Today, FAH submitted a letter to the Centers for Medicare & Medicaid Services (CMS) expressing strong support for the proposed rule addressing the impact of significant, anomalous, and highly suspect (SAHS) billing activities on the Medicare Shared Savings Program (MSSP) financial calculations for CY 2023. FAH commends CMS for its proactive measures to exclude payment amounts for specific urinary catheter codes, ensuring the integrity and fairness of MSSP ACO financial calculations. This proposal is a crucial step in mitigating the adverse effects of fraudulent billing on ACOs, enhancing their ability to deliver high-quality care and achieve cost savings.

In addition, FAH urges CMS to extend these protections to other value-based payment models, specifically the Bundled Payments for Care Improvement (BPCI) Advanced and Comprehensive Care for Joint Replacement (CJR) programs. FAH members participating in these programs have also experienced significant impacts from SAHS billing, with some hospitals reporting over $1,000,000 in fraudulent billing across multiple performance periods. By applying similar exclusions for these programs, CMS can further safeguard the financial viability of hospitals and support their continued participation in value-based care initiatives.

Read the letter here.