The American Hospital Association, which represents 5,000 member hospitals, health systems and other healthcare organizations, has submitted a letter to CMS commenting on its proposed hospital outpatient prospective payment system and ambulatory surgical center payment system rules for calendar year 2024.
For calendar year 2024, CMS has proposed an update of 3 percent less a productivity adjustment of 0.2 percentage points for ASCs. The AHA has "strong concerns about this inadequate update, especially when taken together with the underwhelming market basket increases from calendar year 2022 and 2023," according to the Sept. 8 letter.
The AHA believes proposed changes do not capture the current inflationary environment or the financial headwinds health systems are facing. It also does not account for high labor and supply costs that persist.
"We urge CMS to examine ways to account for these increased costs to ensure that beneficiaries continue to have access to quality outpatient care. We also urge the agency to reduce the productivity cut for calendar year 2024 as such a cut does not align with hospital and health systems' public health emergency experiences related to actual losses in productivity during the COVID-19 pandemic," the letter says.
CMS has also proposed changes to the hospital price transparency requirements. The AHA emphasized in its letter that it looks forward to improving these rules with CMS.
AHA's letter also expresses concerns about the agency's proposed policy to make separate payments under the inpatient PPS, and potentially under the OPPS, for the additional costs that hospitals face in establishing and maintaining access to a buffer stock of domestically manufactured essential drugs.
"While the AHA strongly agrees that it is necessary to support practices that can curtail shortages, we also continue to believe that much more must be done in addressing these concerns," they write.