WHA Submits IPPS 2022 Comment Letter

July 01, 2021

On June 28, WHA submitted comments to the Centers for Medicare & Medicaid Services (CMS) on the proposed 2022 Inpatient Prospective Payment System (IPPS). Among the list of topics WHA urged CMS to reconsider were its proposals on mandating reporting of health care workers' COVID vaccination as a quality measure and its distribution of new Medicare Graduate Medical Education (GME) slots.

WHA also praised CMS for continuing its efforts to restore fairness to the Medicare area wage index, while expressing disappointment that Congress included an earmark that will exacerbate unfairness in the wage index. The American Rescue Plan Act of 2021 restored the imputed rural floor for three northeastern states. While it was fortunately done in a way that it will not reduce wage index payments for other states, it nevertheless unfairly manipulates the wage index to benefit only certain states at a time when the Medicare Trust Fund continues to face solvency concerns.

WHA also thanked CMS for promptly working to implement the Graduate Medical Education (GME) rotator cap fix to address an error that had unfairly penalized two Wisconsin hospitals. Those hospitals had hosted rotating residents for short periods of time and had their GME caps set at less than 1.0 full-time equivalent (FTE) employee when Congress implemented the GME cap in 1997. Congress finally addressed this long-time WHA priority when it passed the Consolidated Appropriations Act of 2021.

At the same time, WHA urged CMS to be more thoughtful about implementing other provisions of the Consolidated Appropriations Act that will add 200 new GME slots per year for the next five years. CMS proposed to cap new slots at 1.0 FTE per hospital due to the insufficient supply and overwhelming demand. However, its proposal would not allow for the slot to take into consideration the length of the residency, meaning a hospital receiving a slot would only create a new physician once every 3-5 years (depending on the length of the residency). WHA urged CMS to change the policy so a hospital receiving a slot would be able to produce a new physician every year, which is in line with Wisconsin's current highly successful GME grant program crafted by WHA that has created 125 new slots for Wisconsin.

CMS also proposed several changes to its quality reporting programs and the Promoting Interoperability Program in this year's rule update. WHA praised CMS for recognizing the potential for the pandemic to impact data measures and supported CMS's proposal to suppress a number of those measures for 2022. At the same time, WHA urged CMS to make the reporting of health care worker vaccinations optional, rather than mandatory, as a quality measure while the vaccines are under Emergency Use Authorization and more questions remain about the future need for booster vaccines. To reduce the administrative burden on hospitals, WHA urged CMS not to go forward with its proposal to increase the Promoting Interoperability electronic health record reporting period from 90 to 180 days.

Contact WHA Vice President of Federal and State Relations Jon Hoelter with questions.

This story originally appeared in the July 01, 2021 edition of WHA Newsletter