetrical care and potentially higher rates of maternal morbidity and mortality. In trying to address the maternal crisis, the last thing we want to do is intensify disparities we know are already present in obstetrical care.

To address this problem head-on, the Department of Health and Human Services (HHS) Office of Women’s Health (OWH) has tapped into Premier’s extensive data to understand why disparate maternal outcomes occur. The HHS Perinatal Improvement Collaborative, a multi-year collaborative comprised of more than 220 hospitals from all 50 states and the District of Columbia, leverages standardized data and proven performance improvement methodology to scientifically identify root causes of maternal-infant mortality and morbidity. Premier urges CMS to hold on the creation of a CoP until the results of HHS’ work are available and instead focus on how it can improve data collection, standards and other elements of obstetrical care in the United States.

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