News: AHA opposes inpatient-only list elimination, applauds star rating revamp in comments to CMS
The American Hospital Association (AHA) has submitted a lengthy comment letter to CMS on behalf of its members in response to the outpatient prospective payment system (OPPS) proposed rule released in August.
In the comment letter, the AHA expressed strong opposition to four of the five issues on which they submitted comment. The only change the AHA supports, according to the comment letter, is CMS’ proposed changes to the hospital overall star ratings.
“The changes attempt to address the serious questions AHA and others have raised about the transparency and fairness of the ratings,” the letter says.
As they have in the past, the AHA continues to oppose the proposed cuts to the 340B drug pricing program and further stated that they “do not believe HHS has the legal authority to punitively target 340B hospitals in this manner.”
Additionally (and of particular interest to CDI professionals), the AHA expressed strong concerns over the proposed elimination of the inpatient-only list over a three-year period.
“Given the depth and breadth of the more than 1,700 procedures on [the inpatient-only list], it would be premature and myopic to adopt such a policy,” according to the letter.
First and foremost, the AHA says that the removal of the inpatient-only list poses a threat to patient safety as the procedures listed were placed on the list because they are complicated and/or invasive, requiring potential multi-day hospital stays. Secondly, the AHA says that the list’s elimination would pose a real and present financial threat to the security of hospitals.
“It would be unconscionable to finalize this policy when the financial impact of the COVID-19 public health emergency (PHE) has already been devastating for hospital—and there still remains an uncertain future as to the path of the pandemic,” the letter says, recommending instead that CMS continue with its standard process of removing procedures from the list when it is deemed that they are safe to conduct in the outpatient setting.
The comment letter also outlined the AHA’s concerns over the proposed changes to the ambulatory surgical center covered procedures list and the eased restrictions on physician-owned hospitals.
While the comment period for the OPPS proposed rule ended on October 5, CDI professionals can still make a difference on future rulemaking, particularly with the proposed COVID-19 code changes which, if adopted, take effect on January 1, 2021.