Today, FAH submitted comments to CMS on the proposed rule for the FY 2026 hospital inpatient prospective payment system (PPS) and long-term care hospital (LTCH) PPS. FAH comments focused on the following: 

Inpatient PPS:

• Recommended CMS apply a 4.6 percentage point adjustment to the IPPS update for unaddressed forecast errors from FY 2021–2024. This would result in a 7.0 percent net update: 3.2 percent market basket + 4.6 percent adjustment – 0.8 percent productivity.  
• Expressed support and urged CMS to finalize the UC-DSH estimates with any upward adjustments as appropriate based on other policy developments that may increase the number of uninsured before the rule is finalized. 
• Continued opposition to mandatory provider participation in any Centers for Medicare and Medicaid Innovation testing, including the Transforming Episode Accountability Model.  
• Opposed CMS proposal to include MA data on any measure in the hospital readmission reduction or value-based purchasing programs; and,
• Continue to oppose the mandatory reporting of the THA/TKA Pro PM measure.  

LTCH PPS:

Urged CMS to apply a one-time forecast error adjustment for understated FY 2021–2024 LTCH market baskets in the FY 2025 rate update. This would result in a 6.9 percent net update: 3.4 percent base + 4.3 percent forecast error – 0.8 percent productivity. 

Read the letter here.