HomeWashington Letter2014 ▶ ATS Comments on Proposed CMS Inpatient Prospective Payment System Rule
ATS Comments on Proposed CMS Inpatient Prospective Payment System Rule

June 2014

This week, the American Thoracic Society submitted comment to the Centers for Medicare and Medicaid Services on the proposed rule governing payments, quality measures, and other policies for Medicare inpatient stays. While the rule covers a broad range of policies for hospital and long-term acute care hospitals, the ATS comments focused on areas specific to the pulmonary, critical care, and sleep community.

The ATS agreed with CMS's proposal to further refine the quality measure for COPD readmissions. CMS proposes to, and the ATS supports, removing planned readmission as triggering a COPD readmission for the purpose of the quality measure. As ATS notes, planned readmissions for COPD patient, either as a result of the patient's respiratory condition or other comorbidity, should not be included for the purposes COPD readmission rates calculation.

The ATS also expressed concerns with CMS's proposed measure for ventilator-associated events in long-term acute care hospitals (LTACH). CMS is proposing a new quality measure consisting of three components: 1) an admission assessment of functional status across five domains (self-care, mobility, cognitive, communication, and bladder continence), 2) an admission plan to improve functional status in these domains, including a target level of function at discharge, and 3) a discharge assessment of functional status. CMS proposes to tie FY18 payments to the successful completion of this measure. Additionally, CMS is proposing a new quality measure focused on measuring "change in mobility" during an LTACH stay and tying it to reimbursements starting in FY18.

While the ATS supports quality measures, we are concerned the proposed LTACH measures have not been validated by an externally validated and are being implemented under the Secretary of HHS's discretion and not through a public validation process.

CMS is expected to finalize the rule later in 2014 with implementation starting in 2015. Once finalized, the ATS will share with members the key policies in the final rule.

Last Reviewed: October 2017