WHA Submits IPPS Comment Letter

Urges CMS to continue striving to restore fairness to wage index

June 25, 2019

On June 24, WHA submitted comments to the Centers for Medicare & Medicaid Services (CMS) on the proposed 2020 Inpatient Prospective Payment System. Among the list of topics WHA commented on were restoring fairness to the area wage index, more accurately covering hospitals’ graduate medical education costs, and reducing the regulatory burden in CMS’ Promoting Interoperability Program.

WHA praised CMS for its recent efforts to examine ways to restore fairness to the area wage index. This is an issue WHA has been very active in ever since the “Bay State Boondoggle,” which was inserted into the Affordable Care Act and ended up taking Medicare wage index payments from states like Wisconsin and sending them largely to coastal states.

The two changes in this rule would try to bring more equity to the wage index by:
  • Raising the wage index for hospitals in the bottom 25% by reducing the wage index for hospitals in the top 25%.
  • Stopping the negative impact of budget neutrality that has occurred when hospitals reclassify from urban to rural.

Overall, the wage index changes are a net benefit to Wisconsin hospitals. However, WHA urged CMS to focus more narrowly on the labor markets and states that have gamed the system to not penalize hospitals in naturally occurring high labor markets.

WHA focused its other comments on ways CMS could reduce the regulatory burden on physicians and hospitals in Medicare’s Promoting Interoperability Program. Specifically, WHA offered support in providing more flexibility for the meaningful use of certified electronic health records technology, removing the “Query of PDMP” measure, and removing the “Verify Opioid Treatment Agreement” measure. WHA noted this would be consistent with the U.S. Department of Health and Human Services’ stated policy of reducing the electronic health record regulatory burden.

For questions, contact WHA’s Director of Federal and State Relations Jon Hoelter or Assistant General Counsel Andrew Brenton.

This story originally appeared in the June 25, 2019 edition of WHA Newsletter