The Task Force Provides Input to CMS on FY 2022 IPPS Proposed Rule

The Health Care Transformation Task Force filed comments on the Centers for Medicare and Medicaid Services (CMS) Medicare Hospital Inpatient Prospective Payment Systems (IPPS) Proposed Policy Changes and FY 2022 rates (CMS-1752-P).  

Task Force Response Summary

  1. RFI on Potential Expansion of the CMS Disparity Methods: Closing the Health Equity Gap in CMS Hospital Quality Programs.  HCTTF supports CMS’ goal of addressing the myriad issues related to health equity in the inpatient hospital setting, and the volume of accurate race, ethnicity, and other demographic data needed to do so.  The Task Force, however, does not support CMS’ proposed approach of using indirect estimation algorithms that utilize last name, zip code, and language preference to extrapolate critical demographics data.  Instead, the Task Force offers several recommendations for other methods to achieve this goal. The Task Force also urges CMS to look beyond race and ethnicity data and expand the notion of demographic data to include information that reflects other social determinants of health that have an impact on equitable access to health care.
  2. Hospital Inpatient Quality Reporting (IQR) Program. Proposed Maternal Morbidity Structural Measure.  The Task Force supports CMS’ proposal to implement a maternal mortality structural measure in the Inpatient Quality Reporting (IQR) program, as a step toward addressing the systemic inequities that exist for pregnant and birthing Black, Indigenous, and People of Color (BIPOC) people.
  3. Medicare Shared Savings Program Proposed Policy Changes. The Task Force supports CMS’ proposal to continue to allow ACOs in the MSSP to continue to “freeze” their operating track, or move to the subsequent level, depending on their readiness in light of the COVID-19 pandemic.  The Task Force appreciates CMS’ recognition that practices will benefit from additional flexibility during this challenging time, while they continue to drive toward downside risk.

Read the Full Letter