In a response to proposed changes to the hospital outpatient prospective payment system, the American Hospital Association voiced "serious concerns" about reporting requirements and payment reductions.
The AHA responded to changes proposed for the program by the Centers for Medicare & Medicaid Services in July.
The AHA came out with strong concerns about several components of the outpatient PPS quality reporting program proposed by CMS, particularly related to measures of medical imaging efficiency that CMS proposed for reporting.
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The measures "were still in the early stages of the National Quality Forum process when the proposed rule was released," the AHA's letter to CMS stated. "Because CMS did not provide sufficient detailed information about these measures in the proposed rule, it is impossible for the public to give appropriate and thorough comment."
The AHA wants the measures to go through assessment by NQF and the Hospital Quality Alliance, neither of which had endorsed the measures.
The AHA also said that it opposes CMS' proposal to create two cost centers for drugs, saying it would create "an unnecssary burden for hospitals, require significant changes to accounting and billing systems and add costs related to hospital compliance." The AHA contends that the new measures won't achieve improved payment accuracy.
"We are concerned that CMS continues to expand and complicate the cost report, an antiquated data collection instrument," the AHA letter said. "We urge CMS to engage with the field in a reasonable effort to design a current, accurate and useful tool that supports today's cost report uses."
The AHA also voiced concerns about CMS' proposed payment rate for separately covered outpatient drugs. That rate, the average sale price plus 4 percent, "does not adequately represent the acquisition cost of outpatient drugs and their related overhead costs," the AHA response said.
"CMS' payment methodology has been shown in a number of recent analyses to contain serious flaws, which leads us to conclude that this methodology should be revised," the AHA said.
The organization, which represents 5,500 hospitals nationwide, recommended a rate for separately covered outpatient drugs that is similar to that used in physician offices, which CMS reimburses at the average sales price plus 6 percent.