WASHINGTON – The American Hospital Association and the Premier healthcare alliance have submitted separate comments to the Senate Finance Committee on its proposed options for reforming the healthcare delivery system.

The AHA supports proposals to develop a comprehensive strategy to address workforce shortages, redistribute unused graduate medical education slots to increase access to primary care and ban certain physician referrals to a hospital in which the physician has an ownership interest.

The association cautioned that some of the panel's specific proposals "would result in payment cuts to an already underfunded Medicare payment system" that could "negatively impact the nation's hospitals."

While agreeing in principle with moving forward on elements of value-based purchasing (VBP), bundling and readmissions proposals, the AHA raised a number of concerns about their impact, particularly on safety-net and small and rural hospitals.

Premier, a hospital group purchasing organization, endorsed VBP as "a tool that should be applied not only to existing Medicare payment models but also to the longer-term approaches such as bundled payments and the creation of Accountable Care Organizations."

However, the organization said the VBP program should promote quality improvement through incentive payments, rather than guarantee savings.

In regard to bundled payments, Premier said policy decisions should be based on experience and data, and an alternative to the proposed mandatory phase-in schedule is to begin with voluntary participation by hospitals and post-acute providers in testing a series of alternative models.

Premier also commented on proposed payment reductions to hospitals with the highest risk-adjusted readmission rates. The organization said an unintended consequence could be to punish those hospitals that have a "more socioeconomically complex mix of patients whose lack of community support systems are difficult to account for in risk adjustment models."

Instead, Premier contends a better approach would be incentivize the reduction of preventable readmissions into broader payment reforms (such as VBP, bundling or accountable care organization models) rather than as a case-by-case cut.

The Senate Finance Committee has issued health coverage options for health reform, and plans to issue financing options on May 18.