Recently multiple proposed rules impacting health care delivery and operations have been released. We will focus on those large Centers for Medicare and Medicaid Services (CMS) annual rate-setting rules. The Inpatient Prospective Payment System, Physician Fee Schedule, and Outpatient Prospective Payment System combined propose rates that comprise 35% of Medicare spend.
Key Takeaways
Inpatient Prospective Payment System (IPPS) – submitted June 29, 2021. This is the annual CMS rule impacting Medicare rates and quality programs for inpatient services. We anticipate CMS will release the final rule in the fall.
- Increasing Medicare rates by 3% for hospitals that successfully participate in the Hospital Inpatient Quality Reporting Program and are meaningful electronic health record users.
- Repealing the requirement that hospitals report on the Medicare cost report, ending on or after January 1, 2021.
- Due to the COVID-19 pandemic, suppressing most value-based purchasing program (VBP) measures so that hospitals will receive neutral payment adjustments under the VBP for FY 2022.
- Implementing several provisions of the year-end Consolidated Appropriations Act (CAA), including distributing 1,000 new Medicare-funded medical residency positions.
- Continuing health equity emphasis and incorporating health equity within hospital quality programs.
Physician Fee Schedule (PFS) – Due September 13, 2021. This is the annual CMS rule impacting Medicare Part B rates and quality programs impacting individual providers. It has historically also included quality measures for Accountable Care Organizations. We anticipate CMS will release the final rule in late fall.
- Extending coverage to the end of CY 2023 for services temporarily added to the Medicare Telehealth Services list during the pandemic.
- Updating underlying clinical labor cost data that may have a disproportionate positive impact on certain specialties with higher-than-average share of labor costs.
- Sunsetting the timeline to the Merit-based Incentive Payment System (MIPS) by end of 2027.
- Continuing health equity emphasis and incorporating health equity within hospital quality programs.
Outpatient Prospective Payment System (OPPS) – Due September 17, 2021. This is the annual CMS rule impacting Medicare rates and quality programs impacting facilities. It has historically also included 340B Drug Pricing Program provisions and site neutral proposals. We anticipate CMS will release the final rule in late fall.
- Withdrawing previous plans to eliminate the Inpatient Only (IPO) list and to expand the Ambulatory Surgery Center Covered Procedures List (CPL).
- Increasing penalties for hospitals under the recently established hospital price transparency program.
- Maintaining the 340B Drug Pricing Program rate cuts at average sales price (ASP) minus 22.5 percent for qualifying outpatient drugs. This rate is the subject of a U.S. Supreme Court case brought by the American Hospital Association and to be heard next term.
- Continuing health equity emphasis and incorporating health equity within hospital quality programs.
- Issuing a Request for Information (RFI) concerning the Rural Emergency Hospital (REH) designation established under the CAA.
- Implementing the Radiation Oncology Alternative Payment Model as of January 1, 2022.
The UnityPoint Health Government & External Affairs department serves as the primary liaison for submissions in response to state and federal public commenting. Our department partners closely with operational experts in the development and submission of comment letters to CMS.
View UnityPoint Health’s comment letters & summaries:
INPATIENT PPS SUMMARY |
INPATIENT PPS LETTER |
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OUTPATIENT PPS SUMMARY |
PROVIDER FEE SCHEDULE SUMMARY |
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For more information on Federal advocacy, legislative, policy and regulatory issues of impact to UnityPoint Health, please contact Cathy Simmons, executive director of government & external affairs for UnityPoint Health or Stephanie Collingwood, government & external affairs specialist.