As the Centers for Medicare and Medicaid Services (CMS) prepares to release the fiscal year (FY) 2016 Hospital Inpatient Prospective Payment System (IPPS) Notice of Proposed Rulemaking, the AAMC March 18 sent a letter to CMS outlining the association’s priorities and positions on key issues for the agency to address in the upcoming proposed rule.
The letter urges CMS to promptly replace the Two Midnight rule for stays that span less than two midnights. The AAMC maintains that the simplest and most equitable solution is to return to the longstanding deference to clinical judgment regarding inpatient admissions along with comprehensive recovery audit contract (RAC) program reform. At the same time, the immediate and clear priority is to alleviate the most onerous effects of the Two Midnight rule. To that end, the AAMC has modeled and evaluated in the letter various alternative short stay payment policies.
In the letter, the AAMC also urges CMS to consider and adopt the following policies:
- Extend the “Two Midnights” enforcement moratorium and “probe and educate” program;
- Repeal the 0.2 percent reduction to the standardized amount;
- Implement meaningful recovery audit contractor (RAC) program reform;
- Update guidance to allow residents to write inpatient orders;
- Clarify that de minimus rotations of medical residents to non-teaching hospitals will not trigger a hospital’s per resident amount or cap-building window;
- Adjust the Uncompensated Care Disproportionate Share (UC DSH) methodology to account for the appeals backlog;
- Implement a floor on weighted direct graduate medical education (DGME) caps to prevent penalizing hospitals training additional fellows above their 1996 caps; and
- Modify quality performance programs to reduce the disproportionate penalty for major teaching hospitals.