“As the AHA has repeatedly argued in the past with respect to the FY 2008 and 2009 adjustments, there is a fundamental flaw in the CMS' methodology for determining the effect of documentation and coding,” wrote Richard Pollack, executive vice president at AHA. “Now, the agency proposes an additional cut of 0.8% with respect to FY 2010. The AHA is extremely troubled by this proposal and by the fact that CMS continues to compare hospitals' documentation and coding practices to their documentation and coding practices under an entirely different system in FY 2007,” he continued. “Doing so is highly inappropriate.”
Similarly, the Federation of American Hospitals—which represents more than 1,000 investor-owned or managed community hospitals and health systems—wrote that the additional cut for FY 2010 is “disconnected from reality of how the system has swiftly and substantially evolved and matured” after the introduction of MS-DRGs in 2007.
The two groups also commented on the hospital readmissions reduction program, which the Patient Protection and Affordable Care Act established. For 2013, AHA noted, the CMS indicated previously that it would use the three existing 30-day readmission measures for heart attack, heart failure and pneumonia patients. “However, CMS has not excluded all planned and unrelated readmissions from these measures, despite ongoing feedback from AHA and others,” according to the letter.
Meanwhile, Chip Kahn, president and CEO of the Federation of American Hospitals, wrote that the CMS does not address the effect of including either Pioneer or shared-savings accountable care organizations in the hospital readmission reduction program. “FAH recommends that CMS exercise its authority to either exempt them from the program or waive the penalty,” Kahn wrote.